1

BP Alaska - Environmental Management System (EMS) and General Compliance Training HSEENV001 THIS COPY VALID UNTIL March 31, 2011 *

2

Topics Covered in this Training Program:

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) 1.

SPILL PREVENTION 2.

DOT PIPELINES AWARENESS 3.

WILDLIFE & POLAR BEAR AWARENESS 4.

This program contains animation. Please use your LEFT MOUSE BUTTON, or [ KEY to “click” your way through the course.

2

3

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) 1.

4

EMS - INTRODUCTION 1.1

The EMS is a framework of: •  Policies •  Procedures •  Programs, and •  Tools

designed to manage and minimize the environmental impact of our oil exploration

and production activities.

Plus, it helps us maintain compliance with

environmental permits and regulations.

What is the BP Alaska EMS?

3

5

EMS: PRIMARY COMPONENTS 1.2

The BP Environmental Management System Includes:

Assignment of key roles and responsibilities to specific employees, who interpret and oversee

compliance with environmental regulations. A formal review of all work activities, to identify potential environmental impacts, which are then

ranked in order of significance Established targets and objectives focused on reducing environmental impacts and improving

the Company’s environmental performance. Advance-planning and active management of work activities to reduce or eliminate

environmental impacts, including: employee training, process alarm systems, Control of Work, written policies and procedures, etc.

A suite of procedures, checklists, and computer programs used to track the completion of

compliance related tasks

Document tracking and storage systems which hold written policies, procedures, and records,

including a formal management of change process (MOC)

Internal audits of compliance, followed by evaluation of any non-compliance and

development of corrective/preventive actions

6

EMS – HEALTH, SAFETY & ENVIRONMENTAL (HSE) POLICY 1.3

That’s correct. Every employee, whether BP or a

contractor, has the responsibility to

see that this policy is carried out in all of their activities.

Sounds like BP’s license to operate in Alaska depends on

everyone’s commitment to this

policy.

BP’s EMS is based on a straightforward

HSE Policy: “No accidents, no harm to people, and no

damage to the environment.”

4

7

EMS: COMPLIANCE AUTHORITIES 1.4

The ISO 14001 standard and OMS element 7.1, Regulatory Compliance require that we identify applicable legal and regulatory HSSE requirements.

BPXA has assigned Compliance Authorities who are responsible for interpreting regulatory requirements and staying current with proposed new regulations. The assigned Compliance Authorities are listed in the document, “BPXA Authorities for HSE Regulatory Interpretations.”

The Compliance Authorities also work with operations and projects to obtain necessary permits for new or changed activities.

BPXA also has Technical Authorities who are responsible for interpreting engineering codes and practices. The list of Technical Authorities is available through the EDDI/Documentum database.

8

EMS: POLICIES & PROCEDURES 1.5

BP policies, procedures, standard practices, and training programs have been established to ensure daily operations, fluid transfers, inspections, tests and non-routine activities are performed safely and are compliant with regulations.

Prior to performing work for BP, it is your responsibility to know the relevant BP policies and/or procedures that apply to that work, and to

follow those procedures as written.

Controlled procedures and policies are available through the BPXA Intranet, at the following web pages:

§  HSE procedures: HSE Document Management System (DK)

§  Site Operating procedures: Operations Document Information Exchange (ODIE)

§  Site Technical Practices, Specifications, and Drawings: Engineering Drawing & Documentation Information (EDDI) (requires permissions)

5

9

EMS: PLANNING AHEAD 1.6

Advanced planning of all work ensures compliance with environmental regulations by:

§  Adequately scoping a project and obtaining the necessary regulatory permits

§  Assessment of potential environmental risks and hazards

§  Determining if existing procedures adequately address the activity to be performed or if new procedures are required

§  Determining the training requirements and ensuring that people are appropriately trained before work begins

§  Assignment of specific roles and responsibilities

10

EMS: RECORDKEEPING 1.7

Accurate recordkeeping is an important piece of the EMS!

Records document your compliance activities, usually with reference to a point in time. These include:

ü Evidence of compliance; such as secondary containment inspections and waste manifests. ü Correspondence; such as a submittal to an agency or waiver from a regulatory requirement ü Proof of completed training

Records must be stored and maintained so they can be protected from loss and easily retrieved when needed.

