APPENDIX TOL-20

ISO 14001 Focus Visit Report, 5-8 January 2015

Focus Visit
Report for:

Tullow Ghana Ltd

LRQA reference: LRQ4007527/0002

Assessment dates: 5-8 January 2015
Assessment location: Accra, Takoradi & FPSO
Assessment criteria: ISO 14001:2004
Assessment team: Bernard Rigg

LRQA office: Coventry

Contents

1. Executive report ........................................................................................................ 3

2. Assessment summary ............................................................................................... 4
3. Assessment findings log - ISO 14001:2004 ............................................................ 10
4. Audit Programme/Plan ............................................................................................ 13
5. Next visit details ...................................................................................................... 14
6. Audit Programme/Plan ............................................................................................ 15
7. Assessment plan ..................................................................................................... 17

Attachments

This report was presented to and accepted by:

Name: 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 Report: LRQ4007527/0002 - 19-Mar-15 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.
Areas for senior management attention:
Ensure that sufficient EHS resources are provided in order so that key activities (e.g. legal compliance
checks, internal audits and EMS document reviews) are conducted in accordance with planned
timescales.

In view of the organisation’s environmental policy commitment to preventing pollution, consider how air
emissions from flaring and venting could be further reduced.

Form: MSBSF43000/3.5 - 1113 Report: LRQ4007527/0002 - 19-Mar-15 Page 3 of 19

 2. Assessment summary
Introduction:
This ISO14001 focus visit was conducted at Tullow Ghana Ltd.’s (TGL’s) 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:

Ghana focus visit

plan Jan 2015 versio

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

Assessor: Bernard Rigg

Form: MSBSF43000/3.5 - 1113 Report: LRQ4007527/0002 - 19-Mar-15 Page 4 of 19

 Assessment of: Environmental Management Auditee(s): Emmanuel Arthur, Laureen
System elements Darku

Audit trails and sources of evidence:

• Overview of operations, organisational changes and environmental issues in 2014
• Policy: TGL EHS Policy dated October 2013
• Management review: 2013 environmental management review actions, presentation and attendance
register 31/1/14
• Environmental aspects: Environmental aspects & impacts spreadsheet
• Objectives and targets: environmental objectives Feb 2014, half year environmental performance
review 2014, Leadership EMS awareness training Oct 2014, CFC survey Accra and Takoradi, ODS
and HFC management plan
• Monitoring and measurement: environmental monitoring plan rev.3 30/9/13, monthly report to EPA
Nov 2014, 2013 annual environmental report, annual marine mammal & turtle observation report 2013,
Group environmental reporting workbook Q3 2014
Evaluation and conclusions:
There have been significant organisational changes during the last year including a change of EHS
leadership. The recent commencement of gas export from the FPSO has significantly reduced the need
for flaring but it is too early to see what flaring rate can be achieved in steady state.

The current EHS policy was signed by the TGL General Manager and conforms to ISO14001
requirements.

The annual management review for 2013 was attended by top management and covered all required
elements. The annual review for 2014 will be conducted soon.

A new environmental aspects evaluation process and record had been established which rectifies the non-
conformance identified during the previous LRQA assessment.

SMART environmental objectives had been set for 2014 with clearly defined actions and responsibilities.
There was an improved focus improvements relating to significant environmental aspects although some
objectives related to compliance and did not therefore contribute to continual improvement. Objectives for
2015 have not yet been established for 2015 but this is reasonable as the new EHS Manager only started
work this week.

Documents sampled demonstrated that environmental performance continues to be measured and

reported in accordance with the environmental monitoring plan. Waste management data for 2014 was
more comprehensive than previously as it included a breakdown of how waste streams had been treated.
Areas for attention:
Minor NC 1310MA01 (environmental aspects & impacts) – closed

Opportunity for improvement:

As the current environmental aspects significance evaluation takes into account the effectiveness of
existing controls, it would be good practice to separate the absolute risk evaluation from the residual risk
evaluation. (Absolute risk would clearly identify all significant environmental aspects which need to be
managed whereas residual risk would help to identify significant aspects with operational controls that may
need to be improved.)

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 Assessment of: Identification of legal Auditee(s): Emmanuel Arthur
requirements and compliance
evaluation
Audit trails and sources of evidence:
2013 EPA audit corrective action plan, environmental legal register (updated Sept 2013), FPSO EHS
compliance audit 30/9/14-2/10/14, operational environmental permits register (Aug 2014), well permitting
status report (updated week ending 9/1/14), Jubilee Operations Environmental Certificate), well
engineering environmental compliance register
Evaluation and conclusions:
National and international environmental legal requirements applicable to TGL had been identified in an
environmental legal register. Permit trackers had also been established for operational permits and drilling
permits.

