Environmental Inspection And Monitoring Manual

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Environmental Inspection and MonitoringManual(developed for petroleum industry)Document Revision Draft 2.0Date of Issue: [October 2020]RACENameDeveloped by:Yelena Shliomenzon (IHSM)October 2020Shawn Gallagher (IHSM)October 2020Enrique Jaramillo (IHSM)October 2020Doris Mwirigi (ESAL)October 2020Jim Thomas (IHSM)October 2020Approved by:SignatureDate1

Revision Final Draft11/09/2020Final Draft24/09/2020Final22/10/2020PurposeIssued for reviewRealigned withPhase 2deliverablesRevised to addressClient’s commentsRevised to addressoutstanding Client’scommentsFinal DocumentPrepared byReviewed/ApprovedIHS Markit/ESAL NEMA/KEPTAP/WBIHS Markit/ESAL NEMA/KEPTAP/WBIHS Markit/ESAL NEMA/KEPTAP/WBIHS Markit/ESAL NEMA/KEPTAP/WBIHS Markit/ESAL NEMA/KEPTAP/WB2

Document HistoryThis chart contains a history of the revisions made to this document by NEMA(to be used by NEMA once NEMA starts using this manual)RevisionNumberDate of IssueAuthor(s)Brief Description of ChangeLast, FirstLast, FirstLast, FirstLast, FirstDocument LocationThis is an on-line document. Paper copies are valid only on the day they are printed. Refer tothe author if you are in any doubt about the accuracy of this document.ApprovalsThis document requires the following approvals:NameTitleSignatureDate[NEMA to update this]DistributionTitleDepartment[NEMA to update this]3

Table of ContentsRevision Matrix . 2Acronyms . 6Volume 1 . 8Section 1 – General Provisions . 81. . Introduction .82. . Document Structure and content.93. . Description of Environmental Monitoring, Auditing, Inspections .104. . General Roles and Responsibilities .125. . Legal References .126. . Quality assurance and quality control measures.13S. 2 Environmental Monitoring Process .141. . Introduction .142. . Process Mapping.153. . Procedure (steps detailing process activities) .194. . Qualifications and Training .22Appendixes.23Section 3 - Environmental Audit (Control Audits) Process .331. . Introduction .33Section 4 – Environmental Inspection Process .341. . Introduction .342. . Process Mapping.353. . Procedure (steps detailing process activities) .394. . Qualifications and Training .42Appendixes.43Volume 2 . 59S. 1 - Sample collection and processing .591. . Introduction .592. . Process Mapping and Procedure.60Appendices.70S.2 - Measurement Procedures .751. . Introduction .752. . Process Mapping and Procedure.75Appendices.80S 3 - Analytical procedures.821. . Introduction .822. . Process Mapping and Procedure.82Appendices.86S. 4 - Reporting procedure (for field operations) .921. . Introduction .924

2. . Process Mapping and Procedure.92Appendices.96S. 5 Enforcement procedure.981. . Introduction .982. . Process Mapping and Procedure.99Appendices.104S.6 - Incident Tracking Procedure . 1051. . Introduction .1052. . Process Mapping and Procedure.105Appendices.109S.7 Process for establishing a data and record management process . 1131. . Introduction .1132. . Process Mapping and Procedure.114Appendices.117S.8 Laboratory analytical procedure. 1191. . Introduction .1192. . Process Mapping and Procedure.119Volume 3 . 135S. 1 Specific provisions related to environmental monitoring and inspection of upstreamonshore petroleum operations . 1351.1. . Description of activities and facilities involved in upstream onshore petroleumoperations.1351.2. . Sources of key impacts of onshore oil and gas operations and impact categorization.1371.3 . Sources of environmental pollutions/emissions from onshore oil and gas operations.1551.4 . Parameters for environmental monitoring.1601.5 . Onshore oil and gas-specific monitoring procedures distinct from those defined inVolumes 1 and 2 .168S2. Specific provisions related to environmental monitoring and inspections of upstreamoffshore petroleum operations . 1742.1 . Description of activities and facilities involved in upstream offshore oil and operations .1742.2 . Sources of key impacts of offshore oil and gas operations and impact categorization.1782.3 . Sources of environmental pollutions/emissions from offshore oil and gas operations.1992.4 . Parameters for environmental monitoring.2012.5 . Specifics procedures relevant to offshore upstream oil and gas operations .203S.3 Specifics related to midstream and downstream petroleum operations . 2203.1 . Description of activities, facilities, and equipment involved in midstream anddownstream oil and gas operations .2203.2 . Sources of key impacts of midstream and downstream oil and gas operations andimpact categorization .2233.3 . Parameters for environmental monitoring.2313.4 . Specific environmental monitoring procedures relating to mid - downstream oil and gasoperations, distinct from procedures defined in Volumes 1 and 2 .2335

