Environmental Monitoring Plan and Waste Management Plan · 2018-08-05 · Environmental Resources...

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Environmental Monitoring Plan and Waste Management Plan

Apache Corporation Operations in Egypt

May 17, 2005

www.erm.com

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TABLE OF CONTENTS

1.0 INTRODUCTION 1

1.1 APACHE CORPORATION IN EGYPT 1 1.4 THIS REPORT 4 1.5 STRUCTURE OF THIS REPORT 4

2.0 RELEVANT STANDARDS, GUIDELINES AND COMMITMENTS 5

2.1 OVERVIEW 5 2.2 NATIONAL (EGYPTIAN) ENVIRONMENTAL POLICY 5

2.2.1 Sustainable Development 5 2.2.2 National Guidelines for Development in Coastal Areas 6

2.3 NATIONAL (EGYPTIAN) ENVIRONMENTAL LEGISLATION AND STANDARDS 6

2.3.1 Introduction 6 2.3.2 Legislation and Standards Mainly Applicable to Air Quality 6 2.3.3 Legislation and Standards Mainly Applicable to the Protection of

Water Resources 8 2.3.4 Legislation and Standards Applicable to Marine Discharges 12 2.3.5 Legislation and Standards Mainly Applicable Noise 15 2.3.6 Legislation and Standards Mainly Applicable to Hazardous

Substances and Waste 16 2.3.7 Legislation and Standards Mainly Applicable to Archaeological

Heritage 17 2.4 INTERNATIONAL LEGISLATION, PROTOCOLS AND

AGREEMENTS 18 2.4.1 Introduction 18 2.4.2 International Convention for the Prevention of Pollution of the

Sea by Oil, 1954 (OILPOL) 18 2.4.3 International Convention for the Protection of Pollution from

Ships, 1973 (MARPOL) 18 2.4.4 The Oil Preparedness, Response and Co-operation Convention

1990 (OPRC) 19 2.4.5 Barcelona Convention on Protection of the Mediterranean Sea

Against Pollution 19 2.4.6 Other International Agreements of Potential Relevance to

Hydrocarbon Developments 21 2.5 WORLD BANK AND IFC ENVIRONMENTAL GUIDELINES 22

2.5.1 World Bank/IFC Guidelines for Atmospheric Emissions 22 2.5.2 Quality Guidelines for Aqueous Effluent 23 2.5.3 Standards for Ambient Noise Levels 24 2.5.4 General Guidance 25

2.6 APACHE CORPORATION ENVIRONMENTAL HEALTH AND SAFETY POLICY 27

2.6.1 Introduction to Apache’s EHS Philosophy 27 2.6.2 Apache’s Environmental Policy 27 2.6.3 Apache’s Safety Policy 28

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2.7 COMMITMENTS DETAILED IN THE CONCESSION AGREEMENTS 28 2.8 COMMITMENTS DETAILED IN THE EIAS 29

2.8.1 Environmental Impact Assessment for Egyptian Oil and Gas Activities 29

3.0 ENVIRONMENTAL MONITORING PLAN 38

3.1 INTRODUCTION 38 3.2 RECORDS AND REPORTING 38

3.2.1 General Record Keeping and Reporting 38 3.2.2 Environmental Effects Register 39

3.3 ENVIRONMENTAL MONITORING PROTOCOL 39

4.0 WASTE MANAGEMENT PLAN 44

4.1 INTRODUCTION 44 4.2 PURPOSE 44 4.3 CONTEXT 44 4.4 WASTE MANAGEMENT DEFINITIONS 45 4.5 WASTE MANAGEMENT PRINCIPLES 46

4.5.1 The Waste Management Hierarchy 46 4.5.2 Application of Best Available Techniques (BAT) 47

4.6 WASTE STREAMS CURRENTLY GENERATED BY APACHE IN EGYPT 47

4.7 PROCEDURES FOR SPECIFICALLY DEALING WITH APACHE’S WASTE ARISINGS 48

4.7.1 Identification of New Waste Streams 48 4.7.2 Procedure for Selection of Waste Disposal Option 49 4.7.3 Handling and Disposal Practices 49

4.8 DOCUMENTATION OF WASTE TRANSFER AND DISPOSAL 52 4.8.1 Movement of Waste Within Egypt 52 4.8.2 Export of Waste 53 4.8.3 Training 53 4.8.4 Internet Resources 53 4.8.5 Testing and Analysis 54 4.8.6 Storage 54 4.8.7 Waste Disposal Contractors 55

5.0 COMPLIANCE ASSURANCE FOR EMP AND WMP 57 5.1 DESCRIPTION OF COMPLIANCE ASSURANCE TOOLS 57

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1.0 INTRODUCTION

1.1 APACHE CORPORATION IN EGYPT Apache Corporation is the largest oil and gas producer in Egypt’s Western Desert. Output has increased significantly since 2001, after the company acquired Repsol’s interests in the Western Desert and became operator of the Khalda Concession. The Khalda complex is spread across nearly 2 million acres, approximately 250 miles west of Cairo, and holds two dozen oil and gas fields producing from 58 sandstone reservoir units in seven formations located from one mile to three miles below the desert surface. In 2003, Apache replaced 217 percent of production at an all source finding cost of $4.60 per barrel of oil equivalent on the strength of several discoveries, including Qasr, Alexandrite, Atoun, Emerald, JG-2, Matruh and 13 discoveries in East Bahariya. The successful drilling program pushed daily gross production to all-time highs of 102,052 barrels of oil per day (bpd) and 258 million cubic feet per day (mmscfd) in December 2003. The 2003 Qasr discovery in the Khalda offset acreage is the most significant gas discovery in the Western Desert in the last decade. The Qasr-1X and Qasr-2X wells confirmed a 700-foot gas condensate column with estimated recoverable reserves of between 1 and 3 trillion cubic feet. The Qasr-1X well was brought on production in December 2003 at a rate of 10 mmscfd. As additional appraisal and development drilling continues, Apache is working on development plans to deliver significant gas volumes from Qasr in 2005. A 95 square mile development lease approved in January 2004 includes the Qasr area and two additional prospects which were scheduled to be drilled during 2004. Apache also owns a 75 percent interest in the Qarun Concession, which it acquired from Phoenix Resources in 1996. In addition to the Khalda/Khalda Offset Concession and the Qarun Concessions, Apache also holds interests in the East Beni Suef Concession, the WD-19 Concession and four other blocks in the Western Desert:

• The Matrouh Development Lease;

• The North East Abu Gharadig Concession;

• The East Bahariya Concession; and

• The West Mediterranean Block. In 2001, Apache acquired all of Repsol’s interests in the Khalda Concession, the Ras Kanayes Concession, the Ras El Hekma Concession, the North East Abu Gharadig Concession and the West Mediterranean Concession onshore and offshore (up to 100 m water depth). Included in the transaction was Repsol’s interest in the Umbarka Development Lease, and in the South Umbarka Concession. Apache has become operator in all of these areas except North East Abu Gharadig.


In 2003, Apache signed a Memorandum of understanding for significant gas sales from four discoveries in the deepwater segment of the West Mediterranean Concession area. Apache is currently negotiating a gas sales agreement with the Egyptian government for the gas reserves discovered in the deepwater, offshore portion of the West Med Concession. Once these negotiations are concluded, Apache anticipates that it will proceed immediately with development activities. Development activities currently envisioned include:

• Laying a 75 km offshore pipeline;

• Completing 2 - 4 of the currently existing wells and installing subsea control equipment;

• Drilling 4 - 8 wells and installing the necessary subsea control equipment; and

• Producing the gas via an onshore gas plant and transporting the gas to the Egyptian gas market using the existing gas pipeline infrastructure.

Apache Corporation’s interests in Egypt are summarized in Figure 1.1, and a more detailed schematic of the Khalda Concession and the Qarun fields is shown in Figure 1.2.

FIGURE 1.1 Apache Corporation's Interests in Egypt


FIGURE 1.2 Map Showing the Facilities Associated with The Khalda Concession and Qarun Fields

KHALDA

UMBARKA

UMBARKA

NAKHAW-1X Ii 26-1

Buchis-1

KALABSHA

NEITH

HAYAT-YASSER

SHROUK E.

SHROUK

SAFIR

NADER

SAFIR N.

KHALDA KAH. S.

KAH.-C

KHALDA

ALKARAA ABU MADI

TANTA

DAMANHUR

ABU QIR

ALEXANDRIA

SIDI KREER EGYPTIAN

PETROCHEMICAL

BAPETCO HORUS

ALAMEIN

YIDMA

RAZAK

AL HAMRA

KANAYES

SALA

RAS EL HEKMA

MATROUH

ABU AL GHARADIG

ABU SANNAN

CAIRO GIZA

W-D 19

166232

17

K

217

K

60

OOBBAAYYEE EL-AMERYA

260 KM DAHSHUR

MM EE DD II TT EE RR RR AA NN EE AA NN SS EE AA

31

T.N

2

50Km/ 1.6

Km/

MATROU

Ii 23-1

TUT

KENZ

TUT

FALAK

SHAMS

MELIEH

37

Km

31° 00’

30° 00’

29° 00’

100Km 0

QATARA DEPRESSION

AKIK

N. ALAMEINIi 26-2X

RENPET OZORIS

HEQET

26° 00’ 27° 00’ 28° 00’ 29° 00’ 30° 00’ 31° 00’

GAS PLANT

GAS LINE

OIL LINE

COND. LINE

KAH. S-B

11 Km

5.5”

11 4”

30 4”

8” 60

KHALDA

KHEPRI - SETHOS

KHALDA

KHALDA

20 Km

RAS KAN

RAS KANAYE

RAS HEKMA

QARUN

64 Km / 10”Planned 15 Km /

PLANNED GAS LINE

TARE


1.4 THIS REPORT This report presents a summary of the environmental requirements of Apache. including obligations and commitments identified in the following guidelines, project documents and Concession Agreements:

• International Finance Corporation’s Environmental, Health and Safety Guidelines for Oil and Gas Development Offshore (December 22, 2000);

• World Bank’s Environmental, Health and Safety Guidelines for Oil and Gas Development (Onshore) (July 1998);

• joint venture and concession agreements and any environmental, health or safety authorizations or licenses applicable to joint venture operation; and

• Any project document including but not limited to the following:

- Environmental Impact Assessment. West Mediterranean Deepwater Gas and Condensate Development Project (dated November 15, 2003); and

- Environmental Impact Assessment for Egyptian Oil and Gas Activities (dated February 2004).

In addition, the report presents an Environmental Monitoring Plan for Apache’s operations in Egypt and a Waste Management Plan for Apache’s operations in Egypt. It should be noted that Apache currently has no active offshore operations and, although this report has been designed to cover onshore and offshore operations, all information relating to current operations refers only to the onshore operations.

1.5 STRUCTURE OF THIS REPORT The remainder of this report is structured as follows:

• Section 2 describes the standards, guidelines and commitments of relevance to Apache’s operations in Egypt, including Egyptian national standards, IFC Guidelines and standards, World Bank Guidelines and standards and commitments in the Concession Agreements and Project Documents.

• Section 3 describes the Environmental Monitoring Plan for Apache’s Operations in Egypt; and

• Section 4 describes the Waste Management Plan for Apache’s Operations in Egypt.

• Section 5 presents Compliance Assurance tools developed to aid in implementation of the Plans.


2.0 RELEVANT STANDARDS, GUIDELINES AND COMMITMENTS

2.1 OVERVIEW This Section of the Report summarizes the environmental legislation, standards and guidelines and institutional administrative protocols, which are of direct relevance to Apache’s operations in Egypt. These are considered in sequence under the following headings:

• National Environmental Policy of the Government of Egypt;

• National environmental legislation and standards applicable in Egypt;

• International conventions, protocols and agreements dealing with environment to which the Government of Egypt is a signatory;

• Relevant environmental guidelines of the World Bank and IFC;

• Apache’s corporate environmental policy; and

• Commitments made in the two recent EIA reports commissioned by Apache for the operations subject to this review.

2.2 NATIONAL (EGYPTIAN) ENVIRONMENTAL POLICY

2.2.1 Sustainable Development

In 1992 the Egyptian Environmental Affairs Agency (EEAA) published the National Environmental Action Plan of Egypt (NEAP). The NEAP sets out the Government’s overall policy and approach to economic development in Egypt within the context of a framework of sustainable development that aims to enhance the health and welfare of the Egyptian population. The NEAP, together with its 2002 update, establishes a number of sustainable development principles which are of direct relevance to Apache’s operations. The NEAP has been updated and the revised plan was published in late 2002.

• The NEAP identifies the importance of Egypt’s coastal shore and marine areas and acknowledges the importance of Lakes Bardawil, Manzala, Burullus, Idku and Maryut, which collectively provide an important sanctuary for birds migrating between Europe and Central and Southern Africa. Reference is also made to the many sites of archaeological importance that lie within the coastal region.

• The NEAP identifies exploration and exploitation of oil and gas as a key issue when considering sustainable development in Egypt. The NEAP also identifies a key program for action as the reduction in the use of high sulphur fuels (known locally as Mazout), a program that may be facilitated by the further development of natural gas resources.

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2.2.2 National Guidelines for Development in Coastal Areas The EEAA published Environmental Guidelines for Development in the Coastal Areas in 1996. The guidelines relate to the need to ensure the protection and conservation of the environment and natural resources against uncontrolled development in the coastal zone. The guidelines set out fundamental principles of coastal protection through good environmental design, and address issues such as oil and gas installations, set back lines, erosion and sediments, and infrastructure. The guidelines refer to a coastal Building Front Line, which reiterates that, in undeveloped land zones, buildings should not be closer than 200 m from the highest high tide mark.

2.3 NATIONAL (EGYPTIAN) ENVIRONMENTAL LEGISLATION AND STANDARDS

2.3.1 Introduction Egypt has for some time had in place various laws and regulations related to the environment, in particular the establishment of the Egyptian Environmental Affairs Agency (EEAA) under Presidential Decree No. 631 of 1982, the Egyptian Law Concerning the Environment, Law No. 4 of 1994, which is Egypt’s first modern and comprehensive law regulating the environment as a whole, including air, water, earth, biodiversity and the anthropogenic activities which may impact upon these receptors. The Law was promulgated on January 27th, 1994 and provides that companies are required to conform with the Law and the requirements of the Executive Regulations, promulgated under Prime Ministerial Decree No. 338 of 1995. The Law repeals and replaces all laws and regulations contrary to its provisions, but specifically maintains in force the provisions of the Law Concerning the Protection of the River Nile and Water Courses from Pollution, Law 48 of 1982.

2.3.2 Legislation and Standards Mainly Applicable to Air Quality Egyptian Law No 4 of 1994 Concerning the Protection of the Environment also provides the basis for regulating impacts to the atmospheric environment. Egyptian standards and guidelines for ambient air quality are presented in Table 2.1.