It was evident that compliance with key legal requirements is being checked periodically (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.
Areas for attention:
Minor NC 1501BLR01 (legal compliance evaluation) – new

Requires correction:
The environmental legal register should be updated to include document control information such as a
record of the revision date.

Form: MSBSF43000/3.5 - 1113 Report: LRQ4007527/0002 - 19-Mar-15 Page 6 of 19

 Assessment of: Certificate renewal planning Auditee(s): Andy Oliver, Emmanuel Arthur

Audit trails and sources of evidence:

• 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.
Evaluation and conclusions:
Review
Monitoring data shows that oil in water content of FPSO discharges has improved during the last 2 years
but the flaring rate has varied due to various factors including process interruptions and third party delays
in installation and commissioning of the gas export pipeline and processing plant. The quality of waste
management data has improved as it now includes how each waste stream has been treated. Oil
production rates have increased significantly during the last 2 years but there have been no significant
changes to activities within the current scope.

Three ISO14001 assessments have been conducted in the last 2 years. Only six minor non-conformities
were raised during these assessments and there is no evidence that similar findings have recurred.

Preview
The scope of the EMS is not likely to be expanded to include the TEN field until production operations are
well established so the certificate renewal assessment will cover activities relating to the Jubilee field only.

Current EMS documentation will be reviewed and simplified during 2015. The current operating permit for
the FPSO is due to expire in May 2015 and a renewal application will require several key documents to be
reviewed and updated (including the environmental management plan, environmental monitoring plan,
waste management plan and oil spill response plan.)

Five additional wells are being planned for the Jubilee phase 1A addendum development and the EIA has
already been completed.

Various changes are being planned regarding the management of production operations including a new
OMS, revised MOC process, significant changes to the planned maintenance schedules and maintenance
deferral process.

Plan
A certificate renewal assessment plan has been developed based on the above review and preview. Refer
to section 7 of this report for details.
Areas for attention:
N/a

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 Assessment FPSO visit Auditee(s): Bruce Tait, Dave Gray, Adam Philips, Jerry
of: Narhyumu, Ajanta Awuni, Rao Chenna, Alexander
Burgesson, Surendra Manocha, Fausto Tesio
Audit trails and sources of evidence:
• 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
Evaluation and conclusions:
Discharges to water
• It was evident that oil in water levels in produced water discharges are now regularly below the
average monthly legal limit of 29mg/l and the Tullow target of 20mg/l. Bilge water discharges have
now been separated from produced water and pass through the vessel’s oil/water separator which is
designed to comply with the 15mg/l MARPOL limit.
• Although previous problems with the food waste macerator had been rectified, the existing macerator
failed again and a new macerator is currently awaiting installation.
Air emissions
• It was evident that the GTGs are fitted with sampling ports and that annual air emissions monitoring is
being conducted.
• Until the gas export pipeline is fully commissioned in the next few weeks, it is not possible to assess
what flaring rate will be achieved but it appears that the 2.5% average monthly target will be difficult to
meet consistently until a long term solution is found to rectify the bursting disc issue.
• Recent changes have been made to reduce VOC venting including changing the way in which oil is
discharged into the tanks and increasing the pressure in the tanks. Results of recent analysis of the
vent gas are awaited to quantify the effect of these changes.
Maintenance
There are known issues with the AMOS database and the way in which work is planned and a review is
underway to rectify this. The completion rates for planned maintenance tasks in December 2014 was
reported as 94.66% for criticality 1, 84.3% for criticality 2 and 60.42% for criticality 3. However the current
criticality rating system is based on the safety case and does not take account of environmental criticality
(e.g. OIW analyser and sewage treatment unit currently rated as criticality 3.)

Waste, oil and chemical storage

Waste containers were clearly labelled although there may be scope for further segregation and
compaction before shipping to shore. During the tour it was noted that chemical and oil containers were
mainly stored in bunded areas.
Areas for attention:
Minor NC 1210BLR01 (corrective action) – closed
Minor NC 1210BLR02 (monitoring & measurement) – closed
Opportunities for improvement:
• The current review of the way in which maintenance is scheduled and prioritised would be a good
opportunity to identify environmentally critical tasks so that they are prioritised appropriately in the new
system.
• Although it is too early to assess whether an average 2.5% flaring rate will be achieved consistently
now that gas export has commenced, in view of Tullow’s policy commitment to preventing pollution,
the outstanding MOC to provide a long-term solution to the bursting disc issue should be progressed.
• Although recent changes appear to have reduced the level of VOCs being vented, Tullow should
consider conducting a BAT assessment on how venting is controlled in order to demonstrate its
commitment to pollution prevention. It may be appropriate to install a vapour recovery system.

