Environmental Monitoring Report - TotalEnergies

M5 M6 Block

7 August 2019

Environmental Monitoring Report of Existing

Yadana Facilities

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TABLE OF CONTENTS

1. Executive Summary ................................................................................................................ 3

2. Introduction ............................................................................................................................ 4

3. Description of the Yadana Project and Environmental Management ................................... 4

3.1 Yadana Onshore Activities ............................................................................................... 5

3.2 Offshore Facilities and Activities ..................................................................................... 7

3.3 TEPM Environmental Management System .................................................................... 9

4. Applicable Regulations Related to the Project ..................................................................... 10

4.1 Compliance with Guidelines .......................................................................................... 14

5. Monitoring Activities in Offshore and Onshore ................................................................... 14

Verification Audit ................................................................................................................. 29

7. Conclusions ........................................................................................................................... 30

8. Appendixes ........................................................................................................................... 31

Appendix 1. Sample Noise Map in Offshore ....................................................................... 31

Appendix 2. Sample of PLC Sewage system ........................................................................ 32

Appendix 3. Internal and External Audit reports ................................................................ 33

Table of Figures

Figure 1 Overview of Yadana Existing Facilities......................................................................... 5

Figure 2: Location of Taninthayi Nature Reserve ...................................................................... 6

Figure 3: Simplified Onshore Process ........................................................................................ 7

Figure 4: Yadana Offshore Complex .......................................................................................... 8

Figure 5: Simplified Offshore Process........................................................................................ 9

Figure 6: Test Result of Cutting Discharge .............................................................................. 16

Figure 7: Laboratory Result of Produced Sand ........................................................................ 18

Figure 8: Sample results of sewage water from Yangon Head Office ..................................... 28

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Acronyms and Abbreviations

ADB Asia Development Bank

CSR Corporate Social Responsibility

EBS Environmental Baseline Study

ECD Environmental Conservation Department

EIA Environmental Impact Assessment

EMP Environmental Management Plan

ESIA Environment and Societal Impact Assessment

IEE Initial Environmental Assessment

IFC International Finance Corporation

MOGE Myanma Oil and Gas Enterprise

OSCP Oil Spill Contingency Plan

RSES Responsible Safety Environment on Site

TEPM Total Exploration and Production Myanmar

1. Executive Summary

In line with the government’s environmental regulation, Total Exploration and

Production Myanmar (TEPM) was instructed to submit a six monthly environmental

monitoring report after receiving the approval of an EMP report of Yadana existing

facilities in October 2018. Therefore, this report is produced based on the available

information and the current practices of TEPM’s environmental management system.

In order to get the general understanding of offshore and onshore operations, the

simplified process of both offshore and onshore are elucidated and the current

environmental management system of TEPM is also briefly explained. The applicable

regulations related to Yadana project are described.

The monitoring program is totally implemented based on the monitoring measures

elaborated in the EMP report of Yadana existing facilities. The explanation and

justification of these monitoring measures like produced water, produced sand for

offshore and noise and storm water drainage for onshore parts are discussed. In

conclusion, the difference of TEPM’s current industrial practices and the requirements

imposed by ECD is discussed. There are also some commitments made for the next

six monthly environmental monitoring report to be submitted after receiving the

feedback or comments from ECD.

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2. Introduction

Total EP Myanmar has been operated Yadana project since 1993. The first export gas

was delivered to Thailand in 1998 and local market starting in 2010 through 24”

domestic pipelines. Being the responsible international company in earlier days, even

though there is no obligation to perform EBS and EIA studies, TEPM had conducted

these studies in line with international and internal best practices for every operational

activity. When the Myanmar Environmental Impact Assessment rule and procedure

was issued in December 2015, TEPM was started engaging with the Environmental

Conservation Department for the compliance of existing Yadana facilities several

times. In October 2018, ECD approved the existing Yadana facilities EMP by sending

the letter to TEPM via MOGE.

As per article (108) of 2015 Environmental Impact Procedure, TEPM is required to

submit a six monthly environmental monitoring report for its current existing Yadana

facilities. Therefore, this document is developed for the assurance of complying with

the requirements committed in the Environmental Management Plan of Yadana

facilities. Being the mature Oil and Gas Company in Myanmar, ISO 14001:2015 which

is one of the internal requirements of TOTAL group is recently performed by the

external third party in Dec 2018. Regular internal HSE audits emphasized on

environmental management are also performed to monitor the environmental

compliance of TEPM.