AcronymsBTEX – Benzene, Toluene, Ethylbenzene, and XyleneBOD - Biological Oxygen DemandCEO – Chief Executive OfficerCO2 - Carbon dioxideCVSA – Commercial Vehicle Safety AllianceDCE – Director of Compliance and EnforcementDDE – Deputy Director EnforcementDOSHS – Directorate of Occupational Safety and Health ServicesEA – Environmental AuditEIA – Environmental Impact AssessmentEM – Environmental MonitoringEMCA - Environmental Management and Compliance ActEMR – Emissions Monitoring ReportE&P – Exploration and ProductionEPA – Environment Protection AgencyEPC – Engineering, Procurement and ConstructionEPRC – Energy Petroleum and Regulatory CommissionESDV – Emergency Shut Down ValveGC – Gas-chromatographyGBSS – Gravity Base StructureGPA – Gas Processor AssociationH2 S - Hydrogen sulfideHDPE – High-density polyethyleneHEIA – Health Equity Impact AssessmentHELCOM – Baltic Marine Environment Protection CommissionHIS – Head of Inspectorate SectionHNO3 – Nitric acidHPU – Health Protection UnitHPLC – High Performance Liquid ChromatographyHSE – Health and Safety ExecutiveHWMS – Hazardous Waste Management SystemHWQS – Hydrologic and Water Quality SystemISO- International Standard OrganizationIT – Inspection TeamIPCC – International Panel on Climate ControlKg/m3 - Kilogram per cubic metreKPI – Key Performance IndicatorLDPE – Low density polyethyleneLNG – Liquefied Natural Gasmg/l – milligrams per litreml – millilitresNEMA – National Environment Management Authority (of Kenya)NIST – National Institute of Standards and TechnologyNH4 – AmmoniaNO2 - Nitrogen dioxideNO3 - NitrateNOx – Nitrogen OxideNORM – Naturally occurring radioactive materialsNPDES – National Pollutant Discharge Elimination SystemOGP – Oil & Gas Producer6

O&G - Oil and GasOSPAR – Oslo/Paris convention (for the Protection of the Marine Environment of the North-EastAtlantic)PLETS – Pipeline End TerminationPLONOR – Pose Little or No Risk to the Environmentpsi – Pounds per square inchQA – Quality AssuranceQC – Quality ControlROV – Remotely Operated VehiclesSOP – Standard Operating ProcedureSOx – Sulphur oxidesTHC – Total Hydrocarbon ContentTL – Team LeaderTSS – Total Suspended SolidsUg/m3 - Micrograms per Cubic Meter of AidVOC – Volatile Organic Compound(s)7

Volume 1Section 1 – General Provisions1.1.1IntroductionPurpose and objective of the manualThe purpose of this manual is to establish and document the processes and procedures developedand adopted by NEMA in execution of its compliance and enforcement function in the form ofEnvironmental Monitoring, Auditing and Inspection process of petroleum industry facilities andoperations, as prescribed by Environmental Management and Compliance Act as revised, (furtherreferred to as EMCA) and its underlying regulations.This manual establishes the process of environmental monitoring to be executed by NEMA and/orLead Agencies, control audits by NEMA auditors and NEMA inspections processes of upstream,midstream and downstream operations and facilities as provided in Figure 1 aimed at achievingcompliance with applicable Kenyan environmental legislation.Figure 1 – Kenya compliance and enforcement processesThe objective of this manual is to provide clear and comprehensive information on the processes andprocedures to be uniformly followed by authorized NEMA inspectors, auditors and otherrepresentatives of NEMA or Lead Agencies to provide for consistent execution of compliancemonitoring activities of petroleum operations in Kenya.This Manual shall serve as a reference guide for NEMA, or those granted authority by NEMA, toundertake government led environmental Monitoring, Auditing and Inspection activities of oil and gasoperations and facilities in Kenya.8