Form: MSBSF43000/3.5 - 1113 Report: LRQ4007527/0002 - 19-Mar-15 Page 8 of 19

 Assessment of: Takoradi facilities visit Auditee(s): Joseph Klemesu, Ronnie
Clughen, Jonathan Field,
Emmanuel Arthur
Audit trails and sources of evidence:
• Takoradi EHS induction
• Tour of pipe yard & warehouse, overview of Sekondi port facility and fabrication yard, Baycourt offices
and warehouse
• Waste contractor management: Zeal and Zoil gap analysis reports 29/9/14, Zeal EHS audit report 22-
23/4/14 and associated corrective action register
Evaluation and conclusions:
During the tour of the pipe yard a high standard of housekeeping was evident. Waste containers were
clearly labelled and NORM waste was being securely stored. Chemicals and oils were stored in bunded
areas. Drains from the pipe storage apron pass through an oil water separator which is maintained and
sampled regularly. A comprehensive range of oil spill response equipment was available.

The contract with the existing waste contractor (Zeal) has been extended until end of this year and a
specialist provider had conducted a gap analysis on this contractor and a new contractor (Zoil) in order to
assist both contractors to improve. It was evident that the last annual audit of Zeal had been thorough and
Zeal had provided honest feedback and progress with corrective actions. These annual audits are
supplemented by frequent inspections of Zeal facilities by the Tullow EHS team in Takoradi.
Areas for attention:
Minor NC 1310MMA02 (contractor monitoring) - closed

Assessment of: Internal audits, incident Auditee(s): Emmanuel Arthur, Stephen Sesi
investigation and corrective
action
Audit trails and sources of evidence:
• 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)
Evaluation and conclusions:
EHS audit records sampled showed that the audits had been thorough and had identified some significant
non-conformities relating to environmental management of operational activities by contractors. It was
evident that corrective actions identified had been tracked using a combination of action trackers (e.g.
Takoradi action tracker) and individual corrective action plans for each audit. Actions from the last LRQA
audit had been tracked using ATMS.

Records showed that the environmental incident on the West Leo in August 2014 had been notified to the
regulator. The investigation had identified root causes and corrective action had been initiated.
Areas for attention:
Opportunities for improvement:
• Consider using ATMS to record and track corrective actions from internal audits.
• It would be good practice if the internal audit programme included periodic (not necessarily annual)
audits of key functional teams whose activities can have significant indirect/direct environmental
impacts (e.g. contracts and procurement, HR, well engineering.)

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 3. Assessment findings log - ISO 14001:2004
Grade Status Finding (including location if applicable)
1 2 3 corrective action review
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.
1. Grading of the finding * 2. New, Open, Closed 3. Description of the LRQA finding
6. Date of the finding 7. YYMM<Initials>seq.# 8. Clause of the applicable standard
* Major NC = Major nonconformity Minor NC = Minor nonconformity
Form: MSBSF43000/3.5 -1113 Report: LRQ4007527/0002 - 19-Mar-15
Correction, root cause & Process / aspect Date Reference Clause
5 6 7 8
4
Proposed corrective action Corrective and preventive 24 Oct 12 1210BLR01 4.5.3
1. The food waste macerator on the FPSO will action
be upgraded or replaced so that it has the
capacity to treat all food waste. Target date
31/12/12.
2. Bilge water will be re-directed through the oil
separator in the engine room once it has
been demonstrated that this separator is
effective at achieving a maximum of 15pmm
oil in water content. The separator equipment
will be added to the AMOS database to
ensure that it continues to be maintained
regularly. Target date 30/11/12
3. These issues will be communicated to the
design team to ensure that the new FPSO
incorporates a suitable macerator and bilge
water treatment system. Target date
30/11/12.
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 5. Process, aspect, department or theme
Page 10 of 19
 Grade Status Finding (including location if applicable) Correction, root cause & Process / aspect Date Reference Clause
1 2 3 corrective action review 5 6 7 8
4
Minor NC Closed Requirement Proposed corrective action Monitoring & measurement 25 Oct 12 1210BLR02 4.5.1
ISO14001 requires an organisation to monitor and measure 1. The environmental team will provide a
the key characteristics of its operations that can have a specification to Modec and will communicate
significant environmental impact. the need for sampling points to the FPSO
Deficiency design team. Target date 30/11/12
There are currently no proper sampling points for analysing 2. Sampling points will be installed during the
the GT and boiler exhaust gases so TGL is currently unable to next shut-down. Target date 31/1/13
carry out effective monitoring of air emissions from the FPSO.
Root cause 22.10.2013 MMA:
The need for air emission sampling points was not identified 1. Closed on the 30 10 12
when the FPSO was designed. 2. The actions could not be verified during this
visit since offshore FPSO was not included in
visit scope. To be verified next visit

