DRAFT ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN FOR DRILLING. Block 58 Suriname. Apache Suriname 58 Corporation LDC

Transcription

1 DRAFT ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN FOR DRILLING Block 58 Suriname Apache Suriname 58 Corporation LDC 1

2 DRAFT ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN FOR DRILLING, BLOCK 58 SURINAME APACHE SURINAME 58 CORPORATION LDC March

3 TABLE OF CONTENTS 1.0 OVERVIEW PURPOSE OF THE EMMP PROJECT OVERVIEW LEGAL FRAMEWORK AND STANDARDS RISK IDENTIFICATION AND MANAGEMENT ESIA IDENTIFIED POTENTIAL IMPACTS AND MITIGATION MEASURES Mitigation To Reduce Impacts On Commercial Fishing And Shipping Mitigation To Reduce Impacts From Accidental Fuel, Oil, Chemical Spills Mitigation To Reduce Impacts Resulting From Vessel Collisions Mitigation To Reduce Impacts Resulting From Wastes Mitigation To Reduce Impacts From Loss Of Well Control/Blow Out ENVIRONMENTAL IMPLEMENTATION STRATEGY Key Roles And Responsibilities Inductions And Training Monitoring, Recording And Incident Reporting Environmental Performance Objectives, Standards And Criteria Audit And Review Of Performance Stakeholder Consultation EMMP Table of Commitments FIGURES 1.0: Location of Block 58 Suriname : Location Of and Bathymetry at Block 58 Drilling Program... 8 TABLES Table 1: Block 58 Drilling Location and Coordinates... 9 Table 2: Key Personnel Environmental Responsibilities Table 3: Environmental Performance Objectives, Standards and Criteria

4 APPENDICES Appendix 1: Apache Corporate HSSE Policy Apache Worldwide EH&S Standards Apache Contractor EH&S Management Guidelines Appendix 2: NIMOS Letter Of No Objection To The Study Plan Appendix 3: Apache Corporate Environmental Risk Identification Procedure Appendix 4: Typical Shipboard Oil Pollution Emergency Plan - SOPEP Appendix 5: Typical Bunkering Procedure Appendix 6: Typical Collision Avoidance Procedure Appendix 7: Typical Garbage Management Plan Appendix 8: Typical Ballast & Bilge Water Management Procedure Appendix 9: Apache Environmental HazID Report Appendix 10: Typical Environmental Management Procedure Appendix 11: Apache New Ventures Incident Reporting Form Apache Suriname Waste Management Guidelines 4

5 DRAFT ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN FOR DRILLING BLOCK 58 OFFSHORE SURINAME APACHE SURINAME 58 CORPORATION LDC 1.0 OVERVIEW Environmental management of Apache Suriname 58 Corporation LDC (Apache) activities is implemented through a hierarchy of policies, plans and procedures from the corporate level to the regional business units and their individual operations. These policies and procedures are set forth in the Apache Corporation Environmental Policy, the Safety Policy, the Apache Worldwide Environmental, Health and Safety (EH&S) Standards, the Contractor EH&S Management Guidelines and other documents. (Appendix 1) NIMOS designated the Block 58 exploratory well drilling project (drilling project) as Category B Path 3, requiring completion of an Environmental and Social Impact Assessment (ESIA) and an Environmental Management and Monitoring Plan (EMMP) prior to project approval (Appendix 2). The Block 58 drilling program will be conducted by a third party drilling contractor. This EMMP will be implemented by subcontracted third party personnel, onboard the drillship and support vessels that operate under the subcontractor s EH&S management systems. These systems include elements such as the environment, general shipboard management, and procedures for the bridge, engine room, deck, and drilling equipment. It is Apache s responsibility to ensure the drilling subcontractor s environmental management programs are aligned with this EMMP. Apache has reviewed the contractor s plans, processes and procedures to ensure they are acceptable for use during this drilling operation. The EMMP has been prepared by Apache s Corporate Health, Safety, Security and Environmental (HSSE) Department. The initial draft EMMP documents were reviewed prior to submittal to NIMOS by the independent environmental consulting firm CSA Ocean Sciences Inc. (CSA), 8502 SW Kansas Ave, Stuart, Florida and comments have been incorporated into this draft. CSA did not review subsequent drafts of the document. 1.1 PURPOSE OF THE EMMP The purpose of this EMMP is to ensure that the drilling project in Block 58 offshore Suriname is conducted in accordance with the controls and mitigation measures adopted to minimize potential significant environmental impacts identified in the environmental hazard identification assessment and the ESIA. The EMMP will: Ensure compliance with Suriname legislation, international legislation, Apache s EH&S policies, procedures and guidelines, and industry best practice; 5