TABLE 2.1 Ambient Air Quality Guidelines (µg m-3) (1)

Pollutant Averaging Period

Egyptian Standards (µg/m3)(a)

Nitrogen dioxide (NO2)

1 hour 24 hours

400 150

Sulphur dioxide (SO2)

1 hour 24 hours 1 year

350 150 60

Carbon monoxide (CO) 1 hour 8 hours

30,000 10,000

Ozone 1 hour 8 hour

200 120

Respirable particles (PM10) 24 hours 70 Suspended Particles (measured as black smoke)

24 hours 1 year

150 60

Total suspended particles 24 hours 1 year

230 90

In addition to the ambient air quality standards presented above, Law 4 requires the developer to ensure that pollution concentrations in emissions (or leakages) during construction and operation do not exceed set maximum limits. Concentration limits for pollutants in emissions to atmosphere are shown in Table 2.2.

TABLE 2.2 Maximum Concentrations in Emissions to Atmosphere (mg Nm-3)(a)

Pollutant Egyptian Standards (a)

Oxides of nitrogen(b) 300 Sulphur dioxide 4,000 (existing)

2,500 (new) Total Suspended Particulates (TSP) (c) Sources in urban areas or near residential areas (d) Sources far from inhabited urban areas (e)

100 250 500

Carbon monoxide(f) 500 (existing) 250 (new)

(a) The Egyptian regulations for fuel burning sources (Law 4, Article 42) do not specifically state whether emission limits refer to emission under standard or actual flow conditions. For consistency with other standards, it has been assumed that the limits refer to standard flow conditions.

(b) Law 4 (1994) Annex 6, Table 2 (c) Law 4 (1994) Annex 6, Table 1 (d) Law 4, Article 42 states that emissions of suspended ashes from fuel burning sources in

urban/residential areas should not exceed Ringlemann Chart 1, which Article 42 states is equivalent to an emission concentration of 250 mg/m3

(e) Law 4, Article 42 states that emissions of suspended ashes from fuel burning sources far from inhabited areas should not exceed Ringlemann Chart 2, which Article 42 states is equivalent to an emission concentration of 500 mg/m3

(f) Law 4, Article 42 Maximum Limits of Emission from Fuel-Burning Sources

Egyptian Law 4 (specifically Article 42) also establishes specific conditions for the combustion of fuels, as follows:

• Fuel/air mixtures and the combustion process should be such as to provide for full burning of the fuel;

(1) According to Annex 5 of the Executive Regualtions of Law 4 of 1994


• The use of mazout and heavy fuel oil is prohibited in residential areas; and

• The sulphur content of fuels is restricted to equal or less than 1.5% in or near urban and residential areas. The use of high sulphur content fuels is permissible in regions far from inhabited urban areas, provided that suitable atmospheric factors are prevalent and adequate distances are observed to prevent these emissions from reaching residential and agricultural areas and watercourses.

Egyptian Law 4 (specifically Article 37) also establishes maximum limits for the exhaust emissions from machines, engines and vehicles which emit exhausts, which are summarized in Table 2.3.

TABLE 2.3 Maximum Emission Rates for Exhausts From Vehicles and Machines (1)

Parameter Vehicles/Engines Pre-1995 Vehicles/Engines Post-1995 CO 7% by volume @ 600-900 RPM 4.5% by volume @ 600-900 RPM Unburned Hydrocarbons 1,000 ppm @ 600-900 RPM 900 ppm @ 600-900 RPM Smoke 65% degree of opacity or the

equivalent in other units at minimum acceleration

50% degree of opacity or the equivalent in other units at minimum acceleration

2.3.3 Legislation and Standards Mainly Applicable to the Protection of Water Resources

Introduction The principle for protection of water resources in Egypt is largely related to the nature of the receiving water. The appropriate standards for the control of aqueous discharges are contained in Law 48 and the Executive Regulations to Law 48. Law 48 pertains to discharges to inland waters, while Law 4 covers the marine environment (see Section 2.3.4). Discharges to Inland Waters Used for Potable Supply According to Law 48, discharges to inland waters used for potable supply may not exceed the concentration limits presented in Table 2.4 and discharges of less than 100 m3/day to inland waters used for potable supply may not exceed the slightly less stringent standards presented in Table 2.5.

(1) According to Article 37 of the Executive Regulations of Law 4 of 1994


TABLE 2.4 Standards for Discharges to Inland Waters (Used for Potable Supply) (1)

Maximum Limits and Specifications [(mg/L) – unless otherwise indicated]

Parameter

Discharges to the River Nile from Egypt’s Southern

Borders to the Delta Barrages

Discharges to Nile Tributaries, Large Irrigation Canals, Side Channels and

Underground Water Reservoirs

Temperature 35°C 35°C pH 6 – 9 6 – 9 Color Free of colored materials Free of colored materials Biochemical Oxygen Demand 30 20 Chemical Oxygen Demand (Dichromate)

40 30

Chemical Oxygen Demand (Permanganate)

15 10

Total Dissolved Solids 1,200 800 Ash of Dissolved Solids 1,100 700 Suspended Solids 30 30 Ash of Suspended Solids 20 20 Sulphate 1 1 Oil and Grease 5 5 Phosphates 1 1 Nitrates 30 30 Phenols 0.002 0.001 Fluorides 0.5 0.5 Residual Chlorine 1 1 Total Heavy Metals 1 1 Mercury 0.001 0.001 Lead 0.05 0.05 Cadmium 0.01 0.01 Arsenic 0.05 0.05 Chromium (Hexavalent) 0.05 0.05 Copper 1 1 Nickel 0.1 0.1 Iron 1 1 Manganese 0.5 0.5 Zinc 1 1 Silver 0.05 0.05 Industrial Detergents 0.05 0.05 Fecal Coliform Count (No. in 100 ml)

2,500 2,500

(1) According to Article 61 of the Executive Regulations of Law 48 of 1982


TABLE 2.5 Standards for Discharges (<100 m3/day) to Inland Waters (1)


Parameter

Discharges to the River Nile from Egypt’s Southern

Borders to the Delta Barrages

Discharges to Nile Tributaries, Large Irrigation Canals, Side Channels and

Underground Water Reservoirs

Biochemical Oxygen Demand 40 30 Chemical Oxygen Demand (Dichromate)

60 40


20 15

Total Solids 1,500 1,000 Ash of Solids 1,000 900 Suspended Solids 40 30 Oil and Grease 10 10 Nitrates 40 30 Phenols 0.005 0.002

Discharges to Inland Waters Not Used for Potable Supply According to Law 48, discharges to inland waters not used for potable supply may not exceed the concentration limits presented in Table 2.6.

TABLE 2.6 Standards for Discharges to Inland Waters (Not Used for Potable Supply) (2)


Parameter

Sanitary Drainage Water Industrial Effluent Temperature 35°C 35°C pH 6 – 9 6 – 9 Biochemical Oxygen Demand 60 60 Chemical Oxygen Demand (Dichromate)

80 100


40 50

Dissolved Oxygen ≥ 4 - Total Dissolved Solids 2000 2000 Suspended Solids 50 60 Color Free of colored materials Free of colored materials Oil and Grease 10 10 Sulphide 1 1 Cyanide - 0.1 Phosphates - 10 Nitrates 50 40 Fluorides - 0.5 Phenols - 0.005 Insecticides ND ND Total Heavy Metals 1 1 Fecal Coliform Count (No. in 100 ml) 5,000 5,000

(1) According to Article 66 of the Executive Regulations of Law 48 of 1982 (2) According to Article 66 of the Executive Regulations of Law 48 of 1982


In addition, Egyptian Law 48 provides for the protection of inland water bodies, particularly potable water sources, as follows:

• It is prohibited to discharge any industrial effluents or drainage wastewater into water bodies used for potable supply or into underground water reservoirs. Under certain circumstances, the Ministry of Irrigation may authorize the discharge of pre-treated industrial effluents into underground water reservoirs according to specific criteria determined in the present regulations.

• Cooling water may not be discharged into inland waters, unless the water is extracted from the same body to which it is being discharged, or at least from a similar source (with respect to water quality). In such cases, cooling systems should be closed, and the discharge not mixed with any other effluent wastes of any industrial operations.

• The outfall pipe for the discharge of treated effluents discharged to an inland waterway must be located visibly and positioned above the highest water level of the waterway. The discharge pipe should be at a distance not less than 3 km upstream of any potable water extractions, or at least 1 km downstream.

Drainage of Liquid Wastes (Discharges to Sewer) Egyptian Law Number 93 of 1962 Concerning the Drainage of Liquid Wastes (as amended by Decree 44 of 2000) prohibits drainage of liquid wastes except by virtue of a license from the department responsible for sewage disposal (it should be noted that no such entity exists in desert areas). The drainage technique employed must fulfill all requirements and specifications and criteria stipulated by the Ministry of Health. If liquid wastes are to be reused for irrigation purposes (including irrigation of landscaped areas), criteria have to be fulfilled depending on the nature of the wastes. The agricultural use of land irrigated with treated effluent is also restricted, depending on the type of use proposed and the types of crop to be cultivated. For the purposes of utilizing liquid waste streams for irrigation purposes, liquid wastes are divided into three categories:

• First Category: liquid wastes generated from public sanitary treatment processes which are managed by central or local government authorities or by government-owned general organizations;

• Second Category: liquid wastes generated from private sanitary drainage operations (similar to the First Category, but privately owned); and

• Third Category: industrial liquid wastes. Treated liquid wastes may only be used for land irrigation after receiving approval from the Ministry of Health. The land to which the wastes are


disposed is required to be located at a distance of at least 3 km from built-up areas or the city or village, whichever is further. The waste stream must meet the maximum criteria for disposal as summarized in Table 2.7

TABLE 2.7 Maximum Criteria for Authorized Re-Use of Treated Wastewater and Requirements for Treatment (1)

Parameter Units First Category (Primary Treatment)

Second Category (Secondary Treatment)

Third Category (Advanced Treatment)

BOD5 ppm 300 40 20 COD ppm 600 80 40 Total Suspended Solids

ppm 350 40 20

Oils & Lubricants

ppm - 10 5

No. of Enteric Nematode Eggs

No. /100 l

- 1,000 100

Maximum concentration of Total Solute Salts (2)

ppm 2,500 2,000 2,000

%-age of sodium absorption

% 25 20 20

Chlorides ppm 350 300 300 Boron ppm 5 3 3 Cadmium ppm 0.05 0.01 0.01 Lead ppm 10 5 5 Copper ppm - 0.2 0.2 Nickel ppm 0.5 0.2 0.2 Zinc ppm - 2 2 Arsenic ppm - - 0.1 Chromium ppm - - 0.1 Molybdenum (3) ppm - 0.01 0.01 Manganese ppm 0.2 0.2 0.2 Iron ppm - 5 5 Cobalt ppm - 0.05 0.05

2.3.4 Legislation and Standards Applicable to Marine Discharges

Marine Discharges Egyptian Law No. 4 of 1994 Concerning the Protection of the Environment provides the basis for regulating impacts on the aquatic environment. The Law states that:

“It is prohibited for all establishments, including public places and commercial, industrial, touristic and service establishments, to discharge or throw any untreated substances, wastes or liquids which may cause pollution along the Egyptian sea shores or adjoining waters either directly or indirectly, intentionally or unintentionally” (4).

(1) According to Law No 93 as amended by Decree 44 of 2000 (2) According to the Decree on Plant Endurance (3) Relevant to production of green fodder crops only. (4) Part Three, Protection of the Water Environment from Pollution, Article 69.


Limits and Specifications for Draining and Disposing of Certain Substances into the Marine Environment are given in Annex 1 to the Executive Regulations of Law No. 4 of 1994, concerning the protection of the environment. Discharges to the marine environment may not exceed the concentration limits indicated in Table 2.8. In all cases, drainage and discharge into the marine environment is only permissible at a minimum distance of 500 m from the coastline. Drainage and discharge is not permitted in fishing zones or swimming zones or in zones designated as nature reserves.

TABLE 2.8 Maximum Limits for Discharges to the Marine Environment (1)

Parameter Maximum Limits and Specifications [(mg/L) – unless otherwise indicated]

Temperature Not more than 10 degrees over existing level pH 6 – 9 Color Free of colored agents Biochemical Oxygen Demand 60 Chemical Oxygen Demand (Dichromate) 100 Total Dissolved Solids 2,000 Fixed (Ash of) Dissolved Solids 1,800 Suspended Solids 60 Turbidity NTU 50 Sulphides 1 Oil and Grease 15 Hydrocarbons, of oil origin 0.5 Phosphates 5 Nitrates 40 Phenols 1 Fluorides 1 Aluminum 3 Ammonia (Nitrogen) 3 Mercury 0.005 Lead 0.5 Cadmium 0.05 Arsenic 0.05 Chromium 1 Copper 1.5 Nickel 0.1 Iron 1.5 Manganese 1 Zinc 5 Silver 0.1 Barium 2 Cobalt 2 Pesticides (Total) 0.2 Cyanide 0.1 Fecal Coliform Count (No. in 100 ml) 5,000

(1) As presented in Annex 1 of the Executive Regulations of Law 4, 1994. Note that Article 54 of Law 4, 1994 should be consulted as well to assess whether applicable requirements are contained therein.


Pollution With Sanitary Drainage Wastes and Garbage Article 54 of Law 4 specifies the requirements for ships and offshore platforms with respect to sanitary drainage. This article requires that ships shall be provided with a Sanitary Drainage Waters Treatment Unit, and that no ship may drain or dispose of treated sanitary drainage waters within four nautical miles from the shoreline. The article does allow discharge of untreated wastes beyond a distance of 12 nautical miles from the shoreline. Non-Biodegradable Polluting Substances The concentration of a given pollutant in the marine environment will depend on the quantity discharged and the rate at which it breaks down in the environment. There are a number of substances that are known to be non-biodegradable and are therefore prohibited from being discharged into the marine environment under Law 4 (Annex 10) as follows:

• Persistent non-organic substances including mercury (and its compounds), lead (and its compounds) and cadmium (and its compounds);

• Persistent organic substances including organophosphorus pesticides, dimethoate and malathion;

• Organochlorine pesticides, aldrin, dieldrin, DDT, chlordane and endrin (which persist over several months);

• Non-degradable compounds including polychlorinated biphenyls (PCBs), Aroclor 1254 and 2,3,6-Trichlorobiphenyl;

• Substances which are not completely degradable and are considered highly toxic in very low concentrations including polynuclear aromatic hydrocarbons (PAHs, e.g., benzo(a)pyrene, naphthalene); and

• Solid substances such as plastic bottles and nets which only degrade after a significant length of time.

Accidental Releases Article 50 of the Executive Regulations of Law 4 of 1994 state that:

“ship owners, ship captains, or any other persons in charge of ships and those responsible for oil transport consignments within ports, territorial waters, or the exclusive economic zone of the Arab Republic of Egypt, and the companies operating in hydrocarbon exploration and extraction, must immediately notify the competent administrative bodies of every oil leakage incident upon its occurrence”.