When it comes to compliance, if there is no record, it didn’t happen! Please refer to the BPXA HSE Record Control Procedure for further guidance.

6

11

EMS HOT TOPICS: WATER USE 1.8

Even though water is abundant on the North Slope, water use permits are required, to prevent adverse impacts to the environment in and surrounding the bodies of water.

Drawing water from an unapproved source, or even using an incorrect intake screen size, may violate conditional-use permits.

If in doubt, always check with Environmental!

Additionally, special care must be taken to prevent contamination of natural bodies of water from releases, leaks and spills.

Many fluid transactions, such as discharging water after a hydro test, or even dumping a pot of coffee on the ground, are not allowed.

12

EMS HOT TOPICS: LAND USE & PERMITTING 1.9

§  Local, State and Federal government agencies regulate, permit, and monitor North Slope land use for a myriad of reasons: land ownership/lease matters, collection of applicable taxes and fees, and for protection of critical animal habitat – particularly for the conservation of threatened or endangered species.

§  Any alteration of the natural landscape or use of natural material to construct roads and pads must be pre-approved and permitted.

§  Any type of ground disturbance/excavation on or off pad may require a permit.

§  Any alteration of an existing road or pad requires additional permits, even though the road or pad was permitted when it was built.

§  Always check with the BP Environmental Team before ground work begins!

7

13

EMS HOT TOPICS: HAZARDOUS WASTES 1.10

§  When it comes to oil exploration activities, the Federal Resource Conservation and Recovery Act (RCRA) regulations focus on how a volume of waste is generated. Wastes from certain sources are exempt, so it is important to keep wastes separated before disposal.

§  The Alaska Waste Disposal and Reuse Guide (a.k.a. the Red Book) provides guidance on proper waste handling. RCRA regulations are very complex and not necessarily logical – so don’t try to guess or make assumptions about how a particular waste must be handled.

§  When in doubt, always check with the BP Environmental Team!

§  Did you know all hazardous waste must be trucked off the Slope and sent out of State for disposal? This is a very laborious and expensive process!

§  If hazardous wastes are accidentally combined with non-hazardous wastes, the whole load becomes “hazardous” and it must be handled accordingly.

14

EMS HOT TOPICS: WASTE MANAGEMENT 1.11

ü  Think twice about everything you use and then throw away…was it really necessary?

ü  Use re-usable containers and utensils for packing food items.

ü  When ordering project or office materials, order only what you need.

ü  Recycle used and unused materials whenever possible.

ü  Investigate waste recycling options for your location.

Due to limited landfill space and the fragile, Arctic environment, waste disposal on the North Slope is very limited and expensive.

Consider this - all we really do at a dump is HIDE our garbage. It doesn’t go away!

Please try to minimize the creation of waste which must be disposed.

8

15

EMS HOT TOPICS: AIR EMISSIONS 1.12

Modifications to equipment regulated under air permits may have serious impacts on air quality compliance. Always check with Environmental or an Air Quality Compliance Authority (CA) when doing repairs or modifications to permitted emissions sources.

While only a few employees can control the emissions from our facilities, EVERYONE can help minimize equipment emissions by shutting down

vehicle and equipment engines when no longer needed or in use.

Unnecessary idling, multiplied by thousands of engines, injects a large volume of pollutants into the air.

Be sure to follow the rules in the BPXA Unsecured Vehicle Policy, which sets forth the [only] conditions when vehicles may be left idling.

16

EMS HOT TOPICS: TUNDRA TRAVEL 1.13

Due to the harsh, Arctic climate and short growing seasons, tundra is an extremely fragile environment where any disturbance or damage can take decades to heal.

All off-pad tundra travel must be approved in advance. Immediately report any suspected or known tundra damage or tundra erosion to Environmental.

9

17

EMS HOT TOPICS: REGULATORY COMPLIANCE 1.14

The NUMBER ONE ENVIRONMENTAL RULE we must follow is: Maintain compliance with ALL permit stipulations and regulations. Failure to do so can result in federal action against BP and even individual employees, followed by loss of business, loss of business opportunities, damaged reputations, etc. This can be prevented by:

ü  Assessing how your job tasks could impact the environment.