2.2.1Document Structure and contentDocument StructureThis manual is arranged in a number of volumes and subordinate sections to assist NEMA personnelin executing of a specific compliance and enforcement activity. The manual structure is provided inthe Figure 2.Figure 2 – Manual StructureThe structure of the manual allows and facilitates: A clear definition of general compliance and enforcement processes used in Kenya thatapply to the petroleum industry, Detailing sub-processes that form each compliance and enforcement process, Provision of specifics that apply to upstream onshore, upstream offshore and middownstream petroleum activities and facilities.2.2Document ContentsFor the ease of reference and understanding, the content of each Volume is summarised below. Volume 1, S.2-4Except for this general section S.1 which aims to provide general information, sections 2-4 of Volume1 of this manual are drafted with the following structure:1Introduction1.1Purpose and Objective1.21.32ScopeRoles and ResponsibilitiesProcess Mapping2.12.22.32.4Process MapInputsOutputsTools, Forms and Templates2.5Metrics (KPIs)9

3Procedure (steps detailing process activities)4Qualifications and Training4.1Qualifications4.2TrainingAppendixes detailing applicable forms, etc. Volume 2All sections of Volume 2 of this manual are drafted with the following structure:1Introduction1.11.21.3Purpose and ObjectiveScopeRoles and Responsibilities2Process Mapping and Procedure2.12.2Process MapInputs2.32.42.5OutputsTools, Forms and TemplatesProcedure (steps detailing process activities)Appendixes detailing applicable forms, etc. Volume 3All sections of Volume 3 of this manual are drafted with the following structure:1Description of activities and facilities involved in upstream onshore oil and operations2Sources of key impacts of onshore oil and gas operations and impact categorization3Sources of environmental pollutions/emissions from onshore oil and gas operations45Parameters for environmental monitoringSpecific procedures distinctive from Volumes 1 and 2 as it relates to onshore oil and gas operations3.3.1Description of Environmental Monitoring, Auditing, InspectionsEnvironmental Monitoring by NEMA and Lead AgenciesEnvironmental monitoring is a continuous or periodic determination of actual and potential effects ofany activity or phenomenon on the environment whether short-term or long-term.NEMA in consultation with the relevant lead agencies, as needed, has authority to monitor theoperation of any industry, project or activity with a view to determining its immediate and long-termeffects on the environment. An environmental inspector appointed under this Act may enter uponany land or premises for the purposes of monitoring the effects upon the environment of any activitiescarried out on that land or premises.Furthermore, all projects for petroleum operations are required to have an environmental impactassessment (EIA) study license. Each EIA includes an environmental management plan that includesmonitoring activities executed by oil and gas companies. Such monitoring is undertaken to determinethe actual and potential effects of the given activity on the environment in the short and long term.As part of its monitoring function NEMA in consultation with the relevant lead agencies, as needed,may request and verify results of monitoring carried out by oil and gas company against baselineparameters.10