The responsible parties must indicate the place and circumstances of the incident, type of leaking materials, quantities, and the procedures taken to stop or limit such leakage, with the provision that the notification shall include the following data:


• Procedures taken for dealing with the leakage;

• Quantities and types of dispersants used;

• Probable source of leakage, and whether or not a fire has broken out;

• Direction in which the formed oil spill is moving;

• Rate of leakage, if ongoing;

• Dimensions of the oil spill;

• Wind velocity and speed, temperature, and extent of visibility;

• Direction of current speed, and water temperature;

• Condition of the sea;

• Tide status (overflowing, high, medium, weak);

• Details of threatened coastal areas;

• Nature of the area: coral reefs – marine organisms; and

• Reporting source: -name – telephone – address. In all cases, the competent administrative bodies are required to notify the EEAA of all information on a given incident, upon its occurrence, in order to enable the EEAA to follow up the procedures taken, according to the responsibilities of the Agency, as prescribed in Article No. 5 of Law 4.

2.3.5 Legislation and Standards Mainly Applicable Noise Egyptian Law No 4 of 1994 Concerning the Protection of the Environment provides the basis for regulating noise emissions. The regulations pertain principally to noise limits in the workplace and Table 2.9 presents the maximum permissible noise levels inside the workplace.

TABLE 2.9 Maximum Permissible Noise Levels Inside the Workplace (dB(A)) (1)

Type of Place and Activity Maximum Permissible Noise Level

Workplace with up to 8 hour shifts and aiming to limit noise hazards on hearing 90 Workplace where acoustic signals and good audibility are required 80 Work rooms for the follow up, measurement and adjustment of high performance operations

65

Work rooms for computers, typewriters and similar equipment 70 Work rooms for activities requiring routine metal concentration 60

Maximum noise intensity must not exceed 90 dB(A) during a daily 8 hour work shift. However if noise intensities do exceed 90 dB(A), the periods of exposure must be reduced according to the levels and exposure periods presented in Table 2.10.

(1) According to Annex 7 of the Executive Regulations of Law 4 of 1994


TABLE 2.10 Maximum Exposure Periods to Different Noise Levels (dB(A)) (1)

Noise Intensity Level 95 100 105 110 115 Period of Exposure (hours) 4 2 1 0.5 0.25

Noise intensity levels should at no time exceed 135 dB(A). For semi-continuous noise events such as those associated with operation of machinery, where the period between noise events is one second or more, the frequency of noise events should not exceed the number of events detailed in Table 2.11. If there is less than one second between noise events, then the noise shall be considered as a continuous noise source and levels shall be as per the criteria specified in Table 2.9 and Table 2.10.

TABLE 2.11 Frequency of Noise Events at Different Intensities (2)

Noise Intensity (dB) Number of Permissible Impacts During the Working Day 135 300 130 1,000 125 3,000 120 10,000 115 30,000

Limits are also given for ambient noise levels, according to the type of area the source is located in, as presented in Table 2.12.

TABLE 2.12 Maximum Permissible Limits for Noise Intensity (dB(A)) (3)

Type Of Area Day Evening Night Commercial, administrative and downtown areas 55-65 50-60 45-55 Residential with some workshops or commercial establishments or which are located on a main road

50-60 45-55 40-50

Residential areas in the city 45-55 40-50 35-45 Residential suburbs with low traffic 40-50 35-45 30-40 Residential rural areas, hospitals and gardens 35-45 30-40 25-35 Industrial areas (heavy industries) 60-70 55-65 50-60

NOTE:“Day” means from 07:00 to 18:00; “Evening” from 18:00 to 22:00; “Night” from 22:00 to 07:00

2.3.6 Legislation and Standards Mainly Applicable to Hazardous Substances and Waste

Article 25 of the Executive Regulations to Law 4 sets out procedures for waste management, particularly of potentially hazardous materials. Law 4 states that:

“It is forbidden to displace and use hazardous substances and waste without a license from the competent authority….”

The categories of wastes that might be generated by Apache’s operations and the relevant competent authorities for their disposal are:

• hazardous industrial substances - Ministry of Industry; (1) According to Annex 7 of the Executive Regulations of Law 4 for 1994 (2) According to Annex 7 of the Executive Regulations of Law 4 of 1994 (3) According to Annex 7 of the Executive Regulations of Law 4 of 1994


• Hazardous pharmaceutical, hospital and laboratory substances and domestic insecticides - Ministry of Health;

• Hazardous petroleum substances and waste - Ministry of Petroleum; and

• Hazardous inflammable and explosive substances - Ministry of Interior. With respect to other non-hazardous materials, the Regulations state that

“respective bodies competent to issue a license for their displacement shall be designated by a decree of the Minister for Environmental Affairs on the basis of a proposal by the CEO of the EEAA.”

Further, that:

“…an emergency plan is in place to confront any potential accidents which may occur during the production, storage, transportation or handling of such substances, provided the plan is reviewed and approved by the licensing authority after consulting the EEAA and the Civil Defense Department”.

2.3.7 Legislation and Standards Mainly Applicable to Archaeological Heritage

Law No. 117 of 1983 deals with the protection of antiquities. It is the main law in Egypt regarding the protection of archaeological and historical sites. According to this law, the Egyptian Antiquities Organisation (EAO) is the authority concerned with the supervision of all archaeological affairs and sites in the country (Article 5). The Authority is responsible for discovery of antiquities and all exploration activities on Egyptian territory. Specialized national or foreign scientific organizations may be permitted by the Authority to undertake explorations on a specific site and for a limited period, after fulfilling certain conditions. The use of archaeological land for building and cultivation purposes is prohibited (Article 20). Furthermore, lands owned by individuals may be expropriated because of their archaeological importance (Article 18). Protection of newly discovered important sites in desert areas can be obtained through a Ministerial Decree upon advice of the Authority (Article 20). The responsibility of EAO furthermore includes photographing and documentation of antiquities, as well as surveys to map and delineate archaeological sites (Article 26). The Authority will give priority permission for missions to excavate antiquities in case of environmental threats or urban expansion (Article 31). Missions can only work under direct supervision of the Authority and according to certain specified terms and conditions (Article 32 and Article 33).


2.4 INTERNATIONAL LEGISLATION, PROTOCOLS AND AGREEMENTS

2.4.1 Introduction There are a number of international conventions, protocols and agreements dealing with environment to which the Government of Egypt is a signatory. Those of greatest relevance to Apache’s operations in Egypt are summarized in the following sections.

2.4.2 International Convention for the Prevention of Pollution of the Sea by Oil, 1954 (OILPOL) The discharge of oil or oily mixtures to sea from vessels is regulated by the terms of OILPOL. While the Convention does not deal with the releases from offshore installations per se, it regulates vessels operating in offshore oil fields by prohibiting the deliberate discharge of oil or oily mixtures from nearly all seagoing vessels in specific areas called ‘prohibition zones’. Prohibited zones generally extend at least 50 miles (80 km) from all land areas.

2.4.3 International Convention for the Protection of Pollution from Ships, 1973 (MARPOL) The Arab Republic of Egypt is a signatory to the MARPOL Convention which it has also ratified. Throughout most of the world, MARPOL has superseded OILPOL, and MARPOL standards are adhered to by most offshore operators. MARPOL places restraints on the contamination of the sea, land and air by ships. It has two protocols dealing respectively with reports on incidents involving harmful substances and arbitration; and five annexes which contain regulations for the prevention of various forms of pollution:

• Annex I - Prevention of pollution by oil;

• Annex II - Control of pollution by noxious substances;

• Annex III - Harmful substances carried in packaged form;

• Annex IV - Prevention of pollution by sewage; and

• Annex V - Prevention of pollution by garbage from ships. MARPOL is noteworthy among international marine conventions in that it is one of the few that prescribe specific limits on discharges rather than concentrating on strategic policy objectives.


2.4.4 The Oil Preparedness, Response and Co-operation Convention 1990 (OPRC) The Oil Pollution Preparedness, Response and Co-operation Convention came into force in May 1995 and relates to oil pollution of the marine environment throughout the world from offshore units. The convention covers much of the same area of concern as the Barcelona Convention (specifically the Protocol Concerning Cooperation in Combating Pollution of the Mediterranean Sea by Oil and Other Harmful Substances in Cases of Emergency (1976)) as described in Section 2.4.5. In particular, States must establish national programs for responding to oil pollution incidents, while operators of offshore units are required to have oil pollution emergency plans in place, which are co-coordinated with the national oil response program. Further sections of the Convention deal with provision of oil pollution combating equipment, reporting, training, salvage and international cooperation.

2.4.5 Barcelona Convention on Protection of the Mediterranean Sea Against Pollution The Convention for the Protection of the Mediterranean Sea against Pollution (the Barcelona Convention) was signed by Egypt in 1976 and has been subsequently ratified. The Convention was amended in 1995 to form the new Convention for the Protection of the Marine Environment and the Coastal Region of the Mediterranean. A number of protocols have been agreed under the original convention or its amendment, dealing in detail with the different aspects of marine environment protection, which have been agreed under the Conventions. Since Egypt is a signatory of the Barcelona Convention, Apache will have to comply with the following six relevant protocols developed under the Convention.

• Protocol for the Prevention and Elimination of Pollution of the Mediterranean Sea by Dumping from Ships and Aircraft or Incineration at Sea, 1976 (amended version adopted by the contracting parties in 1995).

• Protocol Concerning Cooperation in Combating Pollution of the Mediterranean Sea by Oil and Other Harmful Substances in Cases of Emergency, 1976. (A new text entitled Protocol Concerning Cooperation in Preventing Pollution from Ships and, in Cases of Emergency, Combating Pollution of the Mediterranean Sea, was signed on January 25, 2002, but has yet to be ratified by Egypt).

• Protocol for the Protection of the Mediterranean Sea against Pollution from Land-Based Sources and Activities, 1980.

• Protocol Concerning Specially Protected Areas and Biological Diversity in the Mediterranean, 1995 (annexes adopted 1996). (Replaced the 1982 SPA Protocol).

• Protocol for the Protection of the Mediterranean Sea against Pollution Resulting from the Exploration and Exploitation of the Continental Shelf and the Seabed and the Subsoil, 1994.

• Protocol on the Prevention of Pollution of the Mediterranean Sea by Transboundary Movements of Hazardous Wastes and their Disposal, 1996.


Protocol of Most Relevance to Apache’s Proposed Offshore Operations Of these six protocols, The Protocol for the Protection of the Mediterranean Sea Shelf against Pollution Resulting from the Exploration and Exploitation of the Continental Shelf and the Seabed and its Subsoil (1994) relates specifically to the environmental conduct of offshore exploration and production operations in the Mediterranean. Egypt is party to this protocol, the key elements of which are described below as either general or specific requirements. • General requirements for the authorization of hydrocarbon exploration and

production activities are as follows:

- All activities, including the erection of on site installations, shall be subject to prior authorization for exploration and production from the competent authority. The authority shall be satisfied that the installation has been constructed according to international standards and practice and that the operator has the technical and financial capacity to carry out the activities.

- No detrimental effects to existing facilities should arise from the siting of a new installation.

- An Environmental Impact Assessment is to be carried out.

- The geographical areas where the activity is envisaged, including safety zones, must be defined.

- Particulars of the professional and technical qualifications of the candidate operator must be given.

- The safety measures to be taken for protecting human life, preventing and combating accidental pollution and facilitating prompt response to an emergency must be detailed.

- Operators must have a contingency plan.

- Monitoring procedures should be defined.

- Plans should be drawn up for the removal of installations.

- Operators must possess insurance or other financial security to cover liability.

• The specific requirements in the Protocol relating to pollution control are as

follows:

- The use of diesel-based muds is prohibited. Low toxicity oil-based drilling fluids may be used, but discharge at sea is prohibited. Drill cuttings may be discharged to sea at an appropriate site, with a discharge limit of 100 g/kg oil on cuttings.

- For production and development drilling, a program of seabed sampling and analysis relating to the zone of contamination must be undertaken.

- For produced water, an absolute maximum oil concentration of 100 mg/L is set, along with an average maximum oil content 40 mg/L.


- A Chemical Use Plan must be submitted by the operator for approval (to include water-based drilling fluids).

- Oily waste and sludges must be transported to shore.

- Sewage treatment is generally required for installations permanently manned by 10 or more persons. Discharges causing visible floating solids, or discoloration or opacity of the surrounding water are not permitted.

- Garbage is to be taken to a designated onshore disposal facility. Food waste may be discharged to sea if more than 12 nautical miles (approximately 22 km) from the shore.

- A special permit is required for the use of biocides.

- For machinery space drainage, a limit of 15 mg/L oil in water is set.

Protocol of Most Relevance to Apache’s Onshore Operations Of the six protocols agreed under the Barcelona Convention, the most relevant to the operation of onshore facilities is the Protocol for the Protection of the Mediterranean Sea against Pollution from Land-Based Sources and Activities, 1980 (1). This relates specifically to point and diffuse discharges onshore and therefore is relevant to any discharges to sea from onshore treatment facilities. The key requirements of the protocol which are relevant to Apache’s operations are:

• Point source discharges are subject to authorization;

• Best Available Techniques must be applied; and

• Risk of pollution caused by accidents must be minimized.

2.4.6 Other International Agreements of Potential Relevance to Hydrocarbon Developments Egypt is a signatory to a variety of other international agreements. Those that may have implications for hydrocarbon developments are outlined below.

• Egypt has signed the 1972 Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (the London Dumping Convention), which regulates the disposal of potentially hazardous materials to sea.

• The Vienna Convention for the Protection of the Ozone Layer and the Montreal Protocol on Substances that Deplete the Ozone Layer require strict controls on the use of, inter alia, CFCs, HCFs and Halons.

• The Convention on Biodiversity requires Egypt to take measures to preserve its natural biodiversity through the protection of key species and habitats. Other international agreements relating to the protection of flora and fauna include the Bonn Convention on the Conservation of Migratory Species of Animals, and the Convention on the International Trade in Endangered Species (CITES).

(1) Amended version adopted by the Contracting Parties in 1996.


• Egypt is a signatory of the Ramsar Convention (Convention on Wetlands of International importance especially as Waterfowl Habitat), and has designated Lake Burullus under the terms of this agreement. It is likely that Lake Idku may be similarly designated in the future, and has already been identified as an Important Bird Area.

2.5 WORLD BANK AND IFC ENVIRONMENTAL GUIDELINES

The World Bank and International Finance Corporation guidelines include General Environmental Guidelines (contained in the Pollution Prevention and Abatement Handbook, 1998) and sector-specific guidelines for oil and gas development onshore and offshore. This section describes those specific standards relevant to the project and does not provide an exhaustive overview of the guidelines in their entirety.

2.5.1 World Bank/IFC Guidelines for Atmospheric Emissions Table 2.13 presents the World Bank guidelines with regard to the maximum ground level concentration of contaminants allowed in ambient air at the site boundary.