6 Provide a strategy for mitigating predicted impacts and impacts that may be unforeseen or unidentified until drilling activity is underway; and Provide a plan to assure Apache that environmental performance targets are being met. The EMMP will be reviewed during the course of the project to ensure its provisions are being implemented and that environmental controls are effectively mitigating predicted impacts. Findings will be reported to management teams and the EMMP will be amended if necessary. 1.2 PROJECT OVERVIEW Apache is obligated to undertake an exploration drilling program within offshore Block 58 (Figure 1.0) under the terms of the Production Sharing Contract (PSC) with Staatsolie. The purpose of the drilling program is to evaluate sub-surface geological features that may contain oil and gas in Block 58, characterized from a recent 3-D seismic program and drilling of the Block 53 Popokai-1 and Kolibire-1 wells. Data from the D marine seismic survey is being processed and interpreted. The initial consideration of Apache is that waters deeper than 600 meters, into the abyssal plain of the northern area of Block 58 (Figure 1.1), would likely be the location for the first exploration well, utilizing a dynamic-positioning (DP) drill ship and support vessels. The southern portion of Block 58, with water depths of approximately 50 to 100 meters and part of the shelf break in 100 to 600 meters, would require a different type of drilling facility. If drilling is later considered for Block 58 waters less than 600 meters in depth, additional water quality, seafloor sediment sampling and other baseline environmental information will have to be provided as part of an Addendum to an approved Block 58 ESIA. Any additional environmental management or monitoring requirements for these waters would be included in an Addendum to this EMMP. Apache is considering drilling operations over an as yet unidentified portion of Block 58. The ESIA will contain refined estimates of well timing and drilling duration. Because of the current uncertainty of the proposed drilling locations, the ESIA will cover the entirety of Block 58. Apache s key environmental objectives for the proposed drilling program are to ensure: No significant water quality impacts resulting from contamination of the marine environment; Minimal reduction in air quality due to exhaust emissions; and No significant disruption of international shipping or fishing activities. 6

7 Figure 1.0: Block 58 Location 7

8 Figure 1.1: Location and Bathymetry of Block 58 Suriname 8

9 Table 1: Block 58 Drilling Location and Coordinates Characteristic Wellsite Information Operator Location X Y Latitude Longitude Well Type Water Depth Proposed Spud Date 1Q 2018 Total Drilling Time Datum: WGS84, UTM Zone: 21N Apache Suriname 58 Corporation LDC Block 58 Offshore Suriname Final Location to be determined Final Location to be determined Final Location to be determined Final Location to be determined Vertical exploration well Greater than 600 meters 90 to 120 days * see Figure 1.1 for geographical location and bathymetry of proposed drilling area. 1.3 LEGAL FRAMEWORK AND STANDARDS Environmental issues relevant to the proposed drilling project are governed or guided by a number of standards including: Suriname legislation; Safety guidance from the National Coordinating Body for Calamities NCCR (National Coordinate Centrum Suriname) as applicable; Civil aviation regulations from the Civil Aviation Department of Suriname (CADSUR) and the Civil Aviation Safety Authority Suriname (CASAS); Apache s EH&S policies, standards and guidelines; Standards established by industry codes of practice, such as the IMO (International Maritime Organization), IADC (International Association of Drilling Contractors), IPIECA (International Petroleum Industry Environmental Conservation Association), API (American Petroleum Institute), and OGP (International Association of Oil & Gas Producers); and Relevant international standards and conventions such as World Bank Group and IFC environmental standards (if applicable). 9

10 The ESIA guidelines from the Nationaal Instituut voor Milieu en Ontwikkeling in Suriname (NIMOS), designate the Apache drilling project as Category B Path3, requiring the completion of a full Environmental and Social Impact Assessment (ESIA) and an Environmental Management and Monitoring Plan (EMMP). A Study Plan was prepared and submitted to NIMOS on June 30, A stakeholder consultation meeting (SCM) on the proposed project was held in Paramaribo on September 26, Comments received from NIMOS and the minutes from the meeting during the SCM will be incorporated into the final ESIA and EMMP. NIMOS issued a letter of no objection to the Study Plan on December 5, 2017 provided that the ESIA would be conducted according to the Study Plan (Appendix 2). 1.4 RISK IDENTIFICATION AND MANAGEMENT The objective of the Environmental Risk Identification Procedure is to ensure that potential environmental risks are identified, assessed, managed and communicated. The communications reaches out to all parties involved in the planning, development, installation and construction of the operational phases of the project. Implicit is the requirement to comply with Apache s Worldwide EH&S Standards, the Environmental Policy, the Safety Policy, the Contractor EH&S Management Guidelines and other controlling documents. (Appendix 1) Apache and their subcontractors will continually evaluate the risks to their business, workforce, and the environment. Comprehensive hazard analysis and risk control provides the necessary information to prevent risks and mitigate the impact of operations on health, safety, and the environment. The purpose of the risk identification procedure is to provide standards and/or guidelines for: Identification of major risks associated with each phase of a project or activity that may impact the environment or a component thereof. Ranking risks in terms of likelihood and severity. Methods of quantifying releases and probability of occurrence (where possible). Determination whether each risk has the potential to impact the environment, and Methods to provide engineering and procedural controls into the design and operations of the project at an early stage so that environmental risks can be managed to as low as reasonably practical (ALARP). 10