Contact details of Project proponent is provided below:

Name: Saw HUDSON

Position: Environment Engineer

Address: No. 5, Sacred Tooth Relic Lake Avenue,

Punn Pin Gone Quarter No.5, Mayangone Township, Yangon, The Republic of the Union of Myanmar.

Phone: 95 (1) 650 977, 650 989, 660 466

Email: [email protected]

3. Description of the Yadana Project and Environmental

Management

The Yadana Onshore and Offshore project are an existing development operated by

Total Exploration and Production Myanmar (TEPM) consisting of various onshore and

offshore components that extract, produce and transport gas from TEPM’s offshore

Block M5 and M6 to local market and Thailand.

mailto:[email protected]

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The Yadana field is located offshore in Myanmar in the Andaman Sea in blocks M5

and M6. The first gas delivery began in 1998 and commercial production in 2000. The

Yadana Field currently produces natural gas from wellhead platforms WP1, WP2, WP3

and WP4. The gas is transported through a 355.16 km offshore pipeline and 63.67 km

onshore pipeline for gas delivery to a power generation facility in Ratchaburi Province,

Thailand and to the Myanmar domestic market.

TEPM’s Yadana Production operations can be divided into six main components, as

follows,

Yadana Offshore Facilities; WP1,WP2,WP3,WP4,PP, FP,QP, MCP, LCP

Yadana Onshore Facilities, consisting of

o Pipeline Centre;

o Metering Station;

Thaketa Logistics Base and

Kanbauk Village Corporate Social Responsibility Activities.

An overview of Yadana components is illustrated in Figure 1.

Figure 1 Overview of Yadana Existing Facilities

3.1 Yadana Onshore Activities

The onshore components include Kanbauk pipeline center, Thaketa Logistics Base

and Yangon Head Office. The Kanbauk pipeline center consists of landfall, Pipeline

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Right of Way (ROW), Pipeline Center (PLC), and Metering Station (MS) including

Tanintharyi Nature Reserve, which is the conservation project funded by TEPM, PCML

and PTTEP (see fig 2). The gas pipeline is approximately 63 km long and run parallel

with the PTTEPI Zawtika and the Petronas Carigali (Hong Kong) Myanmar Ltd (PCML)

Yetagun pipeline from Daminseik village to the Thailand border. Kanbauk pipeline

center is located approximately 10 km from the Daminseik landfall location.

In the pipeline center, several activities like overall control of pipeline center, TEPM

conducts corporate social responsibility (CSR) activities with Kanbauk community and

other stakeholders near the onshore facilities. CSR activities primarily consist of

support for education, health and fishing activities. Public participation activities have

also been conducted in this community. TEPM also have been conducting an annual

report of CSR for this community every year since 1999 and distributed to all

stakeholders.

Figure 2: Location of Taninthayi Nature Reserve

PLC/MS Onshore Facilities and Activities

PLC/MS onshore facilities are divided in two main sites: Pipeline Centre (PLC) and

Metering Station (MS). Additional components include a pipeline landfall, permanent

wharf and transit road1, pipeline and service track, and border crossing as permanent

components.

The simplified operating philosophy of onshore part is that the gas transported from

36” pipeline is filtered together with a domestic line in pipeline center located near

1 The transit road and most part of the service track become public roads today. TEPM, as one of the road users, do the regular

monitoring and maintenance where necessary

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Ownbingwin village. The filtered gas is then sent to the Metering Station near Thai

border where the gas is again filtered for the final gas sale (see in below fig.3).

Figure 3: Simplified Onshore Process

Thaketa Logistics Base

Thaketa Logistic Base is located in Yangon. This logistic base supports TEPM’s

onshore and offshore operations, providing equipment, chemical products and stock

items. Thaketa Logistic Base is comprised of a warehouse, chemical shelter,

dangerous good site, generator house and also a marine transportation port owned by

MOGE for the marine transportation. Moreover, there are two supply boats assigned

to supply cargos from Singapore and Ranong to TEPM offshore and onshore sites.

Alternatively, one of these two boats has to stay in stand-by at Yadana platform.

TEPM Office in Yangon

The TEPM Yangon, head office is located in Yangon, Myanmar. The premises consist

of an office building and two utility buildings, containing a chiller for the HVAC system

and 1 standby generator and an electric room and plumbing system. There are 269

employees working in the office as a total on a working day. The office is shown in

fig.1.