TABLE 2.13 World Bank Guidelines – Ambient Air Quality (1)

Contaminant Averaging Period World Bank Maximum Concentration (µg/m3)

PM10 24-hr (maximum) 70 Annual 50 NOx 24-hr (maximum) 150 SO2 24-hr (maximum) 125 Annual 50 NOTES: The contaminant concentrations will be calculated for conditions of 1 atmosphere and 298°K. Table 2.14 presents the World Bank guidelines with regard to atmospheric emissions from Oil and Gas Development (Onshore).

TABLE 2.14 Air Emissions from Onshore Oil and Gas Production (World Bank, 1998) (2)

Parameter Maximum Value (mg/Nm3) VOCs (including benzene) 20 Hydrogen Sulphide 30 Sulphur Oxides 1,000 Nitrogen Oxides (gas fired) 320 (or 86 ng/J) Nitrogen Oxides (oil fired) 460 (or 130 ng/J) Odor Not offensive at the receptor end (Hydrogen

sulphide should be less than 5 mg/Nm3)

(1) General Environmental Guidelines (in Pollution Prevention and Abatement Handbook, 1998. (2) Guidelines for Onshore Oil and Gas Production, World Bank 1998.


Table 2.15 presents the IFC guidelines with regard to atmospheric emissions from Oil and Gas Development (Offshore).

TABLE 2.15 Air Emissions from Offshore Oil and Gas Production (IFC, 2000) (1)

Parameter Maximum Value (mg/Nm3) Sulphur Oxides (oil production) 400 Nitrogen Oxides 1,000

2.5.2 Quality Guidelines for Aqueous Effluent

The following table (Table 2.16) shows the limits on specific regulated constituents in effluent streams discharged to surface waters from onshore oil and gas production facilities, as stipulated by the World Bank.

TABLE 2.16 Effluent Discharge Limits from Onshore Oil and Gas Production (2)

Parameter Maximum Value pH 6-9 BOD (5-day), mg/L 50 Total Suspended Solids, mg/L 50 Oil & Grease, mg/L (3) 20 Phenol, mg/L 1 Sulphide, mg/L 1 Total toxic metals, mg/L (4) 5 Temperature Increase, °C (5) <3 Table 2.17 shows the limits on specified regulated constituents in effluent streams discharged to marine waters from offshore oil and gas production facilities, as stipulated by the IFC.

(1) Guidelines for Offshore Oil and Gas Production, IFC, 2000. (2) From Guidelines for Onshore oil and Gas Production World Bank, 1998. (3) Up to 40 mg/l is acceptable for facilities producing less than 10,000 tons per day. (4) Toxic metals include antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, vanadium and zinc. (5) The effluent should result in a temperature increase of no more than 3°C at the edge of the zone where initial mixing and dilution take place. Where the zone is not defined, use 100 meters from the point of discharge.


TABLE 2.17 Effluent Discharge Limits for Offshore Oil and Gas Production (1)

Parameter Requirement Oil & grease (2) (daily average) 42 mg/L Oil & grease (monthly average) 29 mg/L Deck Drainage No visible sheen Drilling Fluids and Cuttings (3) (non-water based)

No discharge allowed except in compliance with 96-hr LC50 of SPP-3% volume. Toxicity test first for drilling fluids or alternatively testing based on site-specific species agreed with IFC. Discharge via a caisson at least 15 m below sea surface.

Drilling Fluids and Cuttings (water based) No discharge allowed except in compliance with 96-hr LC50 of SPP-3% volume. Toxicity test first for drilling fluids or alternatively testing based on site-specific species agreed with IFC. Discharge via a caisson at least 15 m below sea surface. Maximum chloride concentration must be less than four times ambient concentration of fresh or brackish receiving water.

Diesel oil No discharge allowed. Can only be used to free stuck pipe in an emergency.

Additives and chemicals No limitation except toxicity testing of chemicals for hazards.

Produced sand Discharge not permitted – reinject or take ashore.

Produced water If separated and disposed at locations other than the platform, it must, at a minimum, meet these guidelines.

Sanitary effluents and sink drainage (gray water)

Package treatment and chlorination to an average of 1 mg/L residual chlorine (because of concerns about chlorinated hydrocarbons, alternative forms of disinfection should be evaluated.)

Cooling Water The effluent should result in a temperature increase of no more than 3°C at the edge of the zone where initial mixing and dilution take place. Where the zone is not defined, use 100 meters from the point of discharge.

2.5.3 Standards for Ambient Noise Levels

World Bank standards for onshore oil and gas development specify the following noise limits (set out Table 2.18) measured at receptors located outside the project site boundary, or a maximum increase in the ambient level of Leq 3 dB(A), whichever is the higher. For personnel working in the plant, the exposure should be limited to 90 dB(A) (8-hr Leq). (1) From Guidelines for Offshore Oil and Gas Production, IFC, 2000. (2) Testing for oil and grease should be done according to the Oil and Grease Test Method 1664 Revision A employing normal hexane as an extracting solvent as approved by the USEPA. (3) Products used in concentrations that could cause these effects should be avoided - a risk based approach is recommended. Equivalent screening procedures or risk evaluations may be acceptable to IFC.


TABLE 2.18 World Bank Maximum Allowable Noise Levels (Leq 1 hour dB(A)) (1)

Receptor Daytime Night-time Residential, institutional, educational 55 dBA 45 dBA Industrial, Commercial 70 dBA 70 dBA NOTES: Day Time - from 7 am to 10 pm Night Time - from 10 pm to 7 am

2.5.4 General Guidance

The IFC Guidelines for Oil & Gas Developments (Offshore) include a number of Environmental Best Practices, which will be applied by Apache and its contractors where project resources permit. General guidance on good practice is summarized in Box 2.1.

(1) General Environmental Guidelines - Pollution Prevention and Abatement Handbook, 1998.


BOX 2.1 Environmental Best Practice for Offshore Oil & Gas Developments (IFC, 2000)

Drilling Management: • Use directional drilling (horizontal and extended reach) techniques to avoid sensitive surface

areas and to gain access to the reservoir from less sensitive surface areas; where this is not possible, provide a documented explanation.

• Use closed loop systems. • Reduce the hydrocarbon content of cuttings by mechanical, chemical or thermal clean-up

treatment where possible or transport them to shore for treatment or disposal or consider annulus or down-hole injection.

• Use enhanced solids control systems to reduce the amount of wastes from circulation systems and the amount of dilution.

• Develop and use chemicals with the lowest toxicity and the lowest levels of biologically available heavy metals and other hazardous substances, especially persistent organic chemicals and substances with a potential to bioaccumulate.

• Minimize, and avoid where possible, the use of toxic additives in drilling fluids. Produced Water Management: • Consider alternatives to surface discharge of produced water, such as re-injection, onshore

treatment and disposal and down-hole separation of oil and water. • Minimize the quantity and reduce the toxicity of discharged produced water. • Select the least hazardous chemicals in order to minimize produced water toxicity. • Reuse produced water and recover oil from process wastewater prior to disposal. Chemical Management: • Use a chemical hazard assessment and risk management techniques to evaluate chemicals and

their effects, and utilize the least toxic and hazardous chemicals (considering persistence and bioaccumulation aspects).

• Use low toxicity lubricant additives to reduce the overall toxicity of drilling fluids where possible.

Solid Waste Management: • All solid wastes such as packaging materials, containers, discarded and damaged drill bits and

pipe and leftover construction materials are to be taken ashore and appropriately reused, recycled or disposed of at an appropriate facility.

Hazardous Waste Management: • Hazardous wastes such as paint residues, solvents, batteries, mercury lamps, pig cleaning

sludges and contaminated chemicals from drilling and production operations are to be taken to onshore facilities for treatment and disposal. Efforts should always be made to eliminate, reduce, or recycle hazardous waste.

Naturally Occurring Radioactive Materials (NORMs): • The NORM accumulation process is very gradual and often unpredictable. Radiation surveys

of equipment and sites should be undertaken every five years or when equipment is to be taken out of service for maintenance. Where NORM bearing scale is anticipated or found, use scale inhibitors and personal protective equipment where necessary. Sludge, scale or NORM impacted equipment must be treated, processed or isolated so that the treated waste does not exceed the background radioactivity concentration of the disposal site by more than 5 pCi/g. Alternatively, the waste may be disposed of at a facility that is licensed to receive such waste.

Other • Implement leak prevention, inspection and maintenance, and repair programs to ensure that

all equipment is performing up to industry standards. • Take all reasonable measures to prevent and promptly correct all leaks from all equipment,

facilities, pipelines and storage facilities.


2.6 APACHE CORPORATION ENVIRONMENTAL HEALTH AND SAFETY POLICY The contents of Section 2.6 are based entirely on information provided by Apache.

2.6.1 Introduction to Apache’s EHS Philosophy Apache’s Environmental Health & Safety group coordinates the company's environmental and safety programs around the world. Apache recognizes that it is incumbent on a company that derives its benefits from the Earth’s resources to take responsibilities to the environment seriously. Apache's operations have been recognized in several countries for its protection of natural resources. Not content with a safety record that is consistent with that of its peers, Apache’s EH&S group constantly looks for areas for improvement. As a corporate goal, employee safety is on the same level as all business goals. Current objectives include:

• Making an already strong management commitment to EH&S more visible to the entire company.

• Implementing performance measures as a means of tracking and monitoring the effectiveness of Apache’s safety programs.

• Formalizing environmental and safety compliance auditing. • Enhancing contractor safety through revisions to master service agreements. • Energizing the safety-training meeting curriculum.

2.6.2 Apache’s Environmental Policy Apache’s environmental policy is reproduced in Box 2.2.

BOX 2.2 Apache's Environmental Policy One of Apache’s Core Values is conducting our business with honesty and integrity which means that we will conduct our business in an environmentally responsible manner. Conducting our business in an environmentally responsible manner means that we shall:

• Comply with all Federal, State and local environmental laws and regulations in all its operations.

• Continually endeavor to manage environmental risk through contingency planning and training of its employees in environmental compliance.

• Conduct periodic audits of our operations to ensure compliance.

• Expect that all contractors and other parties engaged in activities on our operated properties will abide by our environmental policies as well as Federal, State and local environmental laws and regulations.

• Recognize that our management believes that every employee is responsible for the environmental compliance for the company.


2.6.3 Apache’s Safety Policy Apache’s safety policy is reproduced as Box 2.3.

BOX 2.3 Apache's Safety Policy One of Apache’s core values is conducting our business with honesty and integrity, which means that we will conduct our business safely. Apache Corporation is committed to conducting our business in a manner that protects the health and safety of our employees, contractors and the general public. We believe that work-related injury and illness are preventable and we strive to continuously improve our safety and health performance. To meet these commitments, Apache and its contractors shall:

• Recognize that no business objective is so important that it will be pursued at the sacrifice of safety.

• Recognize that each of us has the responsibility to make the safety of our co-workers and ourselves a primary concern. Comply with all federal, state, local and industry safety and health regulations and laws.

• Comply with all federal, state, local and industry safety and health regulations and laws.

• Identify and eliminate potential hazards. Control and safely manage those hazards that cannot be eliminated.

• Set quantifiable safety objectives and targets that result in continual improvement. Regularly monitor and report performance against those targets.

• Hold employees, supervisors, management and contractors accountable for their safety and the safety of personnel in their charge.

2.7 COMMITMENTS DETAILED IN THE CONCESSION AGREEMENTS The Contractor and the Operating Company under the Egyptian concession agreement are subject to the general laws of the Arab Republic of Egypt to the extent those laws are not inconsistent with the concession agreement (which has the force of law itself). More recent concession agreements contain specific obligations explicitly subjecting the Contractor and the Operating Company to Law No. 4 of 1994 concerning environmental protection and to the regulations issued pursuant to it. Older concession agreements (issued, generally speaking, in the 1990’s and before) do not contain such a provision. It is likely the EGPC and the Government of Egypt will take the position that Law No. 4 of 1994 is not inconsistent with those older agreements and therefore applies to the Contractor and the Operating Company under those concession agreements as well. There are several other provisions of the concession agreement which, though not specifically addressed to EH&S matters, can nevertheless have EH&S implications under certain circumstances. These provisions include those relating to adherence to industry standards; liability for damages; loss or waste of petroleum; and record-keeping, reporting, and inspection.


2.8 COMMITMENTS DETAILED IN THE EIAS

2.8.1 Environmental Impact Assessment for Egyptian Oil and Gas Activities The EIA for Egyptian Oil and Gas Activities (February 2004) covers Apache’s onshore interests in Egypt outside of the West Mediterranean Concession Area. The commitments detailed in the EIA Report are summarized in Table 2.19 under the following headings:

• Drilling operations;

• Pipeline construction and operation; and

• Oil and gas plant construction and operation.


TABLE 2.19 Table of EHS Commitments and Mitigation: Onshore Operations

Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA A Drilling Operations Section 3.1 1. Waste Management The Contractor shall operate a waste management system in accordance with

Apache’s requirements and as directed by Apache’s drilling supervisors. Wastes shall be stored in designated containers, which shall be demonstrated to be suitable for the waste being stored. Incompatible wastes shall be physically separated; in particular, hazardous wastes shall not be mixed. Appropriate storage areas shall be provided for waste containers prior to transfer to disposal facilities. Storage areas should be defined and marked on a site plan. All waste containers shall be labeled. Manual handling of waste containers shall be minimized, and wherever practicable, waste shall be transported on pallets. A transfer shall be completed for all waste loads leaving the Contractor’s premises. The Contractor should keep copies of the transfer note, and records kept for a minimum of 2 years. A second copy shall accompany the waste if it is to be transported to an Apache operated facility and handed to the Apache person responsible for receiving such wastes. A third copy shall be sent to Apache’s Drilling Manager. The Contractor shall transport waste in an appropriate vehicle to the specified disposal sites.

Apache will audit Contractor’s Waste Management System from time to time.

Section 3.1.2

Drill Cuttings Mitigation measures in place for the treatment of drill cuttings are conducted using API testing methods for water based cuttings, then determining the appropriate disposal method. OBM drill cuttings are transported in enclosed containers to a treatment and disposal (incineration) facility approved by EEAA. OBM Mud Cuttings are transported in enclosed containers and transported to a treatment and decontamination facility approved by local EEAA authorities through incineration processes to ensure emissions to atmosphere are colorless, odorless and below set European emission standards.

Section 3.1.2


Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA Garbage Garbage and other solid wastes (wires, metal drums, scrap metal, plastic

etc.) are collected and disposed of in an authorized disposal site selected by the local authority.

Section 3.1.2

Drilling Fluids Water-based drilling mud is reused and only the unrecoverable portion is properly covered to reinstate the soil quality after thorough verification that no adverse environmental impact occurs by conducting API field testing. OBM drilling fluid is sold back to approved vendor for processing and reuse with all non-used residues being sent in enclosed containers to a treatment and disposal (incineration) facility approved by EEAA.