ü  Identifying the most-current procedures and practices that apply to your work tasks.

ü  Learning the permit stipulations that govern the activities you are involved in, and follow them.

ü  If you don’t know the rules, seek them out. Ask your Supervisor or an Environmental Advisor if you have any questions.

18

EMS: REPORTING 1.15

There are many issues that may seem trivial, but they actually require immediate

agency notification and response in order to maintain compliance with permits and

regulations.

§  It is part of everyone’s job at BP Alaska to help make the Environmental Management System work properly.

§ Please keep an eye out for things that don’t look right!

§  If you discover evidence of current or even potential problems (e.g. leaks, spills, malfunctioning equipment, workers unknowingly or willfully not following procedures, etc.), it is your responsibility to report your findings to your Supervisor, North Slope Security, or the Environmental Team.

10

19

EMS - SUMMARY 1.16

That’s easy!

Be current on your training requirements, be proactive on spill prevention, follow the applicable procedures for your job tasks, report any spills that occur, look for opportunities for waste reduction, and submit your ideas for improvements.

So, how can I contribute to the

EMS?

20

SPILL PREVENTION 2.

11

21

SPILL PREVENTION – “OIL HANDLERS” 2.1

§  The operation, inspection and maintenance of equipment used to handle oil and oil-related products is regulated by numerous local, State, and Federal government agencies.

§  The regulations refer to personnel who perform these types of tasks as “Oil Handlers.”

§  The primary purpose of these regulations is to prevent spills, which can harm people, property, and the environment.

§  It is vital for oil handlers to know about these regulations and to comply with their provisions. Failure to comply with these regulations may threaten BP’s permission to operate oil fields in Alaska. Compliance is also a requirement of most oilfield jobs.

22

SPILL PREVENTION – CONTINGENCY PLANS 2.2

BP Alaska maintains Oil Discharge Prevention and Contingency Plans (also known as C-Plans or SPCC Plans), as required by the Federal Environmental Protection Agency (EPA), the Alaska Department of Environmental Conservation (ADEC), and other regulatory agencies.

These plans include detailed facility descriptions and descriptions of controls used to prevent spills, including:

§  Spill prevention methodologies

§  Methods for securing access to facilities and equipment

§  Response plan information in the event of an oil release

These plans must be updated regarding changes to the facility layout, control systems, and inventory or service status of tanks, containments, and response equipment. The Environmental Review portion of the BPXA MOC process ensure these changes are identified, to allow for timely modifications to the plans.

12

23

SPILL PREVENTION - REGULATIONS 2.3

OIL SPILL

PREVENTION

REGULATIONS

WARNING! Failure to comply with oil spill prevention regulations can result in financial penalties to BP, revocation or denial or of permits, and even legal action against both employers and individual employees.

Reminder: If your job duties involve inspection, maintenance, or operation of oil storage and transfer equipment, you are required by Federal and State law to be trained on oil pollution prevention measures that are applicable to your job.

Ø Overview training for Oil Handlers is provided through the BP’s online training course: “Oil Spill Prevention Regulations Training” (HSEENV038)

24

SPILL PREVENTION - CONTROLS 2.4

Numerous controls are used to prevent or reduce the impact of oil spills, including:

§  Impermeable sumps and cellars around well heads

§  Secondary containment for tanks, totes, oil processing equipment, and fluid transfer connection points

§  Corrosion monitoring and control strategies (pigging, use of corrosion inhibitors, protective coatings; plus x-ray, ultrasonic, and visual inspections)

§  Keeping oil processing equipment, mobile equipment, drill rigs, and fluid storage away from the edges of pads or within containment areas.

§  Use of blowout prevention assemblies and well-control systems during drilling operations.

13

25

Secondary containment is required by regulations and BP policy for tanks, vessels and drums containing oil and oil-based substances.

§  Most oil tanks need secondary containment with a capacity 110% of the tank’s shell capacity

§  Containment areas require documented inspections

§  Containment is only effective if the liner is in good, leak-proof condition, and its capacity is not adversely affected by the presence of water, dirt, vegetation or other debris.