Corrective action review Jan 2015

There are sampling ports fitted and records
showed that annual monitoring is now being
conducted.
Minor NC Closed Aspect/impact analysis suffers from some findings e.g.; Corrective action review Jan 2015 Aspect/Impact Analysis 22 Oct 13 1310MMA0 4.3.1
1. There is some confusion/mix up in defining the aspects A new environmental aspects identification and 1
and impacts e.g. in SOP TGL.EHS.PRC.04.0049 Rev 1, evaluation process has been established. Aspects
land and groundwater contamination was identified as and impacts have been appropriately identified
aspect and not impact. Also this appears in the and the methodology has been clearly defined.
environmental aspects register. Air pollution was
identified as an aspect while air emission was identified
as an Impact in page 21 of 94
2. In the above mentioned SOP the methodology of
determining the significant impacts is not illustrated
3. Some terminologies of HIRA are used e.g. 'risk '
although the terminology of ISO 14001 should be used
instead i.e. 'significance'. Reference is made to
environmental aspects register

1. Grading of the finding * 2. New, Open, Closed 3. Description of the LRQA finding 4. Review by LRQA 5. Process, aspect, department or theme
6. Date of the finding 7. YYMM<Initials>seq.# 8. Clause of the applicable standard
* Major NC = Major nonconformity Minor NC = Minor nonconformity

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 Grade Status Finding (including location if applicable) Correction, root cause & Process / aspect Date Reference Clause
1 2 3 corrective action review 5 6 7 8
4
Minor NC Closed Monitoring and measurements activities at Zeal Waste Corrective action review January 2014 Monitoring and Measurements 23 Oct 13 1310MMA0 4.5.1&
treatment facility at Takoradi suffer from some findings e.g.: Zeal activities and facilities are not directly / Compliance with Legal & 2 4.5.2
1. No documented evidence that some parameters in the controlled by Tullow. However it was evident that Other Requirements
Annex 4 of sector specific effluent quality guidelines for Tullow EHS conduct regular audits and
discharges, Ghana EPA and in environmental quality inspections on Zeal and the results communicated
guidelines for the lubricants& waste oil recycling industry to them.
are measured and monitored e.g. heavy metals,
cadmium, iron, zinc, lead ….etc. (in all checked daily
reports)and oil& grease(in some reports)
2. In the daily effluent quality data form dated 7/10/2013
the oil in water was measured with a value of 29 mg/L
while the reference value was 10 mg/L. No evidence of
corrective action taken.
Minor NC New Statement of Non Conformity: Periodic evaluation of legal 08 Jan 15 1501BLR01 4.5.2
TGL has not periodically evaluated compliance with all compliance
applicable environmental legal & other requirements.

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.

1. Grading of the finding * 2. New, Open, Closed 3. Description of the LRQA finding 4. Review by LRQA 5. Process, aspect, department or theme
6. Date of the finding 7. YYMM<Initials>seq.# 8. Clause of the applicable standard
* Major NC = Major nonconformity Minor NC = Minor nonconformity

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 4. Audit Programme/Plan
Certificate
Visit Type Stage 1 Stage 2
Renewal
Due Date
Start Date
End Date
Audit Days
Any change in workforce numbers That
may impact visit duration (if yes add new Y/N Y/N Y/N Y/N Y/N Y/N Y/N Y/N
number)
Process / aspect / location
Final selection will be determined after review of management elements and actual performance

THIS FORM IS NO LONGER USED: REFER TO SECTION 6 BELOW

Scope

Exclusion

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 5. Next visit details

Visit type Certificate Renewal

Theme(s) for
N/a
Next Visit
5
Audit days (+ 2 Due date Oct 2015 Visit start / end dates 28/9/15-2/10/15
travel)