Section 3.1.2

Domestic Sewage Domestic sewage is collected in closed tanks and transported to the nearest public sewer for discharge.

Section 3.1.2

2. Accidental Spillages of Fuels and Lubricants

Response procedures will be implemented. They include, but are not limited to, the following: • Barriers and dikes will be used around the contaminated area to prevent

the spread of the spill. • Contaminated topsoil will be removed and placed in specific containers. • The awareness of the on site staff will raised with respect to managing

fuel or lubricant spills properly if they occur.

Section 3.1.2

3. Mobilization of Heavy Equipment & Accessibility

For the new access roads, reinstatement procedures will take place after the rig demobilization. Best efforts will be implemented so as to restore the topographic features of the soil. Upgraded existing roads will be left for local use. During rig mobilization, the Contractor will follow, as much as possible; the existing tracks to maintain the fragile micro-surface layers. Moving inside the proposed area with cars, trucks and other means of transportation will be done as slowly as possible.

Section 3.1.2

4. Drilling Camps Pre-installed camps are used at the site. Minimal impacts will be caused to the soil.

Section 3.1.2


Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA 5. Noise during Drilling Operations

Best efforts are usually implemented to complete all the operations in a timely manner to minimize the disturbance by noise. All well locations are far from any residential areas due to the nature of the concession areas. Noise during drilling operations is a temporary effect and will cease by the end of the project. Personal protective hearing equipment will be provided to the workers at the site area.

No measurable mitigation measures are implemented.

Section 3.1.2

6. Flaring during Well Testing

Apache has specified the use of high efficiency flares/burners with sufficient capacity to manage the maximum volumes of well-test hydrocarbons anticipated.

Section 3.1.2

B Pipeline Construction & Operation

No commitments identified. Section 3.2

C Oil and Gas Plant Construction & Operation

Section 3.3

1. Air Emissions Use of natural gas for heating will minimize emissions.

Section 3.3.2

2. Surface Water and Groundwater Pollution

Containment structures, pursuant to API guidelines, have been constructed to prevent contamination of surface waters resulting from accidental condensate/oil spillage.

Section 3.3.2

3. Environmental management

An environmental management system will be developed and implemented, including training and reporting.

Internal and external environmental audits will be commissioned on a regular basis.

Section 3.3.2

4. Process Water Treatment All water separated from condensate and methanol will flow to two produced water tanks. The tanks will separate free hydrocarbon from water via gravity separation. The water from these tanks is pumped to a coalescing plate interceptor or a flotation cell, which further reduces hydrocarbon concentration. Separated hydrocarbon will flow to an oil collection tank and treated process water will flow to an evaporation pond via an API oil separator.

Section 3.3.2


Environmental Impact Assessment Development Project for the West Mediterranean Deepwater Gas and Condensate Reserves (Phase 1) The EIA for the West Mediterranean Deepwater Gas and Condensate Reserves (Phase 1) (November 2003) covers Apache’s interests in the West Mediterranean Concession (located partly onshore and partly offshore). The commitments detailed in the EIA are summarized in Table 2.20 under the following headings:

• Drilling operations;

• Pipeline construction and operation;

• Susbea pipeline and facility operations; and

• Onshore gas plant construction and operation.


TABLE 2.20 Table of EHS Commitments and Mitigation: Offshore Operations

Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA A Drilling Operations Section 5.1 Navigation There will be a safety exclusion zone around the drilling unit. The drilling

units will have warning lights, radar beacons, foghorns and other identification as approved by the Egyptian Ports and Lights Authority. Detailed anti-collision and Contingency Arrangement Procedures will be developed.

Section 5.1.9

Fuel & Chemical Storage All chemicals will be stored according to the material hazardous data sheets MSDS. Berming, storage and handling procedures for fuel and chemicals are contained in the operational manual for the drilling unit.

Section 5.1.9

Drilling Mud Water-based mud will be used for drilling of the 30”, 26” and 17½” hole intervals of the proposed well as studies have indicated that the formation is suitable for such a mud system. Oil-based muds will be used during the drilling of the 12 ¼” hole interval (to total depth). Excess oil based mud and all drill cuttings generated during this hole interval will be containerized and transported to shore for proper disposal. If required, only approved biocides will be used at the manufacturer's recommended dosage. If required, only chrome-free lignosulphates will be used. Non-heavy metal pipe dope will be used to lubricate the joints in the drill string. Any other additive used will be approved for use with reference to UK, European or US standards for Mediterranean Sea. Efficient solids control equipment will be used to minimize losses of mud into the sea during drilling.

Section 5.1.9


Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA Drainage System A procedure will be developed for the inspection of the clean drainage

systems. The treated sewage will be discharged to sea via a dedicated overboard discharge line. Refer to the waste water treatment plant procedures . All machinery/oily equipment spaces, oil storage areas and bilge/leg drains will be routed to the oily water separator for treatment. A valid International Oil Pollution Certification (of inspection) and an Oil Record Book will be maintained on the drilling rig unit.

Section 5.1.9

Garbage and general wastes All general wastes and special wastes will be shipped to shore for disposal. Any special wastes will be separated out on the drilling unit and records kept of its storage transfer and disposal, via authorized contractors or correct authority. Solid waste disposal will utilize the onshore local authority approved facility. All unused chemicals will be returned to vendor (this forms part of the original contract conditions) or treated as solid waste. All empty usable chemical containers will be returned to vendor for recycling.

Section 5.1.9

Atmospheric Emissions During testing, the flare will be operated efficiently to minimize any liquid fall-out or smoke.

Section 5.1.9

Helicopter Noise Helicopters will be operated out of Alexandria airport and limited to crew changes and emergency evacuations and special flights only. To minimize disturbance by noise, planned helicopter flights will be confined to daylight hours and routed to avoid residential areas and nature reserves.

Section 5.1.9

Oil Spills Any oil spills will be managed in accordance with the National Oil Spill Contingency Plan.

Section 5.1.9

B. Pipeline Construction and Operation

Section 5.2

Interference with fishing and navigation activities.

Select pipeline route away from known fishing and navigation areas. Mark and map location of offshore pipelines. Bury pipeline that must be located in critical fishing areas.


Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA Habitat and organism losses along offshore pipeline pumping and compressor station sites.

Select route that avoids important natural resource areas. Utilize appropriate clearing techniques. Use alternative construction techniques.

Section 5.2

Potential pipeline failure. An appropriate design must be chosen which includes not only considerations of size, but also plans for the materials to be used in the lining of the pipeline. Turning points in the pipeline are the weakest points; therefore, the design will include as few turns as possible. The pipeline may be at risk of failure when it is lowered into the pipe trench, so a suitable flexible material will be selected.

Section 5.2

Interference with sensitive seabed regions.

A number of alternative routes must be considered, bearing in mind the impact that each route has on the surrounding environment. The route with the smallest impact or the most rectifiable impact should be favored.

Section 5.2

Disturbance of seabed communities.

The ‘skipper’ must take care to use the propeller as little as possible when in shallow water. Also, the skipper should avoid turning the barge around too often, as this has a similar effect. The Contractor shall adopt measures to avoid buckles in the pipeline that require recovery and minimize the number of times abandonment/recovery is carried out.

Section 5.2

Noise and Vibration

This is a short lived impact that can be regarded as unavoidable. Section 5.2

Fuel Leakage from marine Barges

Efforts should be made to keep leakage at a minimum, and there should be a constant watch for surface slicks from the barge. This is mostly important in shallower water.

Section 5.2

C Subsea Pipeline and Facility Operation

Section 5.2

Pipeline Leakage. Prevented by proper design, construction and operation to prevent weak points and corrosion. Also prevented by following API inspection procedures of subsea facilities using ROVs (Remote Operated Vehicles) to visually inspect and measure certain parameters on the pipeline (i.e., wall thickness, anode loss, etc.) Mitigated by proper design and installation of safety valves to shut in the pipeline and wells to reduce the volume of gas and condensate spilled, should a rupture occur.

Section 5.2


Potential Impacts Actions/Mitigation Monitoring/Restoration Timing Ref in EIA D Gas Plant Construction and Operation

Section 5.3

Air Emissions All gas turbines required for power generation will be equipped with low NOx burners. Compressors will have dry gas seals which do not require oil. Gas detectors will monitor for gas leaks and should any leaks be detected, compressors will be automatically shut down.

Section 5.3


3.0 ENVIRONMENTAL MONITORING PLAN

3.1 INTRODUCTION It is an Apache requirement to develop an Environmental Monitoring Plan (EMP). The EMP is required to mandate systematic monitoring of all Apache operations including the following:

• Major air emission sources;

• Treated produced water;

• Wastewater treatment plant effluent;

• Radioactivity; and

• Drilling mud toxicity (with respect to offshore concession areas).

3.2 RECORDS AND REPORTING

3.2.1 General Record Keeping and Reporting Apache should maintain records of significant environmental, health and safety matters. This information should be reviewed and evaluated to improve the effectiveness of the environmental health and safety program. Records will include:

• All incidents resulting in an incapacity to work for at least one full workday beyond the day on which the accident or illness occurred;

• The total number of days of absence from work as a result of the incident;

• Fatalities;

• Results obtained from the environmental monitoring protocol (see Table 3.1);

• Annual greenhouse gas (GHG) emissions modeling, or an update of the annual GHG emissions inventory;

• Environmental health and safety training carried out, including course topics and attendees;

• Occurrences of spills, fires and other emergency incidents;

• Number of emergency response drills and spill response drills carried out without equipment deployment; and

• Number of emergency response drills carried out with equipment deployment.


3.2.2 Environmental Effects Register Records of monitoring results should be maintained in an Environmental Register, as required under Egyptian Law 4 of 1994. The Model Register of Impacts of Establishment Activities on the Environment (Environmental Condition Register) is reproduced from the Executive Regulations of Law 4 below:

• Name and address of establishment;

• Name and job title of person in charge of completing the Register;

• Period covered by the register;

• Type of activity and nature of the raw materials and production during the corresponding time period;

• Laws governing the establishment;

• Special conditions set by EEAA for the establishment;

• Statement of the types of emissions, the rates of discharge and methods of disposal thereof (to include gases, liquids, solids and any other identified discharges);

• Frequency at which monitoring/testing of each emission source will be conducted (from the establishment);

• Details of random samples (including date/time/place of each sample, rate of sample collection and parameters to be monitored);

• Details of samples of compound wastes (including date/time/place of each sample, rate of sample collection and parameters to be monitored);

• Residual materials after waste treatment;

• Efficiency of treatment technology employed; and

• Date and signature of Facility Manager.

3.3 ENVIRONMENTAL MONITORING PROTOCOL The purpose of monitoring is to demonstrate substantive compliance of all Apache’s operations with Egyptian regulatory standards and with relevant World Bank/IFC guidelines. Monitoring data should be analyzed and reviewed at regular intervals and compared with specified requirements so that any necessary corrective actions can be taken. Records of monitoring results should be reported to the responsible authorities and relevant parties, as required.


Monitoring frequencies for required parameters are listed in this EMP. Where the EMP does not specify a monitoring frequency, the following frequencies should be used:

• At least once per month for effluents;

• Annually for air emissions, in addition to running a GHG estimation model annually; and

• As needed for noise, with a minimum frequency of annually. More frequent sampling, chemical analysis, and toxicity testing may be required during start-up and during any upset conditions. Ecologically important amphipods should be used as the sensitive species to assess sediment toxicity of drilling fluids and discharges where required. Any species selected should be indigenous to the region where drilling occurs. Table 3.1 presents the default monitoring requirements based primarily on EEAA and World Bank requirements. In some cases, there is limited EEAA guidance and default World Bank requirements seem particularly onerous for the prevailing conditions. For example, World Bank guidance specifies a default of daily monitoring for pH, BOD, TSS, Oil and Grease, Phenols, Sulfide and Temperature. Depending on the site specific conditions (e.g., type of waterbody into which discharge is occurring), less frequent measurements may be more appropriate (e.g., weekly, monthly). For example, default World Bank monitoring frequencies for inland water discharges may not be appropriate for Apache’s evaporation pits. For documentation purposes, the default Egyptian and World Bank frequencies are provided in the table below. Additionally, an Apache-proposed monitoring frequency is provided. It is recommended that Apache discuss the site-specific detail of monitoring requirements and the Apache-proposed monitoring frequency with EEAA in order to develop a set of practical and fit for purpose parameters and frequencies. Upon confirmation that the Egyptian authorities approve of less frequent sampling events, the protocol for the EMP can be modified as necessary.


TABLE 3.1 Monitoring Requirements for Apache's Operations in Egypt

Monitoring Requirement

Sites to be Monitored Monitoring Location Parameters to be Monitored

Default Frequency

Apache-Proposed

Frequency

Egyptian Standards Listed

in…

World Bank / IFC Standards

Listed in… Air Ambient air quality

All sites where residential camps or permanent offices are located.

Locations (3) on residential camp/office perimeter closest to emission sources.

NO2, SO2, CO, O3, PM10, TSP

Annually Annually Table 2.1 Table 2.13

Air emissions All sites where air emissions

sources are present Exhaust/Stack/ Vent/Chimney of all emission sources.

NOx, SOx, SO2, CO, TSP

Annually Annually Table 2.2 Table 2.14 Table 2.15

Water (1) Effluent Discharges (2)

All sites where sanitary drainage or produced water is discharged to soakaways/cess pits.

Point of discharge pH, BOD5, TSS, Oil & Grease, Phenols, Sulphide, Temperature.

Daily To be determined (5)

Dependent on MoH/EEAA requirements

Table 2.16

Effluent Discharges (3)

All sites where sanitary drainage or produced water is discharged to soakaways/cess pits.

Point of discharge Total Toxic Metals (4) Monthly To be determined (5)

Dependent on MoH/EEAA requirements

Table 2.16

(1) ERM understands that none of Apache's operations in Egypt discharge to inland waters. Standards, (and therefore monitoring requirements) for discharges to inland waters are included in Section 2.3.3. (2) Additional parameters may be required to be monitored depending on any conditions required by the MoH or EEAA. (3)Additional parameters may be required to be monitored depending on any conditions required by the MoH or EEAA. (4) Toxic metals include: antimony, arsenic, beryllium, cadmium, chromium, lead, mercury, nickel, selenium, silver, thallium, vanadium and zinc. (5) Default World Bank monitoring frequencies for effluent discharges to inland waters may not be appropriate for the types of water bodies to receive discharge from Apache’s operations. For example, less frequent monitoring (e.g., monthly or quarterly) may be appropriate for discharges to Apache’s evaporation pits. Apache will confer with the EEAA with respect to acceptable monitoring frequencies for each of the associated surface water bodies.




Default Frequency

Apache-Proposed

Frequency


in…


Listed in… Effluent Discharges

All sites where sanitary drainage or produced water is reused for irrigation purposes.