SPILL PREVENTION – SECONDARY CONTAINMENT 2.5

The BPXA Site Technical Practice (STP) titled, Criteria for Secondary Containment of Storage Tanks and Tank Truck Loading Areas provides an in-depth description of when secondary containment is required.

26

SPILL PREVENTION - SECONDARY CONTAINMENT, cont. 2.6

Storing oil without secondary containment is prohibited.

In an effort to comply with SPCC regulations for storage of empty, portable hydrocarbon tanks, and to minimize the risk of illegal oil storage; storage areas with appropriate secondary containment and signage have been designated.

14

27

SPILL PREVENTION – BASIC TIPS 2.7

Spill prevention is everyone's business.

Ensure that the equipment you work with is well maintained and always have a plan to prevent spills to the environment.

This can be as simple as:

ü always using liners under connection points when fueling your vehicle or transferring fluids

ü using a drip liner under your vehicles and equipment when parked or idling

ü shutting off your vehicle or equipment whenever possible

ü Looking for worn and or leaking parts during your 360- degree vehicle/equipment inspections, and report problems to vehicle maintenance

28

SPILL PREVENTION - REPORTING 2.8

PHOTO: ADEC

PLEASE REMEMBER:

ALL LEAKS, SPILLS, AND UN-PERMITTED DISCHARGES MUST

BE REPORTED IMMEDIATELY.

The North Slope Environmental Field Handbook has phone numbers for reporting.

15

29

DOT PIPELINES AWARENESS 3.

30

DOT-REGULATED PIPELINES 3.1

Many of the liquid and natural gas pipelines in our operating area are regulated by the U.S. Department of Transportation (DOT). These lines have a number of special regulatory and environmental requirements you need to know. Note – A pipeline corridor may contain both DOT and non-DOT pipelines. Hazard awareness, spill prevention, and spill response are the same for all.

16

31

DOT REGULATED PIPELINES - HAZARDS 3.2

POTENTIAL PIPELINE HAZARDS: §  HEALTH: Exposure to harmful compounds spilled or

leaked from pipelines, or exposure to fire and or explosion of the contents

§  PROPERTY: Physical property damage from leaks, spills or ignition of contents, or from the force of pipes moving when “slugs” of product move through.

§  ENVIRONMENT: Damage to land, bodies of water, and wildlife due to exposure to harmful pipeline contents

PIPELINE HAZARD PREVENTION MEASURES: §  Inspection and maintenance programs

§ Automated safety systems for pipeline shutdown

§ Visual surveillance from ground and air

§  Internal and external pipeline integrity assessments

§ Stream bank erosion inspections

32

DOT REGULATED PIPELINES - SIGNAGE 3.3

Anyone driving around the North Slope oil field should be familiar with DOT pipeline signage.

DOT signs generally include:

§ What product is in the pipe

§ Who manages that section of pipeline

§ Who to contact if there is a leak

Note: It is a Federal crime to willfully deface, damage,

remove, or destroy pipeline signage!

17

33

DOT REGULATED PIPELINES – BP SIGNAGE 3.4

BP Alaska Lease Area Pipeline Signage:

•  System Operator Name

•  Name of commodity transported in pipe

•  “Warning” notice

•  24 – Hour Emergency Contact Number (sample)

•  International “No Dig!” symbol

•  Reflective background for maximum visibility in low light conditions

34

DOT REGULATED PIPELINES – REPORTING LEAKS 3.5

If you discover a pipeline leak of any kind: §  Do not touch, breathe, or make

contact with the leaking liquids.

§  Do not light a match, start an engine, use a telephone, operate electrical switches, or do anything else that may create a spark in the vicinity of the leak.

§  Warn others in the area.

§  Leave the area immediately. Do not drive into a vapor cloud.

§  Report the spill. Personnel trained in response will address the leak. Do not try to stop the leak yourself!

PHOTO: ADEC PHOTO: ADEC

18

35

WILDLIFE & POLAR BEAR AWARENESS 4.

36

WILDLIFE - INTRODUCTION 4.1

§  The Arctic Coastal Plain is a sensitive habitat for many forms of wildlife.

§  It is a privilege to operate in the midst of a healthy and unique wildlife community.

§  Most birds and mammals found on the Slope are protected by State or Federal regulations. “Protected” means they cannot be hunted, harassed, captured, or killed without government agency permits and/or approval.

