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Focus Visit
Report for:
LRQA reference:
Assessment dates:
Assessment location:
Assessment criteria:
Assessment team:
LRQ4007527/0002
LRQA office:
Coventry
Contents
1.
2.
3.
4.
5.
6.
7.
Attachments
Emmanuel Arthur
Job title:
Environmental Coordinator
Lloyd's Register Quality Assurance Limited, its affiliates and subsidiaries and their respective officers, employees or agents are,
individually and collectively, referred to in this clause as "LRQA". LRQA assumes no responsibility and shall not be liable to any person
for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that
person has signed a contract with the relevant LRQA entity for the provision of this information or advice and in that case any
responsibility or liability is exclusively on the terms and conditions set out in that contract.
Form: MSBSF43000/3.5 - 1113
Page 2 of 19
1. Executive report
Assessment outcome:
The purpose of this assessment was to assess the ongoing conformance of the management system to
ISO14001:2004, to assess progress made in respect of non-conformities outstanding from the previous
assessment visit and to plan for the forthcoming certificate renewal assessment.
All non-conformities from the previous assessment were closed and only one new minor non-conformity
was raised. Based on the evidence sampled, Tullow Ghana Ltd demonstrated that it has maintained an
environmental management system in conformance with ISO14001:2004.
Continual improvement:
Various examples of continual improvement and good practice were noted including:
High standard of housekeeping in Takoradi shore base and on FPSO.
Improved internal communication of environmental performance information within TGL.
Survey of ozone-depleting/ greenhouse gas refrigerants completed and a phase out plan developed.
Improved tracking of how waste is treated so that recycling/recovery/disposal rates can be measured.
Changes to storage tank pressure and tank filling procedure to reduce vent vapour release.
Installation of self-cleaning oil in water analysers at 3 stages in the produced water treatment
process.
Extensive community engagement in relation to oil spill response.
Page 3 of 19
2. Assessment summary
Introduction:
This ISO14001 focus visit was conducted at Tullow Ghana Ltd.s (TGLs) offices in Accra, port facilities
and shore base in Takoradi and the Kwame Nkrumah FPSO. The visit was originally due to be carried out
by LRQA Egypt in October 2014 but had to be re-scheduled following the decision to transfer certification
assessments back to LRQA UK.
The assessment programme was as follows:
All elements of the visit programme were completed and there were no adverse findings unless otherwise
detailed below.
The main purpose of this assessment was to assess the ongoing conformance of the management system
to ISO14001:2004, to assess progress made in respect of non-conformities outstanding from the previous
assessment visit and to plan for the forthcoming certificate renewal assessment.
Opening and closing meetings were held in accordance with LRQA procedures at the Accra office with the
following attendees:
Audit opening
meeting - Attendanc
Audit closing
meeting attendance
Page 4 of 19
Assessment of:
Environmental Management
System elements
Page 5 of 19
Assessment of:
Identification of legal
requirements and compliance
evaluation
Page 6 of 19
Assessment of:
Review: LRQA assessment reports for SV1 (Oct 2012), SV2 (Oct 2013) and conclusions from current
assessment; environmental performance data for 2013 and 2014.
Preview & plan: overview of anticipated changes to the organisation, activities, management systems
and scope.
Page 7 of 19
Assessment
of:
FPSO visit
Auditee(s):
Tour of FPSO including waste, oil & chemical storage areas, galley, and control room.
Discharges to water: Laboratory daily analysis log book and spreadsheet, oil record book
Air emissions: inspection of gas turbine sampling ports, daily report including gas production/flaring
data, discussion regarding flaring rate and venting, GT emissions monitoring data 2014.
Audits and corrective action: EHS compliance audit report on FPSO 30/9-2/10/14
Maintenance: monthly IMR completion performance report Dec 2014, sample of PPM tasks in AMOS
including OIW analyser 3M calibration and 2W inspection, sewage treatment unit annual clean and
inspection
Page 8 of 19
Assessment of:
Assessment of:
Internal audits: Internal audit schedule 2014, Zeal EHS audit report 22-23/4/14 and associated
corrective action register, environmental management system status review report by Cares
(26/11/14), Cirrus EHS audit report 7/5/14, FPSO EHS compliance audit 30/9-2/10/14, Accra office
EHS audit 27-28/10/14, Takoradi action tracker, EHS inspection report Takoradi port chemical storage
facility 17/10/14
Incidents: environmental incident initial notification and incident investigation report for incident 3026
(West Leo loss of containment 8/8/14)
Page 9 of 19
Status
2
Minor NC
Closed
Requirement
TGL has made a policy commitment to comply with applicable
legal and other requirements. Once potential non-compliances
are identified, effective corrective action should be
implemented in a timely manner.
Deficiency
1. A recent audit identified that untreated food waste was
being discharged from the FPSO as the macerator had
not been functioning for some time. Although the
macerator has now been repaired, it is still not able to
macerate food waste containing bones. The FPSO is
therefore currently unable to fully comply with the
MARPOL/ environmental permit requirement for all food
waste discharges to be no more than 25mm in length.
2. Because bilge water is mixed with process wastewater,
the maximum oil in water content of 15ppm for bilge
water cannot be achieved. Although this was identified
several months ago, it has not yet been rectified.