Point of discharge pH, BOD5, COD, TSS, Oil & Grease, Phenols, Sulphide, Chlorides, Temperature.

Daily To be determined (5)

Table 2.7

Table 2.16

Effluent Discharges

All sites where sanitary drainage or produced water is reused for irrigation purposes.

Point of discharge Total Solute Salts, %-age sodium absorption, nematode eggs, metals (B, Cd, Pb, Cu, Ni, Zn, As, Cr, Mo, Mn, Fe, Co, Hg, Se, Sb, Ag, Th, V, Be)

Monthly To be determined (5)

Table 2.7

Table 2.16

Effluent Discharges

Discharges to Marine Waters Point of discharge Dependent on specific marine discharge zone and EEAA approval

Monthly Monthly Table 2.8

Table 2.17

Drilling Fluids and Cuttings

Offshore Drilling Platforms Point of discharge Toxicity information required (LC50 of SPP-3% volume) – may require toxicity testing.

Prior to use of each new

fluid.

Prior to use of each new fluid

Dependent on EGPC and EEAA

requirements

Table 2.17




Default Frequency

Apache-Proposed

Frequency


in…


Listed in… Noise Ambient noise pressure levels

All operational sites where there are camps/offices

Locations (3) on residential camp/office perimeter closest to noise sources.

Maximum noise level (dB(A))

Monthly/as required.

Monthly/as required

Table 2.12

Table 2.18

Radiation Gamma, Beta and Alpha radiation

All NORM generation and storage areas

Point of NORM occurrence/NORM storage area

Bq/cm2 for gamma, alpha & beta Total level µSv/h Ra 226 Bq/g

Varies based on activity

level

Varies based on activity

level

See Section 4.7.3 ---


4.0 WASTE MANAGEMENT PLAN

4.1 INTRODUCTION

It is an Apache requirement to develop a Waste Management Plan (WMP). The WMP is required to address the following:

• Sources of waste or waste arisings;

• Disposal methods for the wastes generated; and

• Methods for reducing on-site disposal of solid and hazardous waste.

4.2 PURPOSE This Waste Management Plan is provided as a guidance document for identifying the appropriate waste disposal management practices for each type of waste generated by Apache’s operations in Egypt. This plan provides waste management guidance which:

• Meets Egyptian Regulatory requirements;

• Conforms with oil and gas industry standards and practices;

• Facilitates protection of the environment and regulatory compliance;

• Provides a basis for monitoring and evaluating Apache’s waste management practices;

• Provides a mechanism for recognizing improvement in waste minimization; and

• Is a basis for training of Apache’s personnel.

4.3 CONTEXT This plan is consistent with the American Petroleum Institute’s Environmental Guidance Document: “Waste Management in Exploration and Production Operations” (API E5). It is to be used for all of Apache’s onshore and offshore oil and gas production operations in Egypt. It is not intended to provide guidance on all waste handling issues, but is designed to cover the common wastes that are generated as part of Apache’s Egyptian operations. Simple and specific guidelines are given for each waste listed. Many of the waste streams are not currently covered by regulation. The waste management guidelines written in this plan consider the following criteria:

• Consistency with applicable national and international regulations;

• Compliance with Apache corporate policies;

• Consistency with international oil and gas industry practice;

• Acceptability, considering the sensitivities and capacity of the environment of the area in which the wastes are generated; and


• Minimizing future liability consistent with present economic constraints. Covered in these guidelines are:

• Waste Categories;

• Waste Minimization Definitions;

• Testing and Analysis Requirements - test protocols to determine if waste is “hazardous”; and

• Handling and Disposal Guidance - Specific and general guidance on when, how and/or where to dispose of the waste.

This Waste Management Plan functions as a “one-step reference” to handling, storage, labeling, and disposal of waste. Egypt is building a regulatory framework to improve management of waste. Not all of these regulations are currently enforceable. The country also does not currently have a hazardous waste disposal facility, although one is under development. This increases the need to be prudent in production practices in order to minimize the generation of hazardous waste.

4.4 WASTE MANAGEMENT DEFINITIONS Waste - Waste is any solid, liquid or gaseous material which is discharged to the environment or to the plant boundary, not as a product for sale. It is material that will require further treatment or in terms of a material balance would show up as a loss to the process. Waste is any unwanted substance or object which is disposed of, is intended to be disposed of, or is required to be disposed of by the provisions of national law. Decomposable Waste - Non hazardous solids and sludges which are biologically or chemically reactive in the natural environment, such as, paper, wood, household garbage, animal wastes and digested sewage sludge. Inert Waste – Concrete blocks, glass, brick, plastics, rubber products, scrap metal. Hazardous Waste - Materials classified as hazardous according to the Basel Convention 1989 (including subsequent revisions) Basel Convention on the Control of Transboundary Movement of Hazardous Waste, (http://www.basel.int); Special Wastes - Those wastes which do not fit into the hazardous, non-hazardous, decomposable, or inert waste categories or which have special waste disposal practices. Naturally occurring radioactive materials (NORM) waste and asbestos waste fall into this category. Low Toxicity Oil and Gas Waste - Describes most of the high-volume low-toxicity wastes generated in oil and gas drilling and production and includes produced water, drill cuttings, drilling fluids and all other materials from the wellbore associated with the production of oil and gas. This corresponds with


exempt oil and gas waste under the USEPA’s rules (Resource Conservation & Recovery Act). Pollution Prevention - The reduction in volume and/or toxicity of waste prior to discharge or disposal. It is primarily source reduction and recycling. Source Reduction (Minimization) - The reduction or elimination of waste at its source. Involves the evaluation of the facility and its processes, operating practices, raw materials and waste generating processes. Treatment - Any practice designed to alter the character or composition of a waste material so as to neutralize or render it non-hazardous. Treatment is divided into four categories:

• Thermal;

• Chemical;

• Biological; or

• Physical. Treatment may be further classified in accordance with Annex IV of the Basel Convention, (Basel Convention on the Control of Transboundary Movement of Hazardous Waste, (http://www.basel.int));

4.5 WASTE MANAGEMENT PRINCIPLES

4.5.1 The Waste Management Hierarchy The waste management hierarchy is illustrated in the figure on the right and gives preference first and foremost to waste avoidance and minimization (embodied in Apache policy). For unavoidable wastes it gives priority to reuse followed by recovery and recycling, finally it gives priority to treatment over disposal. Effective waste management begins with the selection and handling of materials so that waste is not generated in the first place. Techniques include ordering only what will be used, stock rotation, and proper labelling.


4.5.2 Application of Best Available Techniques (BAT) Apache will employ the best available techniques (BAT) for waste management. In determining ‘availability’, both affordability and local context will be considered. The Proximity Principle The proximity principle says that priority should be given to the management of wastes at source or as close to source as practicable; it can be illustrated in a similar hierarchical form as illustrated on the right. The proximity principle is also embodied in the Basel Convention on transboundary movement of waste which encourages signatory states to be as self sufficient as possible. The tracking of waste is also important, since this ensures that Apache follows its duty of care with respect to wastes generated.

4.6 WASTE STREAMS CURRENTLY GENERATED BY APACHE IN EGYPT The wastes typically generated by Apache’s Khalda Petroleum Company activities are listed in Table 4.1 which shows waste types, waste classifications and annual quantities. Figures for waste arisings from Apache’s Qarun Petroleum Company were not available at the time of the site visit. While it may be anticipated that similar wastes will be generated in similar proportions, Apache needs to generate a waste arisings inventory for its Qarun and (when appropriate) its Western Mediterranean Concession. This should be considered a priority action.


TABLE 4.1 Waste Arisings From Apache’s Operations in Egypt (Khalda Petroleum Company 2004)

Waste Stream Annual Quantity (kg)

Current Disposal Route

Plastics 14,930 Varied domestic wastes disposal routes Glass 4,560 Varied domestic wastes disposal routes Tins and scrap iron 62,940 Varied domestic wastes disposal routes Paper 27,650 Varied domestic wastes disposal routes Wood 10,900 Varied domestic wastes disposal routes Kitchen wastes 30,940 Varied domestic wastes disposal routes Garden wastes 33,640 Varied domestic wastes disposal routes Filters 2,600 units Desert disposal site Vehicle Tires 1,170 units Junk Yard (recycled periodically) Batteries 750 units Junk Yard (recycled periodically) Lubricants (vehicle maintenance) 2,300 API oil/water separator Lubricants (oil/gas plants) 690 API oil/water separator Fluorescent tubes 1,020 units Stored Cooking oil 970 units Desert disposal site Sewage 228,000 liters Irrigation of green areas/soakaway Produced Water 594,850 barrels Evaporation pits NORM Volumes not

known Stored in NORM & Hazardous Waste Storage Area

4.7 PROCEDURES FOR SPECIFICALLY DEALING WITH APACHE’S WASTE ARISINGS

4.7.1 Identification of New Waste Streams

All wastes generated by Apache’s operations need to categorized. If a waste is identified that is not included in this Waste Management Plan, the waste must be categorized according to the properties of the waste. Where the relevant properties are not known, these need to be determined in order to facilitate categorization. The EHS Department will be responsible for waste categorization. Some of the wastes generated by Apache have already been categorized. However, new waste streams generated as a result of process changes will need to be categorized. Correct categorization of a waste stream is important in order to ensure appropriate handling and disposal and to reduce waste management costs and potential for liability. Qualitative or quantitative measures may be employed to determine the waste category when:

• There is some doubt over the appropriate classification, and a less stringent classification will result in significant cost or resource savings;

• When the source and composition of the waste is not known; and

• When it is uncertain whether or not the waste needs to be segregated from other waste types.


In some instances it will be necessary to conduct laboratory testing.

4.7.2 Procedure for Selection of Waste Disposal Option This procedure endeavors to allow for all likely wastes produced by Apache’s operations in Egypt. However, it is not possible to cover all eventualities. Any doubts or concerns over the classification of a waste should be referred to the EHS Department. To apply this procedure, the following steps should be taken:

• Determine what waste is being generated for disposal;

• Refer to the Basel Convention for classification of hazardous waste streams and handling and disposal options for different hazardous waste streams;

• Ensure the material is correctly labeled;

• Use a transfer note in transferring the waste off-site;

• Notify EHS Department of all hazardous waste movements; and

• Maintain a Hazardous Wastes Register denoting generation, quantity, shipment and final disposal of all hazardous and special wastes.

4.7.3 Handling and Disposal Practices

Waste is produced by a number of Apache’s activities and, although a proportion can be reduced, reused or recycled, there will always be a proportion that requires offsite disposal. Waste minimization involves systematically reducing the waste at source. This can be achieved by a number of means, including redesigning production processes and changing work practices (such as inventory control). To prevent environmental pollution, the waste, as with the storage and handling of chemicals, must be stored and disposed of carefully. Since the composition of waste can vary widely, it is more efficient to segregate different waste streams. This helps quantify the different waste types as well as helping to reduce overall disposal costs. The preferred disposal method for each waste category is described in the following sub-sections. In each case, formal approval should be obtained (in writing) from the EGAS and EEAA for the disposal route proposed. Non-Hazardous Domestic Waste Recyclable materials, such as tins, drinks cans, plastic bottles and glass containers should be collected separately and opportunities for recycling investigated. If at any sites opportunities for incineration do not exist, then suitable arrangements for landfilling of wastes should be investigated.


All non-recyclable, non-hazardous domestic waste should be incinerated on site (Apache are currently providing waste incinerators at all sites where incinerators are not currently present or are present but not operational). Sewage All sewage should be subjected to at least primary treatment. If sewage is to be reused for irrigation purposes, it should meet the standards of Law 93 of 1962 as amended by Decree 44 of 2000, as described in Section 2.3.2 of this report. If sewage is to be reused for irrigation or discharged to soakaway, it should be ensured that this is approved by the appropriate authorities including EGAS, EEAA and Ministry of Health. Produced Water Produced water from the API gravity separators is currently either reinjected into the formation or discharged to evaporation ponds. From a waste management perspective, opportunities to reinject produced water should be maximized. Where water is to be discharged to unlined evaporation ponds, it should be ensured that this is approved by the appropriate authorities including EGAS, EEAA and Ministry of Health. Clinical Wastes Clinical wastes should be collected in sharps containers or appropriately labelled yellow bags. All clinical waste should be incinerated. On no account should clinical waste be deposited in any landfill or unsecure waste disposal site. Hazardous Wastes Hazardous wastes should be treated in an appropriate waste management facility. As few such facilities are currently operated in Egypt and available for disposal of Apache’s waste, wastes should be stored in the Hazardous Waste and NORM Storage Area. This storage area should be upgraded so that it is secure, located on hardstanding, and covered with a roof. Normally Occurring Radioactive Materials (NORM) Waste NORM waste is classified according to Egyptian Atomic Energy Authority’s (AEA) Radiation Protection Requirements for Handling of NORM in the Petroleum Industries (2000) and is categorized as follows: Category A: Where the radiation levels exceed 7.5 µSv/h and specific activity of Ra-226 exceeds 2 Bq/gm, NORM requires the following:

• Supervision by an AEA qualified NORM experts;

• Assignments of restricted areas;


• Detailed radiation survey every 3 months;

• Determination of specific activity of Ra-226 in NORM wastes;

• Radiation measuring instruments;

• Radiation personal dosimeter; and

• Cleaning of equipment or land from radioactive contamination by technical services licensed from AEA.

Category B: Where the radiation levels are between 2.5-7.5 µSv/h and specific activity of Ra-226 exceeds 2 Bq/gm, NORM requires the following:

• Supervision by an AEA qualified NORM expert;

• Detailed radiation survey every 6 months;


• Radiation measuring instruments; and


Category C: Where the radiation levels are between 0.5-2.5 µSv/h while the specific activity of Ra-226 exceeds 2 Bq/gm, NORM requires the following:

• Supervision by an AEA qualified NORM expert;

• Detailed radiation survey every one year;


• Radiation measuring instruments; and


Category D: Where the radiation level is less than 0.5 uSv/h and the specific activity of Ra-226 is less than 2 Bq/gm, NORM requires the following:

• Disposal can be done as a non- radioactive waste.

• Radiation survey every 2 years. According to the National Laws and regulations, it is prohibited to dispose or release any radioactive waste or contaminated materials without authorization from the Egyptian AEA. If NORM has been identified, the waste should be treated by one of the following options: Liquid Wastes: Liquid wastes include wash and rinse water from decontamination and cleaning activities, produced water and any other NORM contaminated liquid of a similar nature. Disposal options include:

• Option 1 - To inject into plugged or abandoned wells below the level of the water table.


• Option 2 - If Option 1 is not available, to be discharged into the sea (as long as the discharge will be compliant with Environmental Law No. 4/1994 (note that the IFC guidelines listed in Table 2.17 also apply).

• Option 3 - If Options 1 and 2 are not available, to be discharged into isolated and lined evaporation ponds.

Solid Wastes: Solid production wastes include soil, scales, sands, paraffins and other similar wastes:

• Option 1 - To be clarified and injected into plugged or abandoned wells below the level of the water table.