§  All animals have the “right of way” and should be treated with respect.

§  Crucial wildlife habitats, such as nesting, brood rearing areas, den sites and feeding grounds must not be disturbed.

19

37

WILDLIFE - WARNINGS 4.2

§  All animals, both large and small, can pose a danger to humans. Large animals such as polar bears can severely injure or kill humans. Small animals can transmit fatal diseases to humans and damage property.

§  Please stay alert and attentive while driving. Collisions with small animals are almost always fatal for the animals. Collisions with large animals can be life threatening to both humans and animals.

38

WILDLIFE – PROHIBITIONS 4.3

Avoid attracting wildlife by controlling all food and waste

§  Store food and dispose food-related waste in wildlife-proof containers or structures.

§  Do not leave food, food scraps, or food-related waste where animals can get to it, such as in a vehicle with open windows or in the bed of a pickup truck.

An employee caught feeding, approaching or harassing wildlife may be cited by Security and may face penalties up to and including dismissal.

§  “Feeding” includes leaving food or garbage accessible to an animal, such as in truck beds.

§  “Harassing” includes any human activity that causes an animal to stop what they are doing and take notice of you, such as driving near an animal and then stopping to take a picture.

20

39

WILDLIFE - REPORTING 4.4

Do not take wildlife matters into your own hands! Report all dead, sick or injured animals immediately to a BP Environmental Advisor. They will make the necessary notifications to Federal and State agencies, and will receive guidance on what to do with the animals.

Call North Slope Security immediately if you observe any of the following: §  Any injured, trapped, stranded, nuisance or dead animals

§  Polar bears (including tracks or possible dens)

§  Grizzly bears - all sightings and interactions

§  Red or Arctic fox encounters that require hazing, deterrence or dispatching

§  Dead or injured birds (especially Spectacled Eiders and Yellow-Billed Loons)

§  Seals or whales - interactions or injured or dead animals

§  Unusual wildlife sightings (for example, walrus sightings, ermine infestations, Bald or Golden Eagles, or Peregrine Falcons nesting)

40

WILDLIFE – POLAR BEARS – GOVERNMENT PROTECTION 4.5

§  Polar bears have the highest level of protection by the Federal Government, under the Marine Mammal Protection Act (MMPA) and the Endangered Species Act (ESA). Additionally, in November 2010 the U.S. Fish and Wildlife Service (USFWS) also designated much of the North Slope coastline, barrier islands, and sea ice areas as “Polar Bear Critical Habitat.”

§  The ESA and Critical Habitat designations requires Federal agencies to ensure that the activities they authorize, fund, or carry out are not likely to jeopardize the continued existence of the Polar Bear species, or to destroy or adversely modify its critical habitat.

21

41

WILDLIFE – POLAR BEARS – ESA MITIGATION MEASURES 4.6

§  The Endangered Species act mitigation for oil and gas projects require a site-specific plan of operation and a site-specific Polar Bear Interaction Plan. These plans include steps to minimize impacts on polar bears, such as garbage disposal (to prevent the attraction of bears) and snow management (to discourage hiding or denning); specific chain-of-command for responding to any polar bear sightings; and polar bear awareness training for employees.

§  These measures allow for the early detection and appropriate response to polar bears that may be encountered during operations, which reduces the potential for injury or lethal take of bears in defense of human life.

§  To comply with USFWS regulations, BPXA obtains Harassment Authorizations to reduce the likelihood of death or injury to humans or polar bears, and Letters of Authorization (LOAs) for the unintentional, incidental take of polar bears.

§  Before planning or beginning any new field projects off roads or gravel pads (e.g. ice road construction or new gravel sources), please contact the BPXA Environmental Advisors, HSSEE Permitting Team, or the Wildlife Compliance Authority for consultation.

42

WILDLIFE – POLAR BEARS - PROHIBITION OF HARASSMENT 4.7

§  Government regulations prohibit harassment of wildlife.

§  In accordance with the MMPA and the ESA, it is illegal to “take” polar bears, which is defined as: “hunting, harassing or killing, or attempting to hunt, harass, or kill a polar bear.