This manual makes provisions for NEMA leading environmental monitoring activities of petroleumoperations.3.2AuditsEnvironmental audit is the systematic, documented, periodic and objective evaluation of how wellenvironmental organisation, management and equipment are performing in conserving or preservingthe environment. An environmental inspector may enter any land or premises for the purposes ofdetermining how far the activities carried out on that land or premises conform with the statementsmade in the environmental impact assessment study report.EMCA distinguishes between three types of audit activities: environmental audit studies, self auditsand control audits.Environmental Audit Studies are required for projects that have been undertaken after completionof an environmental impact assessment study.Initial audits provide baseline information upon which subsequent control audit studies shall be based.An initial environmental audit must be within 12 months of the commencement of operations and notmore than 24 months after completion of project. If project life is shorter, the audit may be requiredearlier. Additional audits will be required on a regular basis to verify compliance with t heenvironmental management plan and regulations.Self audits are the primary method of auditing. Companies will prepare a detailed audit of their facilityusing a third-party auditor from a register maintained by NEMA. Self-audits are then reviewed by theNEMA technical staff. NEMA classifies self-audits for review in terms of risks. Low risk facilities requireself-audits only when there is an incident or if NEMA would like to understand the practice within thefacilities. Medium risk facilities must submit self-audits every three years. High risk facilities mustsubmit audits annually. Improvement notices may be issued where needed. If satisfied with the report,NEMA issues a compliance letter to the facility.Control Audits are used when NEMA deems it necessary to check compliance with environmentalparameters set for a project or in order to verify information in a self-audit report. Control auditsintend to verify compliance with a project’s environmental management plan and that the plan issufficient to mitigate any negative impacts of the project. Control audits will be initiated when thereare concerns voiced by NEMA, the public, parliament, or other stakeholders.This manual makes provisions for NEMA lead control audits of petroleum operations. For processesrelated to self audits and environmental audit studies please refer to NEMA Standard OperatingProcedures for Compliance and Enforcement.3.3InspectionsEnvironmental inspections are undertaken by NEMA, or its representatives, through the powersgranted by EMCA. Inspections are periodic events that are undertaken in response to incidents,complaints, or issues raised by the public, Parliament, or other stakeholders. An inspector may, atreasonable times, enter on any land, premises or facility of a project for the purposes of inspection,to examine records and to make enquiries on the project.Inspections consist of a site visit that includes a thorough review of licenses and other documents atthe facility by NEMA compliance staff, observation of environmental management practices in placeat the facility, and discussions with relevant employees. Upon completion of the inspection, findingswill be shared with the responsible authority of the facility and any improvement orders orenforcement actions will be issued.This manual makes provisions for NEMA inspectors to lead environmental inspections of petroleumoperations.11

4.General Roles and ResponsibilitiesThis section makes provision for general definition of parties involved in environmental monitoring,audits and inspection and description of their roles:Name of partyResponsibilitiesNational EnvironmentManagement Authority(NEMA)Responsible for exercising general supervision and co-ordination over all mattersrelating to the environment and to be the principal instrument of the Governmentof Kenya in the implementation of all policies relating to the environment. Assumesgeneral responsibility to execute environmental monitoring, control audits andenvironmental inspections.Chief Enforcement Officer,NEMAResponsible for review of Inspection Reports for enforcement actionsImprovement Orders.Head of Environmental Audit Initiates Audit reports, coordinates review of environmental audits by NEMA staff,Section, NEMAverifies reviewed EA reports, prepares and issue improvement notices, evaluateresponses to improvement notices, and issue compliance letters.Registered ExpertPerforms environmental audits. Must be qualified and registered with NEMADirectorate of OccupationalSafety and Health Services(DOSHS)Provides assistance to NEMA during audits, inspections, and monitoring activitiesas a “lead agency” with specialization in occupational health and safetyEnergy and PetroleumRegulatory Authority(Petroleum & Natural GasDirectorate)Provide assistance to NEMA during audits, inspections, and monitoring activitiesas a “lead agency” with specialization in the midstream and downstream oil andgas industry (i.e. pipelines, petroleum storage depots and tanks, import/exportfacilities, retailers, refineries, etc.)Identifies, reviews, and enhances standards relating to EHS activities in themidstream and downstream petroleum sectors.Oil & Gas OperatorRespond to NEMA or authorized inspector inquiries; undertake environmental selfaudits as needed; provide details of incidents to Compliance Unit.Lead AgencyAny Government ministry, department, parastatal, state corporation or localauthority, in which any law vests functions of control or management of anyelement of the environment or natural resources.5.Legal ReferencesThe following is a list of all major Kenya environmental laws and regulations applicable to inspection,monitoring and auditing petroleum facilities and operations at the time of writing. Environmental Management and Co-Ordination Act, 1999Land Act, 2012National Land Commission Act, 2012Climate Change Act, 2016Energy Act of 2019Petroleum (Exploration, Development, and Production) Act of 2019Environmental (Impact Assessment and Audit) Regulations, 2003Environmental Management and Coordination (Air Quality) Regulations, 2014Environmental Management and Co-ordination (Water Quality) Regulations, 2006Environmental Management and Coordination (Waste Management) Regulations, 200612