Locations Accra, Takoradi & FPSO

Activity codes 111103, 0003

Team Bernard Rigg

Standard(s) /
ISO 14001:2004
Scheme(s)

Remarks and instructions

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 6. Audit Programme/Plan
Focus Cert
Visit Type CTA SV1 Renewal
visit
Due Date Oct 12 Oct 13 Oct 14 Oct 15
Start Date 22/10/12 22/10/13 05/01/15 28/09/14
End Date 25/10/12 24/10/13 08/01/15 02/10/14
Audit Days 4 3 4 5
Any change in workforce
numbers That may impact visit
N N N Y/N
duration (if yes add new
number)
Process / aspect / location
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
 N/A
yard (mainly TEN project)

Visit start time (approximate) 09.00 Visit end time 17.00 The exact start and finish times for the visit
(approximate) will be agreed at the pre-visit contact with the
assessor and recorded in the report
introduction.

Objective of the next visit ( including where applicable the theme selected)
Re-assess whether all elements of the organisation’s 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 N/a

MSBSF43015 Page 15 of 19 Revision 0, 17 January 2014

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

REFER TO ASSESSMENT PLAN BELOW

MSBSF43015 Page 16 of 19 Revision 0, 17 January 2014

 7. Assessment plan
Assessment type Assessment criteria
Re-certification ISO 14001:2004

Assessment team Assessment dates Issue date

Bernard Rigg 28/9/15 – 2/10/15 8 January 2015

Sunday 27/9/15 TRAVEL

13.20 Depart LHR (BA0081)
18.50 Arrive ACC

Monday 28/9/15 ACCRA (Day 1)

09.00 Opening Meeting
09.30 Meeting with top management to discuss environmental policy & objectives
10.00 Overview of changes since last visit
• Operations
• Organisation
• Incidents
10.30 Management system update – review of significant changes
11.00 Management review
11:30 EMS objectives, targets and KPIs
12.30 Lunch
13:15 Environmental aspects identification
13.45 Legal & other requirements and compliance evaluation
14.45 Environmental monitoring data & analysis

15.30 Report writing

17:30 Close

Tuesday 29/9/15 ACCRA OFFICE (Day 2)

09:00 Production operations (including MOC and maintenance planning/completion)
10:00 Well engineering
11:00 Drilling EHS monitoring and reporting
12.00 Lunch.
13.00 Supply chain management
14.00 Emergency preparedness & response
(including oil spill response plan, exercises and corrective action)
15.00 Training & competence
16.00 Report writing

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Wednesday 30/9/15 FPSO (Day 3)
07:30 Flight to Takoradi
09:00 Helicopter transfer to FPSO
10:00 Induction briefing
10.30 Overview of current activities and any significant environmental issues
11:30 Lunch
12.30 Facility tour
13:30 Environmental monitoring, reporting & permit compliance
• Air emissions
• Water discharges
• Waste management
14.15 Maintenance: planning, completion and records
15.00 Emergency preparedness: plans, exercises, corrective actions
15.30 Incident investigation and corrective action
16.00 EHS inspections: trends and corrective action
16.30 Waste management (including storage arrangements and transfer records)
17.00 Feedback on findings
17.30 Report writing

Thursday 1/10/15 TAKORADI SHORE BASE & PORT (Day 4)

TBC Helicopter transfer to Takoradi
11.00 Site tour including oil and chemical storage, waste segregation & storage, drainage
12:30 Lunch
14:00 Tour of port facilities including bunkering and waste reception facilities
15.00 Community liaison (including response to complaints)
16.00 Environmental records including:
• EHS inspection reports
• Wastewater discharge monitoring
• Waste transfer records
17.00 Report writing

Form: MSBSF43011/0.4 – 1113Report: 4007527/0002 - 19 March 2015Page 18 of 19

Friday 2/10/15 ACCRA OFFICE (Day 5)
TBC Flight to Accra
10:30 Accra office environmental aspects and controls
11:30 Internal audit, incident investigation, corrective/preventive action
12.30 Lunch.
13.00 Internal and external communication (including complaints, regulators.)
14.00 Report writing & next visit planning
16:00 Closing meeting with management to present a summary of findings and recommendations

Friday 2/10/15 - Saturday 3/10/14 TRAVEL

22.50 Depart ACC (BA0078)
06.15 Arrive LHR
08.00 Arrive home
AM Finalise report

Form: MSBSF43011/0.4 – 1113Report: 4007527/0002 - 19 March 2015Page 19 of 19