11 The Apache Corporate Environmental Risk Identification Procedure is provided in Appendix 3 of this document. The selected drilling contractor also evaluates its operations and identifies environmental risks associated with its operations and vessels. 1.5 ESIA IDENTIFIED POTENTIAL IMPACTS AND MITIGATION MEASURES Apache understands that management of potential environmental risks is an important component of the project. To aid identification of potential risks and mitigation measures that could be incorporated into the project design, an Environmental Impact Identification (ENVID) Analysis workshop was conducted for the proposed drilling project. ENVID Analysis aims to identify potential risks that require management controls during all stages of project development. An ENVID for the Suriname offshore drilling program was conducted on February 26, 2014 at Apache s corporate office in Houston, Texas. The workshop was attended by key project team members including drilling, environment, reservoir, geology, exploration, security, emergency response, and the selected drilling contractor. The ENVID was facilitated by an external consultancy firm AECOM and the results are included in Section 5 of the ESIA. Apache has utilized this ENVID for both the Popokai-1 and Kolibrie-1 drilling programs. The Block 53 drilling programs are identical to those proposed for portions of Block 58, the difference being the physical location of the wellbore and variations in water depths. It is Apache s intent to utilize the existing ENVID for the proposed drilling program in Block 58. The Environmental Impact Identification Procedure identified several aspects of the project with potential for significant environmental impacts. The procedure also identified the mitigations required to avoid, minimize, and reduce these potential negative impacts. Mitigation measures have been established and will be implemented during the project to ensure residual impacts are managed to as low as reasonably possible (ALARP) Mitigation to Reduce Impacts on Commercial Fishing and Shipping The following mitigation measures will be implemented to avoid or reduce potential impacts to the fishing community and shipping interests in the area: Measure 1: Fisheries Consultations Prior to the start of the drilling operation, a public consultation will be held with local fishing interests. This multi-language consultation will provide information to the fishing community on the location of the drilling and specific times activities will occur. This will allow fishermen to plan their activities in areas well away from drilling operations. See Section on Stakeholder Engagement for additional details. 11

12 Measure 2: Notices to Mariners Notices to mariners will be issued by the Maritime Authority Suriname (MAS) to provide adequate warning to shipping and fishing vessels regarding the drilling vessel s activities. Measure 3: Radio broadcasts Broadcasts regarding the activity and position of the drilling vessel on appropriate shipping channels will be provided. This will ensure that other vessels have adequate notification to alter their intended course and prevent collisions. Measure 4: Support and Chase vessels The drilling vessel will be accompanied at all times during the drilling activities by four other vessels. The Platform Supply Vessels (PSV s) will provide fuel and supplies to the drilling vessel. They will also provide assistance as necessary and help ward off other vessels from entering the exclusion zone surrounding the drilling vessel. (described in Measures 5, 6 and 7). There will always be a minimum of one vessel remaining on duty with the drilling vessel at the project site. Measure 5: Radar and detection equipment The drilling vessel, the support vessels will be equipped with adequate and continuously-manned radar equipment to detect any other vessels that may threaten safety and potentially interfere with the drilling process. Measure 6: Multi-language handouts explaining the drilling activities will be provided for those fishing vessels in the area manned by non-local crews. Measure 7: Protect integrity of the safety zone The primary responsibility of the support vessels is protecting the integrity of the safety zone around the drilling vessel at all times Mitigation to Reduce Impacts from Accidental Fuel, Oil and Chemical Spills Vessels associated with this project maintain and implement a Shipboard Oil Pollution Emergency Plan (SOPEP). Bunkering at sea shall preferably be carried out during daylight hours with suitable weather conditions to minimize potential spillages during the operation. The vessel Master and the Chief Engineer shall evaluate the conditions and it is their responsibility to decide whether to proceed with the operation. The Chief Engineer is responsible for bunkering and de-bunkering and for all fuel tank preparation, as required. Detailed work instructions are in place. Before transfer operations commence, the appropriate warning signals shall be posted, necessary communications systems tested and personnel assigned to their duties. The following specific measures will prevent or minimize impacts from any fuel or oil releases that do take place: 12

13 Measure 1: Shipboard Oil Pollution Emergency Plan (SOPEP) The vessels maintain and implement a shipboard SOPEP as required by MARPOL Annex I, Regulation 26. The contractor also maintains an Oil Record Book as required under MARPOL 73/78. The SOPEP for the selected drilling vessel is in Appendix 4. Measure 2: Oil, grease and chemical containment Oils, greases, other hydrocarbons and chemicals will be stored in designated containment areas onboard the drilling vessel. Measure 3: Sorbent materials Sorbent materials will be maintained aboard the vessels and used to clean up any minor spill onboard the drilling vessel. Stocks of absorbent materials will be checked for adequacy and replenished as needed prior to and during the drilling operation. Measure 4: Fuel transfer protocols Strict fuel transfer procedures are implemented to prevent spills during the loading of fuel at the Port of Paramaribo and during transfers between supply vessels and the drilling vessel. In the event of a spill of oil or other products, the SOPEP will be initiated in response to the incident and it will be promptly reported through the contractor chain-of-command to Apache and Surinamese Authorities. See Appendix 5 for the Fuel Transfer (Bunkering) Procedure Mitigation to Reduce Impacts Resulting from Vessel Collisions The majority of the shipping activity occurs to the west, east and north of the drilling area and as such poses low risk for collision with the project vessels. However, there is the potential for vessel traffic transiting from and to the Port of Paramaribo to potentially pass through the drilling project area. The drill ship SOPEP provides guidance on collision prevention and response (Appendix 6). The potential for a hydrocarbon spill resulting from the collision of one of the drilling project vessels with another ocean going vessel is considered negligible with the following mitigations measures implemented: Measure 1: Radio communications Radio communications will be established and maintained with any vessels observed transiting the area. The PSV s will be used to warn off other vessels that navigate close to the 1,000m exclusion zone surrounding the drilling vessel. Measure 2: Notice to Mariners - Information on the location and timing of the drilling program will be communicated to vessels via MAS through a Notice to Mariners. Measure 3: Support Vessels Vessels will assist in scouting and communicating with other vessels in the area. All vessels involved in the drilling will be equipped with continuously manned radar, marine radios and watchmen. Measure 4: Consultations - Notification of the position of the drilling vessel will be 13