• Option 2 - If Option 1 is not available, the waste should be contained in durable containers and stored in a specially assigned yard for NORM wastes.

• Option 3 - Final disposal to be carried out AEA. Contaminated Equipment: Contaminated equipment should be stored in a NORM store yard after capping all openings, to avoid the leakage of the contaminants.

• Contaminated equipment may be re-used on site (as it is) as long as the equipment meets technical requirements.

• If equipment is not reused, it should be decontaminated to less than 0.4 Bq/cm for alpha emitters or 4 Bq/cm for beta and gamma emitters, before any release from Apache’s custody.

• Any radioactive materials removed during decontamination should be treated as described above.

4.8 DOCUMENTATION OF WASTE TRANSFER AND DISPOSAL

4.8.1 Movement of Waste Within Egypt

Apache need to develop a system of waste transfer notes to track waste transfer and disposal and to ensure all waste is classified, properly handled, and properly disposed. The Apache EHS Department should be advised of all waste shipments so that a register of production/shipment/disposal of waste can be maintained. This is essential for general control of waste disposal and also to allow accurate reporting, when necessary, to the regulatory bodies. Any hazardous waste will be identified on the manifest with its primary hazard and secondary hazard listed. If a material is both flammable and a poison, both hazards should be in the description and underlined so that the warning stands out (e.g. Flammable, Poison).


The following hazard descriptions should be used: Corrosive - acids, bases, and anything that causes visible destruction or irreversible alterations in human skin tissue or that has a severe corrosion rate on steel. Oxidizer - substances such as chlorate, permanganate, peroxide, or a nitrate, that yields oxygen readily to the environment. Poison - Poisonous gases or liquids of such a nature that a very small amount of the gas or vapor of the liquid mixed with air is dangerous to life. Examples include hydrogen sulphide or hydrogen cyanide. Flammable - describes a flammable liquid or gas or semi-solid or solid which has a flash point below 600C (1400F). Medical Waste - includes sharps (needles, syringes, scalpels), bandages and any other material which is contaminated with blood or other bodily fluids. Generally this waste stream will be generated from the medics clinic. Radioactive Waste - waste that displays an activity greater than 70 Bq/gram (U.N. Class7). Irritant - liquid or solid which, upon contact with fire or when exposed to air, gives off dangerous or intensely irritating fumes but is not listed as a poison.

4.8.2 Export of Waste Wastes generated by Apache for which no waste management option currently exists in Egypt will be stored pending development of an appropriate management solution within Egypt, or will be exported for reprocessing or appropriate treatment in another country. In the case of wastes which are exported, Apache shall comply with all provisions of the Basel Convention On The Control Of Transboundary Movements Of Hazardous Wastes And Their Disposal (1989). This Convention, inter alia, specifies a particular manifest system for transboundary shipment of waste.

4.8.3 Training All personnel will receive waste management training and all production staff will receive specific instruction in the application of this procedure.

4.8.4 Internet Resources Further information on waste management may be gained from the following internet sites:

• American Petroleum Institute, (http://api-ep.api.org);


• Basel Convention on the Control of Transboundary Movement of Hazardous Waste, (http://www.basel.int);

• “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,'' EPA Publication SW 846, (http://www.epa.gov); and

• European Waste List (2001/118/EC - Commission Decision of 16 January 2001 amending Decision 2000/532/EC as regards the list of wastes), (http://europa.eu.int/eur-lex/pri/en/oj/dat/2001/l_203/l_20320010728en00180019.pdf).

4.8.5 Testing and Analysis

Testing of waste is an area where specific test methods and protocols are to be followed. The following are some commonly used tests to help classify waste:

• EPA Method 418.1 - used to test for Total Petroleum Hydrocarbons (TPH) (freon extraction);

• EPA Method 413.1 - used to test for oil and grease in water discharges (freon extraction);

• EPA Method 1664 - a new test for oil and grease or TPH in water discharges (hexane extraction); and

• TCLP (EPA Method 1311) - is a series of tests which measures the leachability of heavy metals and other priority pollutants in a substance. This is an expensive test which can be reduced in scope if the probable contents are known. TCLP is the Toxicity Characteristic Leaching Procedure. The test is designed to simulate the concentration of hazardous materials capable of leaching from a waste (placed in a landfill and subjected to natural acidification) into ground water. The TCLP (Method 1311) is published in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,'' EPA Publication SW 846. (See Appendix 7 for a detailed list of chemicals and the limits at which they are considered to be “hazardous”.)

4.8.6 Storage

Chemicals and waste for storage should be kept in secure, closed containers. If doubt exists as to the integrity of the container, it must be placed in a chemical overdrum. All containers and drums will be stored on pallets in the NORM and Hazardous Waste Storage Area. The NORM and Hazardous Waste Storage Area should be signposted as a storage area designated exclusively for hazardous wastes and access to the area strictly controlled. Drums / containers of volatile wastes should be stored out of direct sunlight, preferably in a ventilated ISO container, to minimize risk of over-pressurization leading to leaks or catastrophic failure.


All unidentified chemicals will be treated as hazardous waste and stored accordingly (i.e., in the NORM and Hazardous Waste Storage Area) until their composition and disposal mechanism have been determined.

4.8.7 Waste Disposal Contractors Wastes generated by Apache shall only be transferred to waste disposal contractors which are approved by EHS, and then only if those waste management contractors hold all relevant permits, and providing those permits are ‘current’. The EHS Department will maintain an ‘Approved Waste Management Contractor List’ and, in the case of contractors accepting hazardous wastes, these shall be pre-audited before being accepted onto the list. Waste management contractors and facilities accepting Apache generated wastes will be periodically audited to ensure compliance with Apache’s duty of care.

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5.0 COMPLIANCE ASSURANCE FOR EMP AND WMP This section describes compliance assurance tools developed to aid in implementation of the EMP and WMP for Apache’s operations in Egypt. The compliance assurance tools are designed to meet three primary objectives:

• Make the requirements in the EMP and WMP easily “implementable” - The EMP and WMP summarize the basis for the plans, and provide a comprehensive discussion of the plan requirements. The compliance assurance tools are intended to present these requirements in a concise, organized manner that allows field personnel and management personnel to easily identify applicable requirements and to verify their completion.

• Satisfy the requirements of Apache’s environmental management system (EMS) - Fundamentally, an EMS requires a cycle of plan-do-check-review. The WMP and EMP are intended to satisfy “plan” requirements within the scope of their coverage. The compliance assurance tools provide a framework for satisfying the “do” and “check” portions of the EMS cycle.

• Offer supervisors and management a systematic process to know that required tasks have been identified and are being completed – The activities required by the EMP and WMP typically will be completed in the field by operators or technicians. The compliance assurance tools offer management a way to verify that these compliance activities are being performed in a time-efficient manner.

5.1 DESCRIPTION OF COMPLIANCE ASSURANCE TOOLS

The compliance assurance tools provided herein include the following:

• Requirements Registers - a summary of requirements included in the EMP and WMP. The requirements registers are designed to:

− Explicitly capture all requirements and commitments specified in the plans;

− Identify, where applicable, the specific emission sources or locations affected by the requirement;

− Specify parameters to be monitored or records to be kept;

− Specify frequency of monitoring requirements;

− Identify the location of required records in such a way that anyone with site familiarity could easily locate them;

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− Identify the person(s) or title(s) of the person(s) responsible for satisfying the requirement. This refers to the actual person who will do the monitoring, manage the recordkeeping or waste, or otherwise take the action necessary to meet the requirement;

− Identify the person or title of the person who is accountable for the requirement being met. Typically, this will be a manager in the organization; and

− Specify the frequency at which the accountable person should perform a check task (see below) to ensure that compliance activities are being completed as specified in the plans.

• Management Check Tasks - check lists developed to assist management with performing identified check tasks. The accountable person should perform (or may elect to delegate to someone to perform) the check tasks at the specified frequencies. It is important to note that the specified frequencies may change over time. The frequencies should be set based on a formal or informal risk ranking. If non-conformance with a required task occurs frequently, the frequency of management check tasks should be greater than for those compliance requirements for which non-conformance rarely occurs.

• Environmental Effects Register - the EMP requires certain information to be collected in an Environmental Effects Register. A template for the Environmental Effects Register is included herein.

Appendix A contains the above-referenced compliance assurance tools for Apache’s Operations in Egypt.

G:\2005\0026719\6999Hrpt.doc

Compliance Assurance Tools Appendix A

May 17, 2005

Project No. 0026719

Environmental Resources Management 15810 Park Ten Place, Suite 300

Houston, Texas 77084-5140 (281) 600-1000

Requirements RegisterEnvironmental Monitoring Plan

Apache Egypt Operations

Monitoring Requirements Affected Emission Source/Outfall/Location Parameters to be Monitored Frequency Responsibility Management

Responsibility*Management Check

Frequency

Air

For all sites where residential camps or permanent offices are located, monitor ambient air quality at three (3) locations on residential camp/office perimeter closest to emission sources.

Identify the specific affected sites NO2, SO2, CO, O3, PM10, TSP AnnuallySpecific name or title of the person who is responsible for monitoring

Specific name or title of the supervisor or manager who is accountable for monitoring

Annually

For all sites where air emissions sources are present, monitor air emissions from the Exhaust/Stack/ Vent/Chimney of all emission sources.

Identify the affected emission sources

NOx, SOx, SO2, CO, TSP AnnuallySpecific name or title of the person who is responsible for monitoring

Specific name or title of the supervisor or manager who is accountable for monitoring

Annually

Water

For all sites where sanitary drainage or produced water is discharged to soakaways/cess pits, monitor effluent discharges at the point of discharge.

Identify affected outfalls Total toxic metals a To be determined To be determined

For all sites where sanitary drainage or produced water is reused for irrigation purposes, monitor effluent discharges at the point of discharge.

Identify affected outfallspH, BOD5, COD, TSS, Oil & Grease, Phenols, Sulphide, Chloride, Temperature.

To be determined To be determined

For all sites where sanitary drainage or produced water is reused for irrigation purposes, monitor effluent discharges at the point of discharge. Identify affected outfalls

Total Solute Salts, %-age sodium absorption, nematode eggs, metals (B, Cd, Pb, Cu, Ni, Zn, As, Cr, Mo Mn, Fe, Co, g, Se, Sb, Ag, Th, V, Be)

To be determined To be determined

For all discharges to marine waters, monitor effluent at the point of discharge. Identify affected outfalls Dependent on specific marine discharge zone and EEAA approval To be determined To be determined

Prior to the use of each new drilling fluid, ensure that proper toxicity information (LC50 of SPP-3% volume) is on record, and that toxicity testing is performed if required.

Reference Management of Change procedures as mechanism to identify triggering events

Toxicity information required (LC50 of SPP-3% volume) – may require toxicity testing.

On Event Semi-Annually

NoiseFor all operational sites where there are camps/offices, monitor ambient noise pressure levels at three (3) locations on residential camp/office perimeter closest to noise sources.

Identify the specific affected sites Maximum noise level (dB(A)) Monthly/as required. Semi-Annually

Radiation

Bq/cm2 for gamma, alpha & beta

Total level µSv/h

Ra 226 Bq/g

To be determinedTo be determined

For all NORM generation and storage areas, monitor Gamma, Beta and Alpha radiation at the point of NORM occurrence/NORM storage area.

Identify locations of all NORM generation and storage areas

Varies based on activity level

For all sites where sanitary drainage or produced water is discharged to soakaways/cess pits, monitor effluent discharges at the point of discharge.

Identify affected outfallspH, BOD5, TSS, Oil & Grease, Phenols, Sulphide, Temperature.

Semi-Annually

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Requirements RegisterEnvironmental Monitoring Plan

Apache Egypt Operations

Responsibility Management Responsibility

Management Check Frequency

Specific name or title of the person who is responsible for recordkeeping

Specific name or title of the supervisor or manager who is accountable for recordkeeping

Semi-Annually

Semi-Annually

Semi-Annually and upon submittal of fatality report

Semi-Annually

Annually

Semi-Annually

Semi-Annually

Annually

Annually

Annually

*Note: The management check frequency is the frequency at which a supervisor or manager should review compliance with a requirement to ensure that it is being met.

The check frequency should be risk based; over time, frequencies can be increased if there have not been instances of non-conformance, or decreased if there

have been many instances of non-conformance.

number of emergency response drills and spill response drills carried out without equipment deployment; and

number of emergency response drills carried out with equipment deployment.

Records of monitoring results should be maintained in an Environmental Register , as required under Egyptian Law 4 of 1994.

Recordkeeping Requirements

Keep records of:

results obtained from the environmental monitoring protocol;

annual greenhouse gas (GHG) emissions modeling, or an update of the annual GHG emissions inventory;

environmental health and safety training carried out, including course topics and attendees;

occurrences of spills, fires and other emergency incidents;

all incidents resulting in an incapacity to work for at least one full workday beyond the day on which the accident or illness occurred;

the total number of days of absence from work as a result of the incident;

fatalities;

Specify the location of the physical or electronic record with enough detail that anyone familiar with the site could easily locate it.

Location of Record

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Management Check TasksSampling Week/Month/Quarter/Year:Field:

Effluent Discharges to Soakways/Cess Pits

Parameter Outfall Result Limit Monitoring Date Method or Protocol Used

pHMethod: (enter required method

and/or reference protocol)

BOD5Method: (enter required method


TSSMethod: (enter required method


Oil & Grease Method: (enter required method


PhenolsMethod: (enter required method


SulphideMethod: (enter required method


TemperatureMethod: (enter required method


AntimonyMethod:

ArsenicMethod:

BerylliumMethod:

CadmiumMethod:

ChromiumMethod:

LeadMethod:

Review lab results and/or interview tester to identify method and/or protocol that was used in performing test.

Enter names or descriptions of affected outfalls

Enter test result as check that test was performed.

Enter regulatory limit to compare with test result.

Enter date monitoring was performed to confirm that it was done within specified frequency.

MercuryMethod:

NickelMethod:

SeleniumMethod:

SilverMethod:

ThalliumMethod:

VanadiumMethod:

ZincMethod:

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Effluent Discharges to Irrigation Reuse

Parameter Outfall Result Limit Monitoring Date Method or Protocol Used

Total Solute SaltsMethod: (enter required method and/or reference

protocol)

%-age Sodium AbsorptionMethod:

Nematode EggsMethod:


BOD5Method: (enter required method


CODMethod: (enter required method


TSSMethod: (enter required method






pHMethod: (enter required method


Oil & Grease Method: (enter required method


PhenolsMethod: (enter required method


SulphideMethod: (enter required method


ChloridesMethod: (enter required method


TemperatureMethod: (enter required method


CadmiumMethod:

LeadMethod:

BoronMethod:

CopperMethod:

NickelMethod:

ZincMethod:

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ArsenicMethod:

ChromiumMethod:

MolybdenumMethod:

ManganeseMethod:

IronMethod:

CobaltMethod:

MercuryMethod:

SeleniumMethod:

AntimonyMethod:

SilverMethod:

ThalliumMethod:

VanadiumMethod:

BerylliumMethod:

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Effluent Discharges to Marine WatersParameter Outfall Result Limit Monitoring Date Method or

Protocol Used

Ambient Noise Pressure LevelsParameter Location Result Limit Monitoring Date

Method or Protocol Used

Parameter 1Method: (enter required method

























Maximum noise level (dB(A))

Method: (enter required method and/or reference protocol)

Enter names or descriptions of monitoring locations





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Gamma, Beta and Alpha RadiationParameter Outfall Result Limit Monitoring Date Method or

Protocol Used

Toxicity Testing

Ambient Air Quality

Parameter Location Result Limit Monitoring DateMethod and/or Protocol Used

Enter names or descriptions of monitoring locations.