§  Our permission to operate in bear country requires employees to make every attempt to avoid all polar bear-human interactions.

§  If you are working outdoors in the field, you will need to review and understand the BPXA Polar Bear Interaction Plan for BPXA Areas of Operation. A copy of this Plan should be kept onsite and made available to all personnel.

§  Be prepared to implement all conditions of the BP Polar Bear Letter of Authorization (LOA), which should also be kept on site.

22

43

WILDLIFE – BEAR SIGHTINGS 4.8

IF A BEAR IS SIGHTED IN OR NEAR YOUR WORK AREA:

§  Cease all work activity immediately and move away from the site to a safe area. Alert the on-site Supervisor and any others working nearby.

§  Notify BPXA Security immediately

§  Security will determine if the bear(s) need to be hazed. Only trained Security personnel are authorized to haze bears.

§  Security will contact the BP Environmental Team for guidance and will report the sighting or hazing event to USFWS, as soon as possible, but not more than 24 hours.

§  The Environmental Team will work with USFWS and Operations Management regarding resumption of activities on a case-by-case basis. Activity can not resume without explicit permission from the BP Environmental Team and the USFWS.

44

WILDLIFE – FIELD WORK IN BEAR COUNTRY 4.9

þ  Verify work location is not within 1 mile of a known or suspected polar bear den.

þ  Ask North Slope Security if any polar bears are currently in the fields.

þ  Be prepared to staff designated wildlife observers on site to monitor polar bear activity, if deemed necessary by BP HSSE staff, Security or the USFWS.

þ  Designate “safe areas” at the work site and ensure all workers are briefed on the BPXA Polar Bear Interaction Plan, recent bear activity in the area, work site warning communications, and evacuation routes to the safe area(s).

þ  Arrange for adequate lighting and protection of the work area, as needed.

þ  Monitor areas in the worksite where bears could be hidden from view, such as ditches, ice mounds, terrain, large snow piles, large equipment, containers, and facility modules.

þ  Before leaving buildings or vehicles, survey the exit area for polar bears or bear activity.

Before starting field work in bear country:

23

45

WILDLIFE – POLAR BEAR DENS 4.10

Decreasing sea ice in the Arctic Ocean has

resulted in an increased number of bears inhabiting and

denning in the shoreline areas .

46

WILDLIFE – POLAR BEAR DENS 4.11

þ Cease all activities immediately and move away from the site and to a safe area.

þ Notify Security immediately, who will contact the BP Environmental Team and U.S. Fish & Wildlife Service.

þ The Environmental Team will work with USFWS and Operations Management regarding resumption of activities on a case-by-case basis. Activity can not resume without explicit permission from the BP Environmental Team and the USFWS.

þ Failure to report a known or suspected polar bear den immediately upon discovery could result in disciplinary action, up to and including dismissal.

IF A POLAR BEAR EMERGES FROM A DEN WITHIN 1 MILE OF HUMAN ACTIVITY:

24

47

WILDLIFE – POLAR BEARS – REMINDERS 4.12

ü  Keep work sites clean and clear of food and food waste.

ü  Ensure that work space is well lit and a designated safe area is established.

ü  Drive or walk around and inspect the work area prior to starting work.

ü  Contact Security immediately if a polar bear is sighted.

ü  Do not under any circumstances stop to view or photograph polar bears in the field.

Please remember…

48

WILDLIFE – INFORMATION RESOURCES 4.13

§  If you have additional questions about wildlife, answers can be found in the following documents:

§  What do I do with this Animal? handbook

§  BPXA Polar Bear Interaction Plan

§  North Slope Environmental Field Handbook

§  Or, simply ask a BP Alaska Environmental Advisor, or the BP Alaska Wildlife Compliance Authority

25

49

COURSE CONCLUSION 5.0

You have completed the BP Alaska

General Environmental Management System (EMS) and Compliance Training (HSEENV001).

~ Thank You! ~ Contractor employees: please sign a training roster, make a copy for

your own records, and then send the original to your employer’s Health, Safety and Environmental Training Records Administrator.

* Please Note: since this training program can be downloaded and saved, version control is managed through an expiration date listed

on the first slide. Please direct any questions or requests for the most-current copy of this training to: AKHSSEETraining@BP.com