Root cause
a. The inadequacy of the original macerator was not
identified when the tanker vessel was converted into an
FPSO. The difficulty of achieving 15ppm oil in water for
bilge water treatment was also not identified at the design
stage.
b. The environmental significance of these issues was not
fully understood by the responsible personnel when they
were originally identified.
Process / aspect
5
Date
6
Reference
7
Clause
8
24 Oct 12
1210BLR01
4.5.3
22.10.2013 MMA:
Some records exist for the completion of the
corrective actions .The actions could not be
verified physically during this visit since offshore
FPSO was not included in visit scope. To be
verified next visit
Corrective action review Jan 2015
1. The food waste macerator was initially
repaired but following further failures, a new
macerator has now been purchased.
2. Bilge water has been separated from
produced water and both are now being
discharged within applicable limits.
3. Lessons learned have been communicated
with the TEN project team.
4. Review by LRQA
Page 10 of 19
Grade
1
Status
2
Minor NC
Closed
Process / aspect
5
Monitoring & measurement
Date
6
Reference
7
Clause
8
25 Oct 12
1210BLR02
4.5.1
22 Oct 13
1310MMA0
1
4.3.1
Closed
4. Review by LRQA
Page 11 of 19
Grade
1
Status
2
Minor NC
Closed
Minor NC
New
Process / aspect
5
Date
6
Reference
7
Clause
8
23 Oct 13
1310MMA0
2
4.5.1&
4.5.2
08 Jan 15
1501BLR01
4.5.2
Requirement:
The standard requires that the organisation shall establish,
implement and maintain a procedure(s) for periodically
evaluating compliance with applicable legal requirements. The
organisation shall keep records of the results of the periodic
evaluations.
Evidence of Non Conformity:
Compliance with key legal requirements is being checked (e.g.
Jubilee operating permit compliance was checked during a
recent EHS audit.) However compliance with other legal
requirements identified in the environmental legal register had
not been checked recently.
Root cause(s):
It appears that EHS resource constraints have contributed to
this finding.
4. Review by LRQA
Page 12 of 19
4. Audit Programme/Plan
Visit Type
Due Date
Start Date
End Date
Audit Days
Any change in workforce numbers That
may impact visit duration (if yes add new
number)
Process / aspect / location
Stage 1
Stage 2
Y/N
Y/N
Certificate
Renewal
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
Final selection will be determined after review of management elements and actual performance
Scope
Exclusion
Page 13 of 19
Certificate Renewal
Theme(s) for
Next Visit
N/a
Audit days
5
(+ 2
travel)
Locations
Activity codes
111103, 0003
Team
Bernard Rigg
Standard(s) /
Scheme(s)
ISO 14001:2004
Due date
Oct 2015
28/9/15-2/10/15
Page 14 of 19
6. Audit Programme/Plan
Visit Type
Due Date
Start Date
End Date
Audit Days
Any change in workforce
numbers That may impact visit
duration (if yes add new
number)
Process / aspect / location
Oct 13
22/10/13
24/10/13
3
Focus
visit
Oct 14
05/01/15
08/01/15
4
Oct 15
28/09/14
02/10/14
5
Y/N
CTA
SV1
Oct 12
22/10/12
25/10/12
4
N
Cert
Renewal
Final selection will be determined after review of management elements and actual performance
Accra office:
Management system
elements
Office environmental
aspects
Supply chain
management
Training & competence
Emergency preparedness
and response
Well engineering
Production operations
FPSO
Air emissions
Waste management
Waste water discharges
Maintenance
Training & competence
Takoradi Shore Base
Takoradi Port Facilities:
Chemical storage
Bunkering and waste
handling
Sekondi Port & fabrication
yard (mainly TEN project)
Visit start time (approximate)
09.00
17.00
N/A
Objective of the next visit ( including where applicable the theme selected)
Re-assess whether all elements of the organisations management system continue to conform to all requirements of
the standard.
Scope
Activities including and associated with the production of oil and gas from the Jubilee field
Exclusion
MSBSF43015
N/a
Page 15 of 19
Note: if the visit involves more than one team member and/or is more than one day duration, an additional plan
detailing the activities of each member of the team on each day will be required.
Date am/pm
Assessor 1
Assessor 2
Standard
covered
MSBSF43015
Page 16 of 19
7. Assessment plan
Assessment type
Re-certification
Assessment criteria
ISO 14001:2004
Assessment team
Bernard Rigg
Assessment dates
28/9/15 2/10/15
Issue date
8 January 2015
18.50
Arrive ACC
Opening Meeting
09.30
10.00
Operations
Organisation
Incidents
10.30
11.00
Management review
11:30
12.30
Lunch
13:15
13.45
14.45
15.30
Report writing
17:30
Close
10:00
Well engineering
11:00
12.00
Lunch.
13.00
14.00
15.00
16.00
Report writing
Flight to Takoradi
Helicopter transfer to FPSO
10:00
Induction briefing
10.30
11:30
Lunch
12.30
Facility tour
13:30
Air emissions
Water discharges
Waste management
14.15
15.00
15.30
16.00
16.30
17.00
Feedback on findings
17.30
Report writing
11.00
Site tour including oil and chemical storage, waste segregation & storage, drainage
12:30
Lunch
14:00
15.00
16.00
17.00
Report writing
Flight to Accra
10:30
11:30
12.30
Lunch.
13.00
14.00
16:00
06.15
Arrive LHR
08.00
Arrive home
AM
Finalise report