NO2

Method:



Total level uSv/hMethod: (enter required method


Ra 226 Bq/gMethod: (enter required method


Review Management of change procedures to ensure that toxicity testing was not required for previous 6 month period.

Bq/cm2 for gamma, alpha, beta

Method: (enter required method and/or reference protocol)

Enter names or descriptions of NORM storage areas



SO2Method:

COMethod:

O3Method:

PM10Method:

TSPMethod:

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Air Emissions

Parameter Stack Result Limit Monitoring DateMethod and/or Protocol Used

Recordkeeping Checks

Location Specified in Requirements

Register Actual Location

environmental health and safety training carried out, including course topics occurrences of spills, fires and other emergency incidents;

all incidents resulting in an incapacity to work for at least one full workday the total number of days absence from work as a result of the incident;fatalities;results obtained from the environmental monitoring protocol;

NOXMethod:

SOXMethod:

SO2Method:

COMethod:

TSPMethod:

Records of monitoring results should be maintained in an Environmental

Have records been kept for: annual greenhouse gas (GHG) emissions modeling, or an update of the number of emergency response drills and spill response drills carried out number of emergency response drills carried out with equipment

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Environmental Effects Register

Location Name:Address:

Completed By:Title:

Register DatesFrom:

To:Description of Site Activity:

Raw Materials Utilized Description

Emissions

Type of Emissions/DischargeDischarge

Rate Disposal Method

Physical State

(gas,liquid, solid)

Monitoring/ Testing

FrequencyLiquids

Gases

Solids (examples provided)

The laws governing this site and the special conditions set by EEAA are summarized in reference separate document.

PlasticsGlass

Produced water

Tins and Scrap Iron

NO2

NOX

SO2

SOX

PM10

TSPCOO3

PaperWood

Kitchen WastesGarden Wastes

NORM

FiltersVehicle Tyres

BatteriesLubricants (vehicle maintenance)

Lubricants (oil/gas plants)Fluorescent Tubes

Cooking OilSewage

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Random/Compound Waste Sampling

Sampling Location Sampling Scheme Date TimeRate of Sample

CollectionParameters to be

Monitored

Waste Treatment

Type of Waste Quantity Treatment MethodResidual Waste

Qty. Efficiency of Technology

Facility Mgr. Signature: Date:

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Hazardous Waste Storage Area Monthly Management Check ListPerformed By:Date:

Requirement Check Observation Corrective Action Responsibility Closure Date

Hazardous wastes should be stored in the Hazardous Waste and NORM Storage Area . Treat all unidentified chemicals as hazardous waste and stored according to the requirements for hazardous wastes.

Upgrade storage area so that it is secure, located on hardstanding, and covered with a roof.

Observe hazardous waste storage area to ensure that it is locked and located on hardstanding. Note any compromises to roof integrity.

Store chemicals and waste for storage in secure, closed containers.

Ensure that chemicals and waste containers are not compromised (leaking, dented, overfilled, etc.), and that all containers are closed.

If container integrity is potentially compromised, place in a chemical overdrum.

Observe compromised drums to ensure they are placed in a chemical overdrum

Store all containers and drums in the NORM and Hazardous Waste Storage Area on pallets. Ensure that all containers are stored on pallets.Signpost the NORM and Hazardous Waste Storage Area as a storage area designated exclusively for hazardous wastes. Confirm that signs are posted.

Control access to the NORM and Hazardous Waste Storage Area.

Confirm that hazardous waste and NORM storage area gate/door is locked upon entry.

Store drums / containers of volatile wastes out of direct sunlight, preferably in a ventilated ISO container.

Observe drums of volatile wastes to ensure that they are out of direct sunlight.

Note: when performing the monthly check tasks, refer to the previous months results to ensure that corrective actions have been taken and that observed non-compliance has been resolved.

Inspect non-hazardous waste storage areas and areas where hazardous chemicals are commonly used for presence of stored hazardous wastes or unidentified wastes.

Date that observed non-compliance was corrected.

Name or title of person responsible for implementing corrective action.

Response required (if any) to resolve observed non-compliance.

To be completed by person performing check.

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Waste Management Semi-Annual Management Check ListPerformed By:Date:


ensure the material is correctly labeled;Inspect wastes that are prepared for disposal to ensure that the labeling is complete and accurate.

use a transfer note in transferring the waste off-site;

Interview the individuals responsible for transferring custody of waste to an off-site carrier to ensure that they use a waste transfer note in each instance. Review records of waste transfer notes to see if they are being prepared routinely.

maintain a Hazardous Wastes Register denoting generation, quantity, shipment and final disposal of all hazardous and special wastes.

Ensure that a hazardous wastes register exists, and that it is being filled out by those responsible for transferring custody of wastes. Compare hazardous waste register entry to waste transfer notes to see if shipment records match.

Segregate individual waste streams.

Interview the individuals responsible for collecting and segregating wastes to see if they follow specified procedures. Inspect hazardous and non-hazardous waste collection areas to verify that wastes are segregated.

Note: when performing the check tasks, refer to the previous months results to ensure that corrective actions have been taken and that observed non-compliance has been resolved.

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Requirement Check Observation Corrective Action Responsibility Closure DateCollect clinical wastes in sharps containers or appropriately labeled yellow bags.

Inspect clinical waste collection areas to ensure that they are stored in labeled yellow bags.

Incinerate all clinical wastes.

Review clinical waste disposal records to verify that clinical wastes are incinerated. Interview personnel responsible for disposal of clinical wastes to ensure that appropriate procedures are followed.

Treat hazardous wastes in an appropriate waste management facility.

Only transfer waste to waste disposal contractors which are on the ‘Approved Waste Management Contractor List’.

Advise Apache EHS Department of all waste shipments.

Compare waste manifests and transfer notes to EHS Department records of notification. Interview waste disposal personnel to see that notification of EHS is routinely made for all waste shipments, and that they notify appropriate EHS personnel using specified communication methods.

Identify any hazardous waste on the manifest with its primary hazard and secondary hazard listed.

Inspect a selection of hazardous waste manifests to ensure that the correct primary and secondary hazards have been listed.

Review waste manifest final disposition records to ensure that the waste management facility meets Apache's standards, and that the waste disposal contractor is listed on the ‘Approved Waste Management Contractor List’. Ensure that waste management personnel are using the most up-to-date contractor list.

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NORM Waste Management Semi-Annual Management Check ListPerformed By:Date:


Categorize all NORM waste.Review the list of generated NORM wastes to see that all were categorized according to the NORM procedures.

NORM waste categorized as Category A, Where the radiation levels exceed 7.5 µSv/h and specific activity of Ra-226 exceeds 2 Bq/gm, NORM requires the following:

Ensure that documentation is in place to demonstrate that category A wastes are accurately categorized.

· Supervision by an AEA qualified NORM experts;

Review qualification documentation for supervising NORM experts.

· Assignments of restricted areas; Inspect NORM storage area to ensure that signage is in place and area is securely restricted.

· Detailed radiation survey every 3 months;Review files to ensure that a radiation survey was performed every 3 months, and that the surveys are documented.

· Determination of specific activity of Ra-226 in NORM wastes;

Review documentation to ensure that specific activity of Ra-226 has been determined and documented according to appropriate procedures.

· Radiation measuring instruments; Ensure that radiation measuring instruments are available and in working order.

· Radiation personal dosimeter; andInterview staff responsible for managing NORM waste to verify that they wear personal dosimeters.

· Cleaning of equipment or land from radioactive contamination by technical services licensed from AEA.

Review records of cleaning to ensure that technical service providers are licensed by AEA.

NORM waste categorized as category B, Where the radiation levels are between 2.5-7.5 µSv/h and specific activity of Ra-226 exceeds 2 Bq/gm, NORM requires the following:

Ensure that documentation is in place to demonstrate that Category B wastes are accurately categorized.

· Supervision by an AEA qualified NORM expert;


· Detailed radiation survey every 6 months;Review files to ensure that a radiation survey was performed in the last 6 months, and that the surveys are documented.




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· Radiation measuring instruments; and Ensure that radiation measuring instruments are available and in working order.



NORM waste categorized as category C, Where the radiation levels are between 0.5-2.5 µSv/h while the specific activity of Ra-226 exceeds 2 Bq/gm, NORM requires the following:

Ensure that documentation is in place to demonstrate that Category C wastes are accurately categorized.

· Supervision by an AEA qualified NORM expert;


· Detailed radiation survey every one year;Review files to ensure that a radiation survey was performed in the last year, and that the surveys are documented.



· Radiation measuring instruments; and Ensure that radiation measuring instruments are available and in working order.



NORM waste categorized as category D, Where the radiation level is less than 0.5 uSv/h and the specific activity of Ra-226 is less than 2 Bq/gm, NORM requires the following:

Ensure that documentation is in place to demonstrate that Category D wastes are accurately categorized.

· Radiation survey every 2 years.Review files to ensure that a radiation survey was performed in the last 2 years, and that the surveys are documented.

Obtain authorization from AEA before disposing or releasing any radioactive waste or contaminated materials.

Review NORM disposal records. Check files to ensure that authorization was obtained.

If NORM has been identified, the waste should be treated by one of the following options: None

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Requirement Check Observation Corrective Action Responsibility Closure DateLiquid Wastes: Liquid wastes must be disposed by one of the following methods· Option 1 - To inject into plugged or abandoned wells below the level of the water table.· Option 2 - If Option 1 is not available, to be discharged into the sea (as long as the discharge will be compliant with Environmental Law No. 4/1994.· Option 3 - If Options 1 and 2 are not available, to be discharged into isolated and lined evaporation ponds.Solid Wastes: solid wastes must be disposed by one of the following method· Option 1 - To be clarified and injected into plugged or abandoned wells below the level of the water table.· Option 2 - If Option 1 is not available, the waste should be contained in durable containers and stored in a specially assigned yard for NORM wastes.Option 3 - Final disposal to be carried out AEA

Store NORM contaminated equipment in a NORM store yard.

Inspect all waste storage areas. Ensure that no NORM wastes are stored in areas other than the NORM store yard.

Cap all openings of NORM-contaminated equipment.

Inspect NORM contaminated equipment in store yard. Ensure that all openings have been capped.

Decontaminate equipment to less than 0.4 Bq/cm for alpha emitters or 4 Bq/cm for beta and gamma emitters before releasing from Apache ’s custody.

Review documentation for NORM waste that was released from Apache. Locate associated documentation verifying that equipment was decontaminated to the specified standards.

Treat radioactive materials removed during decontamination as described above.

Interview staff responsible for managing NORM waste to verify that radioactive materials were treated according to specified procedures.

Review NORM disposal records. For each instance of liquid waste disposal, ensure that one of the three available options was selected. Interview waste management staff to confirm that appropriate procedures were followed.

Review NORM disposal records. For each instance of solid waste disposal, ensure that one of the three available options was selected. Interview waste management staff to confirm that appropriate procedures were followed.

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Waste Management Annual Management Check ListPerformed By:Date:


Categorize all wastes.

Review the list of generated wastes to see that all have been categorized. Review the MOC documentation for the previous year to identify changes that may have led to the generation of a new waste stream; ensure that any new waste streams have been identified and categorized.

To be completed by person performing check.

Response required (if any) to resolve observed non-compliance.

Name or title of person responsible for implementing corrective action.

Date that observed non-compliance was corrected.

Obtain formal written approval from EGAS and EEAA for proposed waste disposal routes.

Review waste disposal records to ensure that all disposal routes used in the last year had written approval.

Collect recyclable materials separately.

Inspect waste storage areas to ensure that recyclable materials are segregated. Ask waste management personnel to explain the process for segregating recyclable materials. Inspect point-of-generation waste disposal areas to ensure that segregated containers for recyclable materials are available and clearly labeled.

Investigate opportunities for recycling. Review list of wastes generated to evaluate whether recycling opportunities for specific non-recycled waste streams may exist.

Incinerate non-recyclable non-hazardous domestic wastes on-site if facilities are available.

For sites where incineration is available, interview waste management personnel to verify that they follow specified procedures. Inspect waste management areas to ensure that the appropriate waste streams are clearly identified for incineration.

Landfill non-recyclable non-hazardous domestic wastes on-site if incineration facilities are not available.

For sites where incineration is not available, interview waste management personnel to verify that they follow specified procedures for landfilling wastes. Inspect waste management areas to ensure that the appropriate waste streams are clearly identified for landfilling.

Reused sewage for irrigation purposes should meet the standards of Law 93 of 1962 Obtain approval for reused sewage from EGAS, EEAA and Ministry of Health.

Obtain approval for water discharged to unlined evaporation ponds from EGAS, EEAA and Ministry of Health.

If water is discharged to unlined evaporation ponds, ensure that approvals are on file.


If sewage has been reused for irrigation purposes, review test data to ensure that it meets the standards of Law 93. Check files to ensure that necessary approvals were obtained.

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Requirement Check Observation Corrective Action Responsibility Closure DateStore or export for reprocessing or treatment in another country, wastes for which no waste management option currently exists in Egypt.

Interview waste management personnel to ensure that procedure is followed.

Provide waste management training for all personnel.

Review personnel training matrix to ensure that all personnel received waste management training within last year (example time frame) .

Follow appropriate specific test methods and protocols when testing waste.

Insert specific methods used for each type of waste. Examples may be:

· Ensure EPA Method 418.1 is used to test Total Petroleum Hydrocarbons (TPH) (freon extraction)

· Ensure that EPA Method 413.1 is used to test for oil and grease in water discharges (freon extraction)

· Ensure that EPA Method 1664 is used to test for oil and grease or TPH in water discharges (hexane extraction)

Ensure that all contractors on the 'Approved Waste Management Contractor List’ have been pre-audited.

Review files of waste management contractor audits and compare to approved contractors list. Identify any contractors on the list that have not been audited.

Periodically audit contractors and facilities accepting Apache- generated wastes.

Identify contractors that have not been audited for 3 or more years (example time frame) .

Review documentation for 10% of wastes tested over the last year. Ensure that the proper test method was used to analyze the sample.

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