14 communicated to fishing industry representatives and forwarded to respective vessel owners. Measure 5: Established shipping lanes There are no established shipping lanes across the drilling project area, reducing the opportunity for frequent marine vessel traffic through the project area. Measure 6: Double hull vessels The dedicated drilling vessel is constructed with a double hull as a mitigation measure to reduce the likelihood of fluids from the vessel (fuel oil, lubricating oil, chemicals, etc.) being released into the marine environment as a result of a collision. There are no fuels or oils in direct contact with the outer hull of the vessel. Measure 7: Segregated fuel tanks All of the vessels involved in the drilling program maintain their fuel inventory in segregated fuel storage tanks. All of the fuel is NOT contained in a single tank. If a collision should occur and a fuel tank is compromised, only the fuel volume in the smaller, segregated tank could potentially be released to the marine environment. It is highly unlikely that all of the fuel tanks would be compromised during a significant collision Mitigation to Reduce Impacts Resulting From Wastes A number of potential waste streams are generated by vessels involved in the drilling process. Solid wastes generated onboard will be segregated and recyclable materials will be reserved. Non-recyclable materials will be handled in accordance with the contractor Waste Management and Garbage Management Plans. Ballast water and sewage will be handled and discharged in accordance with international regulations and the contractor management plans. Measure 1: Solid wastes - All solid waste procedures comply with MARPOL requirements. Correct segregation of solid and hazardous wastes in accordance with the vessel management plan. A vessel Waste Log is kept detailing quantities of wastes transported ashore. Waste bins will be closed at all times to prevent rubbish blowing into the marine environment. Solid wastes and garbage will be handled according to the drill ship waste management procedures (Appendix 7). All food wastes will be incinerated onboard the vessel. Those solid wastes which cannot be recycled and are not incinerated will be minimized and stored onboard the drilling vessel for later shipment to Trinidad for disposal. Frequency of solid waste shipments/disposal will be dependent upon volume and vessel storage capacity. Measure 2: Ballast water management The ballast and bilge management procedures (Appendix 8) provided by the contractor ensures that ballast is handled such that the 14

15 transfer of harmful aquatic organisms and pathogens from the ship ballast water is minimized.. It shall always be exchanged or diluted (by overfilling) in deep sea and before entering the coastal waters. Additionally, a separate procedure is in place for preventing transfer of aquatic pest species by sealing overboard valves prior to entering port or other environmentally sensitive zones. The vessels also maintain an up to date ballast water log. Measure 3: Treatment and disposal of sewage Class-approved sewage treatment systems are in place and operational on all vessels. The drilling vessel also includes maceration and disinfection (tertiary treatment). Relevant discharge requirements are adhered to and sewage is not discharged within 12 nautical miles of the coastline unless the vessel has a certified approved sewage treatment plant in place under Regulation 8 (1) (b) of MARPOL 73/78 Annex IV. Frequency and volume of treated sanitary effluent discharge will be determined by volume of waste water generated by the vessels. Operational logs will be provided at the end of the project, if requested. Measure 4: Bilge water management Bilge water is cleaned and discharged through a bilge water separator in accordance with MARPOL requirements. The water quality of the discharged effluent meets or exceeds requirements set by MARPOL. Frequency of bilge water discharges will be determined by the requirements of the vessel for safe and proper operations. Operational logs will be provided at the end of the project, if requested. Measure 5: Air Emissions The vessel selected to perform the drilling project will be an advanced design drilling vessel that incorporates proven technologies to reduce air and gaseous emissions. These vessels typically utilize the DNV Clean Design; high specification exhaust catalysts in combination with use of Urea to reduce NOx emissions; and uses MGO with a low-sulphur content to reduce SOx emissions. Measure 6: Drill Fluids - To ensure that drill fluids impacts to water quality are minimal, a series of drill fluid toxicity tests will be conducted during the drilling program. The standard Gulf of Mexico drilling fluids toxicity test (96-hour LC50 according to EPA Effluent Limitations Guidelines for oil & gas offshore drilling activities) will be conducted on the drilling fluid system at the start of drilling, once per month during the drilling program, when fluid systems are replaced, and at the end of the well Mitigation to Reduce Impacts From Loss of Well Control/Blow Out Although unlikely to happen, loss of well control/blow out must be considered as a possible hazard during well drilling. The following mitigation measures will be implemented to avoid or 15