3.2 Offshore Facilities and Activities

The Yadana gas field in Block M5 and M6 is located approximately 100 km offshore

Myanmar at the edge of the continental shelf. The Yadana site is divided into different

platforms: a Living Quarter Platform called (QP), the Production Platform (PP), the Low

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and Medium Compression Platform (LCP/MCP), the Flare platform (FP2) and 4

Wellhead Platforms: WP1, WP2, WP3 and WP4. WP2, WP3 and WP4 are remote

platforms. An image of the current offshore facilities is shown in fig 4.

Figure 4: Yadana Offshore Complex

The operating facilities are grouped around the southern wellhead WP1 site, where

the relatively low water depth of the Yadana field promotes the use of separate

platforms (i.e. accommodation and process) connected together and to the wellhead

platform by bridges.

Water depth is variable across the field, with depths between 45 m at wellhead platform

(WP) 1 and 2, and 50 m at WP3. The 346 km submarine export pipeline route heads

east, passing to the south of the Gulf of Martaban and coming ashore at a landfall near

the fishing village of Daminseik in the Tanintharyi district of Southern Myanmar. At its

deepest point, the pipeline lies in approximately 145 m of water.

The simplified operating philosophy of offshore platforms is that the gas from the

Yadana reservoir is produced and processed offshore by means of a complex of

manned platforms and remotely operated wellhead platforms. Due to low gas pressure,

the gas is compressed in the LCP and MCP and passed through the dehydration unit

for the removal of water before transporting it to onshore. Then the gas is transported

to shore by tow gas lines: one 36” offshore and 24” onshore gas line transmitting the

gas to the Thai border near Banitong and one domestic gas line at Daw Nyein.

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Figure 5: Simplified Offshore Process

3.3 TEPM Environmental Management System

TEPM has an Environmental Management System, integrated in the Health Safety

Security, Sustainable Development, Environment and Energy (H3SE) Management

System, which is certified in accordance with the requirements of ISO 14001:2004.

TEPM has also integrated an Energy Management System in accordance with the

requirements of ISO 50001:2011. The respect and care of the environment are a

constant concern of TEPM within all levels of the organization. Measures are taken to

limit and control any significant impact on the environment created by TEPM’s

activities.

Before starting every new TEPM project or final abandonment stage, an Environmental

Baseline Study (EBS) is performed in order to describe the physical, chemical,

biological, and general socioeconomic characteristics of the site and highlight its main

sensitivities. In order to determine and demonstrate its energy performance

improvements, TEPM established an Energy Baseline as well. The baseline

establishes the energy performance before to implement an Environmental

Management System to compare energy performance before and after a change is

made to TEPM site or the system. Then, EIA studies are carried out for every single

project with the independent international recognized consulting companies.

In order to control TEPM activities that may contribute to actual or potential significant

environmental aspects, appropriate procedures have been developed and maintained

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accordingly. For example, the procedure (2-PR-DS-05-004) “Identification and

evaluation of environmental aspects and impacts” is developed to identify and evaluate

potential environmental impacts of its operational activities. The identification and

follow-up of Energy consumption and significant use are performed in the (2-PR-DS-

05-005) “Energy Management System”. Below is the procedures developed and

enforced for the implementation of health, safety and environmental aspects of TEPM

activities.

(2-PR-DS-05-003) “Waste Management”, (2-PR-DS-05-004) “Identification and Evaluation of Environmental Aspects and

Impacts”, (2-PR-DS-06-003) “Management of Hazardous Products”, (2-PR-DS-06-006) “Noise and Hearing Conservation Program”, (2-PR-DS-09-003) “Emergency Response Plan”, (2-PR-DS-09-004) “Oil Spill Contingency Plan”, (2-PR-DS-07-002) “Management of suppliers Minimum H3SE compliance

requirements”.

Regarding the enforcement of these procedures, every site has the assigned site’s health, safety, environment manager (RSES) for the implementation of the site’s safety, health and environmental aspects. In addition, Health Safety and Environment team lead by Superintendent/Supervisor is assigned to ensure the monitoring of the operational activities of TEPM. In order to evaluate TEPM’s environmental performance, the following data is monitored, accessed and reported to Head quarter monthly and annually:

Atmospheric Emissions, Aqueous Discharges, Chemicals used, Industrial & Domestic solid waste, Environmental Impact and Aspect Energy Performance Others

Regarding the emergency response to the oil and chemical spill, the procedure (2-PR-

DS-09-004) “Oil Spill Contingency Plan” defines at the affiliate level the response to be

implemented in case of hydrocarbon spill from any TEPM facilities or from any

contracted unit (e.g. rig, vessel) working for TEPM. On site, the RSES will manage the

response as per the site OSCP and, as required, be supported by the TEPM

Emergency Response Team, and international oil spill response organization, which

are mobilized if necessary by the TEPM Call out Authority.