6.Environmental Management and Coordination (Controlled Substances) Regulations, 2007Environment Management and Co-ordination (Noise and Excessive Vibration PollutionControl) Regulations, 2009NEMA Standard Operating Procedures for Compliance and Enforcement. REF No.NEMA/SOP/C&E/01-11Quality assurance and quality control measuresQuality assurance/quality control measures are activities undertaken by NEMA and lead agencies,required to demonstrate the accuracy and precision of environmental monitoring, audits andinspections.Quality Assurance (QA) generally refers to a broad plan for maintaining quality in all aspects of aprogram, including all quality control measure, sample collection, sample analysis, data management,evaluation, etc.Quality Control (QC) consists of the steps, including measurements, calibration and standardizationpractices required to be taken to assure quality of specific sampling and analytical procedures.Quality Assurance is essential in environmental monitoring, auditing and inspections to promote,achieve and maintain adequate data quality. Quality Assurance and Quality Control procedures areincorporated into all aspects of the monitoring programs including: Sampling (equipment preparation, sample collection, sample storage and transportation) – thisis achieved via compliance with sampling standards defined in this manual or alternative defacto international best practice standards.Laboratory analysis – this is achieved through the designation of laboratories by NEMAlaboratory , internal laboratory QA/QC procedures independently verified and audit andanalysis of control samples carried out to maintain laboratory accreditation. It is anticipatedthat NEMA designated laboratories are to follow good laboratory practices.Data management – this is achieved via use, maintenance, issue and storage of data incompliance with applicable regulations and this manual.Reporting – this is achieved through consistent reporting and tracking of results of monitoringactivities in compliance with applicable regulations and this manual.Additional measures that improve the quality of environmental monitoring, audits and inspectionsof petroleum operations include, amongst others: Adherence to NEMA internal QA/QC corporate procedures and other procedures required byISO 18091:2019 (Guidelines for the application of ISO 9001 in local government); Adequate training of NEMA inspectors/auditors in execution of environmental monitoring,audits and inspection of petroleum operations as specified in this manual; Internal audits of NEMA enforcement and compliance activities.13

S. 2 Environmental Monitoring Process1.1.1.IntroductionPurpose and ObjectiveEnvironmental monitoring is the continuous or periodic determination of actual and potential effectsof any activity or phenomenon on the environment whether short-term or long-term. NEMA identifiesprojects and programmes or types of projects and programmes, plans and policies for whichenvironmental audit or environmental monitoring must be conducted under EMCA.Environmental monitoring programs for petroleum industry should be implemented to address allactivities that have been identified to have potentially significant impacts on the environment, duringnormal operations and emergency conditions.Industrial activity, such as oil and gas operations, can impact the environment in many different waysover the short- and long-term. Environmental monitoring indicates whether the environmental statusis stable, deteriorating or improving, due to operators’ activities. In addition to identifying trends, theresults should as far as possible provide a basis for projections for future developments.Environmental monitoring of petroleum operations should take into account any impacts on: air quality,water quality,soil and land uses,and biodiversity.Specific parameters are identified as part of the baseline survey. Environmental monitoring activitiesshould be based on direct or indirect indicators of emissions, effluents, and resource use applicable tothe particular project.Objectives of environmental monitoring include: Evaluating short/medium/long term impacts of petroleum operations,Provide government agencies with data to evaluate any impacts and to contribute toenvironmental impact assessments, audits, and inspections,Assist in the evaluation of environmental goals and programs,Comparison of environmental data to baseline data measured in EIA process,Verify that environmental mitigation measures are sufficient to maintain desired outcomesProvide early warning for potential environmental damage.Environmental monitoring of petroleum operations can be executed in two main forms: Through NEMA verification car

Environmental Monitoring, Auditing and Inspection process of petroleum industry facilities and operations, as prescribed by Environmental Management and Compliance Act as revised, (further referred to as EMCA) and its underlying regulations. This manual establishes the process of environmental monitoring to be executed by NEMA and/or

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