16 reduce potential impacts to the environment should loss of well control/blow out occur during the drilling operation: Measure 1: Shallow Hazard Assessment Apache has completed a pre-drilling Regional Shallow Geohazard Screening Assessment of Block 58, and a detailed Shallow Geohazard Assessment of the selected wellsite to determine if any shallow drilling hazards exist. The shallow hazard assessment is based on a 3-D exploration (3DX) seismic depth volume and available offset data. Site specific shallow hazard site assessments will be conducted for the subsequent wells once their coordinates have been developed. Measure 2: Blow Out Preventer Blow Out Preventers (BOPs) are safety devices used to "prevent" the uncontrolled flow of liquids and gases during well drilling operations. Blowout preventers are large, high-pressure valves that are capable of being remotely controlled. When the driller closes the valve, a pressure-tight seal is formed at the top of the well, preventing the fluids from escaping. A BOP will be utilized during the entire drilling operation. Measure 3: Well Contingency Plan/Blow Out Plan The drilling contractor s well control plan will be bridged to Apache s Well Control Plan. Apache has contracted Wild Well Control to provide the Well Control Plan and a capping stack if it becomes necessary to install such a device. Measure 4: Spill Response Capabilities Apache has international contracts with providers to supply spill response equipment, personnel and supplies. The PSV s will be capable of utilizing dispersant application systems and a supply of dispersant will be maintained as a first line of defense. OSRL will respond with aircraft to be used for dispersant application and a supply of dispersant. Details of the spill response capabilities will be presented in the forthcoming Oil Spill Response Plan (OSRP) that will be included in the ESIA. The Environmental Hazard Identification Report in Appendix 9 presents all of the mitigation measures to be utilized. 1.6 ENVIRONMENTAL IMPLEMENTATION STRATEGY Mitigation measures that will be implemented to reduce environmental risks have been described in Section 1.5 above. This section details the key roles and responsibilities and additional controls to be implemented during the proposed Block 58 drilling to safeguard against the potential environmental impacts and effects identified in previous sections. 16

17 These controls consist of both procedural and operational practices that will be undertaken during the drilling project to protect against any adverse environmental impact. Such controls are recognized as additional measures to further manage environmental risks. A number of the above environmental mitigation procedures and processes discussed above in Section 1.5 are also addressed in a typical contractor Environmental Management Procedure (Appendix 10) Key Roles and Responsibilities The organization and structure of the seismic program including the roles and responsibilities for all key personnel onboard the drilling vessel are described in the Contract Plan between Apache and the drilling contractor. With respect to this EMMP, the responsibilities of key personnel are outlined in the table below. Table 2: Key Personnel Environmental Responsibilities Key Personnel Environmental Responsibilities Vessel Masters Safe execution of all operations of the associated vessels. EHS management onboard the vessels and ensuring that appropriate control and mitigation measures are implemented to minimize potential environmental effects resulting from vessel operations. Immediate notification to the Apache Site Representative of any incidents or activities arising from vessel operations that are likely to impact on the environmental performance objectives detailed in the EMMP. Onboard EHS Representative Safe execution of all operations carried out by the drilling crew and contractors onboard the drilling vessel. Ensure that appropriate control and mitigation measures are implemented to minimize potential environmental effects resulting from the drilling project. Ensure compliance with all aspects of EHS reporting and for investigations of all incidents and near misses. Immediate notification to the Apache Site Representative of any incidents or activities arising from drilling operation that are likely to impact on the environmental performance objectives detailed in Table 2. Apache Site Representative Ensure that all subcontractors perform operations in a manner consistent with the environmental performance 17

18 Key Personnel (Company Personnel) Apache Suriname Country Manager Environmental Responsibilities objectives and management procedures detailed in this document (Table 2). Ensure that the Vessel Master and Onboard EHS Representative adhere to the requirements of this document (Table 2). Keep fully appraised of ongoing operations Immediate notification to the Apache Suriname Country Manager and the Apache Corporate Sr. EH&S Staff Specialist of any reportable incidents or changes in operations that could have an impact on environmental performance and adherence to this document (Table 2). Ensure that the Designated Authority is notified as soon as practicable of all reportable incidents. Ensure full briefing of project personnel of the environmental sensitivities of the drilling area and the environmental management procedures and commitments detailed in this document (Table 2). Responsible for communicating details of the drilling program to relevant government agencies and fishing industry in advance of operations commencing. All personnel in all areas of Apache s activities are responsible for applying the Apache policies, guidelines and procedures in Appendix Inductions and Training All drilling personnel will participate in an environmental induction prior to commencement of drilling. The induction will introduce the EMMP, describe the environmental aims for the drilling project, identify the procedures in place to achieve those aims, and discuss the specific environmental sensitivities of the region. The purpose of this induction is to identify and impart environmental responsibility among all personnel. Specific issues that will be highlighted include: Location of environmentally sensitive marine areas in the immediate vicinity of the drilling area and greater area of Suriname. General housekeeping procedures for all vessels. Precautionary measures to avoid spillage of anything into the marine environment. 18

19 Reporting arrangements for incidents including spills (all spillage on deck must be reported to the Apache Site Representative for reporting to the Apache Suriname Country Manager and NIMOS. If smaller spills reach the marine environment, these must also be reported). Limits for oil in water required to be followed for oily water discharge. Emphasizing the importance of proper storage of chemicals and drums. The integrity of drums should be checked to ensure they are not leaking. Drums of liquid must be within secondary containment. Personnel with responsibilities in specific environmental practices will be adequately trained to ensure effective implementation of the Work Instructions and Procedures for which they have responsibilities Monitoring, Recording and Incident Reporting The following monitoring and records will be kept throughout the Block 58 drilling project: All waste materials removed from the vessel including waste oils reported in the Garbage Log and Oil Record Log. Interactions with all commercial fishing vessels or equipment in the drilling area or exclusion zone. Any environmental incidents including oil spills and non-routine discharges. Incident Reporting All incidents that have the potential to cause significant effects on the environment must be reported and investigated according to legislative requirements, drilling vessel procedures and the Apache Environmental Policy. The designated authority (NIMOS) will be notified of all incidents. Incidents would include: Observed impacts to cetaceans. Spills of oil or fuel on deck and to the marine environment. Adverse impacts with commercial fishing activities. Apache is responsible for providing written reports on any reportable incidents to NIMOS. Additionally, incidents must be reported to NIMOS within 24 hours of the incident being detected. Incident reports will contain: All material facts and circumstances concerning the incident. 19

20 Any actions taken to avoid or mitigate any adverse environmental impacts of the incident; and, Corrective action(s) that have been taken, or are proposed to be taken, to prevent a similar incident. A comprehensive incident reporting form is included as an example in Appendix 11. Apache has an All Hazards Emergency Response Plan in place. This information and management controls will be used to manage any response from an oil spill or other types of incidents associated with the drilling project. The Regional All Hazards Emergency Response Plan applies to Apache offshore and onshore operations on a regional level. The ERP is designed to provide a systematic approach to respond to any emergency in an effective, efficient and professional manner. Objectives of the plan include: To ensure personnel safety. To stabilize the incident and/or secure the source. To protect the environment. To minimize damage to property, assets, and brand. To ensure timely notification of civil authorities and company management personnel. To comply with all applicable laws and regulations. To provide a structured and scalable response system with clear lines of communication and accountability for emergency response measures. To prepare the Apache business units and personnel through training, exercises and drills to effectively respond to incidents. To provide guidelines for communications within the organization, with the partnership/family companies and with the general media /public. Apache is committed to utilizing the National Incident Management System (NIMS) Incident Command System (ICS) as the response framework for incidents that may occur. Recording and Reporting The Apache Suriname Country Manager, or a representative, will be responsible for sending weekly reports to NIMOS outlining the status of the drilling as well as information on any environmental issues encountered. Internal and government reporting on performance 20

21 standards will be carried out by the Corporate Global Environmental Manager or their delegate, and distributed to the company and government on the completion of the drilling Environmental Performance Objectives, Standards and Criteria The environmental performance of the drilling project can be measured, benchmarked and reported. Environmental performance objectives, standards and criteria are described in Table 2. They are compiled from the risk assessment completed for the ESIA Audit and Review of Performance The Apache Site Representative or their nominated representative will conduct a compliance audit against the environmental management controls listed in this document (Table 2) during the drilling project. The representative will forward the results to the Apache Suriname Country Manager. Any required remedial actions will be carried out immediately. A copy of the environmental audit will be forwarded to NIMOS. Table 3: Environmental Performance Objectives, Standards and Criteria Objectives Standards Criteria Reporting Minimize disturbance to benthic habitats Minimize light overspill to the marine environment Apache Environmental Management Policy Drilling Project Environmental Management & Monitoring Plan (EMMP) Apache Environment Policy Drilling Project Environmental Management & Monitoring Plan (EMMP) No anchoring of the vessel will take place during the drilling unless in an emergency Recording and reporting of all items lost overboard Display of appropriate navigational beacons and lights required for safely operating a vessel at night Minimize redundant or non-essential nighttime lights that shine onto the sea surface Report location and duration of any drilling vessel anchoring incidents to NIMOS Provide report of items lost overboard to NIMOS Perform pre-drill and post-drill ROV surveys No reporting required 21

22 Objectives Standards Criteria Reporting Minimize interference with other users Apache Environment Policy Drilling Project Environmental Management & Monitoring Plan (EMMP) Issuance of Notice to Mariners Display of appropriate navigational beacons and lights Radar watch Use of supply and chase vessels to manage interactions with fishing vessels Provide final report of recorded vessel sightings and interactions to NIMOS/MAS/Dept. of Fisheries at conclusion of project Recording of sightings of fishing vessels Operations carried out in a manner that does not interfere with fishing to a greater extent than is necessary Minimize interference with shipping traffic Apache Environment Policy Drilling Project Environmental Management & Monitoring Plan (EMMP) Issuance of Notice to Mariners Display of appropriate navigational beacons and lights Radar watch Provide report of recorded shipping traffic interactions to NIMOS/MAS at conclusion of project Radio warnings to shipping, as required Operations carried out in a manner that does not interfere with navigation to a greater extent than is necessary 22

23 Objectives Standards Criteria Reporting Minimize effects of sewage discharge MARPOL 73/78 Annex IV Apache Environment Policy Contractor Environmental Management System Contractor Environmental Protection Procedures for Marine Operations Drilling Project Environmental Management & Monitoring Plan (EMMP) Procedures for treatment and disposal of sewage are in place Sewage treatment system operational and includes maceration and disinfection (tertiary treatment) with no discharge to the marine environment at the project site (stored in holding tanks) Report any incidents relating to sewage discharges not in compliance with MARPOL, Apache and Contractor standards to NIMOS Relevant discharge requirements are adhered to Sewage not discharged within 12 nautical miles of the coastline unless vessel has a certified approved sewage treatment plant in place under Regulation 8 (1) (b) of MARPOL 73/78 Annex IV. 23

24 Objectives Standards Criteria Reporting Minimize occurrence and effects of fuel and oil spills MARPOL 73/78 Annex I Apache Environment Policy Contractor Environment Policy Contractor Environmental Management System Contractor Environmental Protection Procedures for Marine Operations Drilling Project Environmental Management & Monitoring Plan (EMMP) Contractor SOPEP (Shipboard Oil Pollution Emergency Plan) Contractor Bunkering Offshore Instruction (Appendix 6) Apache All Hazards Plan Procedures comply with MARPOL 73/78 requirements MARPOL Oil Record Log kept up to date Refueling to occur as per Apache s or Contractor companies procedure Fuel spill contingency procedures are in place and operational Designated containment areas onboard the vessel for storage of oils, greases Sufficient spill response equipment on board to respond to foreseeable spill events Appropriate actions are taken to minimize pollution Any incident resulting in significant release of oil, fuel or chemicals to the marine environment will be reported to NIMOS Logs of waste materials removed from vessel including Garbage Log and Oil Record Log. A summary of these logs will be provided to NIMOS. Any significant spills are reported to Apache and NIMOS Personnel responsibilities are clearly identified Bathymetry of areas known (no shallow areas identified in the drilling area) Double hull drilling vessel. 24

25 Objectives Standards Criteria Reporting Minimize potential impacts of solid and hazardous wastes MARPOL 73/78 Annex V Apache Environment Policy Contractor Environment Policy Contractor Environmental Management System Contractor Environmental Protection Procedures for Marine Operations Drilling Project Environmental Management & Monitoring Plan (EMMP) Correct segregation of solid and hazardous wastes A vessel Waste Log is kept detailing quantities of wastes transported ashore Procedures comply with MARPOL requirements Waste bins will be closed at all times to prevent rubbish blowing into the marine environment Waste log detailing quantities of wastes transported to Paramaribo will be provided to NIMOS at the end of the project Contractor waste management plan Minimize potential for introduction of marine pests Apache Environment Policy Contractor Environment Policy Contractor Environmental Management System Contractor Environmental Protection Procedures for Marine Operations Drilling Project Environmental Management & Monitoring Plan (EMMP) Procedures comply with International Ballast Water Management Guidelines Vessels ballast water log is kept up to date Open ocean transfer prior to entering Suriname waters Visual checks and cleaning if necessary of marine gear Copy of Vessel Ballast Water Log entries during project will be provided to NIMOS at the end of the project. 25

26 1.6.6 Stakeholder Consultation A consultation meeting to discuss the Study Plan was held in Paramaribo on September 26, The meeting consisted of a presentation regarding the Draft Study Plan and forthcoming ESIA for the proposed drilling project. The discussion followed an open question and answer format. The minutes of the meeting and an attendance sheet are provided in the Final Study Plan and in ESIA Appendix 1. All comments received during this meeting were integrated in the Final Study Plan. Additional consultation meetings with MAS, LVV and commercial fishing interests will be conducted by Apache prior to the arrival of the drillship in Suriname waters. 26

27 1.7 EMMP Table of Commitments Block 58 EMMP Document Table of Commitments EMMP Commitments Location in EMMP It is Apache s responsibility to ensure the drilling subcontractor s environmental management Sec. 1.0 programs are aligned with this EMMP. Apache has reviewed the contractor s plans, processes and procedures to ensure they are acceptable for use during this drilling operation. The EMMP will be reviewed during the course of the project to ensure its provisions are being implemented and that environmental controls are effectively mitigating predicted impacts. Findings will be reported to management teams and the EMMP will be amended if necessary Mitigations To Reduce Impacts On Commercial Fishing And Shipping Sec Fisheries Consultations Prior to the start of the drilling operation, a public consultation will be held with local fishing interests. This multi-language consultation will provide information to the fishing community on the location of the drilling and specific times activities will occur. Notices to Mariners Notices to mariners will be issued by the Maritime Authority Suriname (MAS) to provide adequate warning to shipping and fishing vessels regarding the drilling vessel s activities. Radio broadcasts Broadcasts regarding the activity and position of the drilling vessel on appropriate shipping channels will be provided. This will ensure that other vessels have adequate notification to alter their intended course and prevent collisions. Support and Chase vessels The drilling vessel will be accompanied at all times during the drilling activities by four Platform Supply Vessels (PSV s). There will always be a minimum of one vessel remaining on duty with the drilling vessel at the project site. Radar and detection equipment The drilling vessel and the support vessels will be equipped with adequate and continuously-manned radar equipment to detect any other vessels that may threaten safety and potentially interfere with the drilling process. Protect integrity of the safety zone The primary responsibility of the support vessels is protecting the integrity of the safety zone around the drilling vessel at all times. 27

28 EMMP Commitments Location in EMMP Mitigation to Reduce Impacts from Accidental Fuel, Oil and Chemical Spills Sec Shipboard Oil Pollution Emergency Plan (SOPEP) The vessels maintain and implement shipboard SOPEPs as required by MARPOL Annex I, Regulation 26. The contractor also maintains an Oil Record Book as required under MARPOL 73/78. The drilling vessel SOPEP is in Appendix 4. Oil, grease and chemical containment Oils, greases, other hydrocarbons and chemicals will be stored in designated containment areas onboard the drilling vessel. Sorbent materials Sorbent materials will be maintained aboard the vessels and used to clean up any minor spill onboard the drilling vessel. Stocks of absorbent materials will be checked for adequacy and replenished as needed prior to and during the drilling operation. Fuel transfer protocols Strict fuel transfer procedures are implemented to prevent spills during loading of fuel at port and during transfers between supply vessels and the drilling vessel. In the event of a spill of oil or other products, the SOPEP will be initiated in response to the incident and it will be promptly reported through the contractor chain-of-command to Apache and Surinamese Authorities. See Appendix 5 for the Fuel Transfer (Bunkering) Procedure. Mitigation to Reduce Impacts Resulting from Vessel Collisions Sec Established shipping lanes There are no established shipping lanes across the drilling project area, reducing the opportunity for frequent marine vessel traffic through the project area. Double hull vessels The drilling vessel is constructed with a double hull as a mitigation measure to reduce the likelihood of fluids from the vessel (fuel oil, lubricating oil, chemicals, etc.) being released into the marine environment as a result of a collision. Segregated fuel tanks All of the vessels involved in the drilling program maintain their fuel inventory in segregated fuel storage tanks. All of the fuel is NOT contained in a single tank. If a collision should occur and a fuel tank is compromised, only the fuel volume in the smaller, segregated tank could potentially be released to the marine environment. 28

29 EMMP Commitments Location in EMMP Mitigation to Reduce Impacts Resulting From Wastes Sec Solid wastes - All solid waste procedures comply with MARPOL requirements. Correct segregation of solid and hazardous wastes in accordance with the vessel management plan. A vessel Waste Log is kept detailing quantities of wastes transported ashore. Waste bins will be closed at all times to prevent rubbish blowing into the marine environment. Solid wastes and garbage will be handled according to the Waste Management Plan (Appendix 7). All food wastes will be incinerated onboard the vessel. Those solid wastes which cannot be recycled and are not incinerated will be minimized and stored onboard the drilling vessel for later shipment to Trinidad for disposal. Frequency of solid waste shipments/disposal will be dependent upon volume and vessel storage capacity. Ballast water management The Ballast and Bilge Operations document (Appendix 8) provided by the contractor ensures that ballast is handled such that the transfer of harmful aquatic organisms and pathogens from the ship ballast water is minimized. It shall always be exchanged or diluted (by overfilling) in deep sea and before entering the coastal waters. Additionally, a separate procedure is in place for preventing transfer of aquatic pest species by sealing overboard valves prior to entering port or other environmentally sensitive zones. The vessels also maintain an up to date ballast water log. Treatment and disposal of sewage Class-approved sewage treatment systems are in place and operational on all vessels. The drilling vessel also includes maceration and disinfection (tertiary treatment). Relevant discharge requirements are adhered to and sewage is not discharged within 12 nautical miles of the coastline unless the vessel has a certified approved sewage treatment plant in place under Regulation 8 (1) (b) of MARPOL 73/78 Annex IV. Frequency and volume of treated sanitary effluent discharge will be determined by volume of waste water generated by the vessels. Operational logs will be provided at the end of the project, if requested. Air Emissions Vessel selected to perform the drilling project is an advanced design 6 th or 7 th generation drilling vessel that incorporates proven technologies to reduce air and gaseous emissions. The vessel uses the DNV Clean Design; high specification exhaust catalysts in combination with use of Urea to reduce NOx emissions; uses MGO with a low-sulphur content to reduce SOx emissions. 29

30 EMMP Commitments Location in EMMP Drill Fluids - To ensure that drill fluids impacts to water quality are minimal, a series of drill fluid toxicity tests will be conducted during the drilling program. The standard Gulf of Mexico drilling fluids toxicity test (96-hour LC50 according to EPA Effluent Limitations Guidelines for oil & gas offshore drilling activities) will be conducted on the drilling fluid system at the start of drilling, once per month during the drilling program, when fluid systems are replaced, and at the end of the well. Mitigation to Reduce Impacts From Loss of Well Control/Blow Out Sec Blow Out Preventer Blow Out Preventers (BOPs) are safety devices used to "prevent" the uncontrolled flow of liquids and gases during well drilling operations. Blowout preventers are large, high-pressure valves that are capable of being remotely controlled. When the driller closes the valve, a pressure-tight seal is formed at the top of the well, preventing the fluids from escaping. A BOP will be utilized during the drilling operation. Well Contingency Plan/Blow Out Plan The drilling contractor has a written Loss of Well Control Plan which will be bridged to Apache s Well Control Plan. Apache has also contracted Wild Well Control to provide a capping stack if it becomes necessary to install such a device. A summary of the Well Control Plan and Relief Well Plan have been added to the ESIA. Spill Response Capabilities Apache has international contracts with NRC and OSRL to provide spill response equipment, personnel and supplies. The PSV s will be equipped with dispersant application systems and a supply of dispersant to be used as a first line of defense. OSRL will respond with aircraft to be used for dispersant application and a supply of dispersant. Details of the spill response capabilities will be presented in the forthcoming Oil Spill Response Plan (OSRP) included in the ESIA. 30