4. Applicable Regulations Related to the Project

According to the approved EMP report of TEPM’s existing Yadana facilities, the

general guidelines related to the Yadana Project are mainly outlined here so that the

most relevant parameters are highlighted for the implementation of the operational

activities.

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Noise Levels

Noise prevention and mitigation measures should be taken by all projects where

predicted or measured noise impacts from a project facility or operation exceed the

applicable noise level guideline at the most sensitive point of reception. Noise impacts

should not exceed the levels shown below, or result in a maximum increase in

background levels of three decibels at the nearest receptor location off-site.

Table 1. Noise Levels

Receptor

One Hour LAeq (dBA)a

Daytime 07:00-22:00

(10:00-22:00 for Public holiday)

Daytime 07:00-22:00

(10:00-22:00 for Public holiday)

Residential, Instructional, educational

55 45

Industrial, commercial 70 70

Odor

Point and diffuse source odors from industries should be minimized using available

prevention and control techniques as described in the IFC EHS industry-specific

guidelines. Point source activities are those that involve stack emissions of odor and

which generally can be controlled using waste reduction, waste minimization and

cleaner production principles or conventional emission control equipment. Diffuse

source activities are generally dominated by area or volume source emissions of odor

(e.g. intensive agricultural activities) and which can be more difficult to control. Projects

should control odors to ensure that odors that are offensive or unacceptable to

neighbors do not occur. Generally, odor levels should not exceed five to ten odorant

units1 at the edge of populated areas in the vicinity of a project. Projects with multiple

odorous point or diffuse releases, or emitting complex odors should conduct an odor

impact assessment to determine ground-level maximum concentrations taking into

account site-specific factors including proximity to populated areas.

Industry-Specific Requirements for Onshore and Offshore Oil and Gas Development

Table 1 Effluent and Emission Standards for Onshore Oil and Gas Development

arameter Guideline

Drilling

fluids and

cuttings

Treatment and disposal in accordance with applicable standards provided in the IFC

EHS Onshore Oil and Gas Development guideline

Produced

sand

Treatment and disposal in accordance with applicable standards provided in the IFC

EHS Onshore Oil and Gas Development guideline

Produced

water

Treatment and disposal in accordance with applicable standards provided in the IFC EHS Onshore Oil and Gas Development guideline

For discharge to surface waters or to land:

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arameter Guideline

- 5-day Biochemical oxygen demand 25 mg/l

- Chemical oxygen demand 125 mg/l

- Chlorides 600 mg/l (average), 1,200 mg/l maximum

- Heavy metals (total)a 5 mg/l

- pH 6-9b

- Phenols 0.5 mg/l

- Sulfides 1 mg/l

- Total hydrocarbon content 10 mg/l

- Total suspended solids 35 mg/l

Hydrotest

water





- Chlorides 600 mg/l (average), 1,200 mg/l maximum

- Heavy metals (total) 5 mg/l

- pH 6-9

- Phenols 0.5 mg/l

- Sulfides 1 mg/l



Completion

and well

work-over

fluids



- pH 6-9


Storm

water

drainage

Storm water runoff should be treated through an oil/ water separation system able to achieve oil and grease concentration of 10 mg/l

Cooling

water

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

Sewage Holding and discharge to municipal or centralized wastewater treatment systems or onboard treatment to achieve:



- Oil and grease 10 mg/l

- pH 6-9

- Total coliform bacteria 400/100 ml

- Total nitrogen 10 mg/l

- Total phosphorus 2 mg/l


Air

Emissions

Achieve WHO ambient air quality guidelines, and apply

the following guideline value to emissions:

- Hydrogen sulfide 5 mg/Nm3c

Table 2 Effluent and Emission Standards for Offshore Oil and Gas Development

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Parameter Guideline

Drilling fluids

and cuttings

(non-aqueous

drilling fluid)

Non-aqueous drilling fluid, re-inject or ship-to-shore; no discharge to sea

Drilled cuttings, re-inject or ship-to-shore; no discharge except:

- Oil concentration lower than 1% by weight on dry cuttings1

- Mercury maximum 1 mg/kg dry weight in stock barite

- Cadmium maximum 3 mg/kg dry weight in stock barite

- Discharge via a caisson at least 15 meters below sea surface

Drilling fluids

and cuttings

(water-based

drilling fluid)

- Water-based drilling fluid, re-inject or ship-to shore; no discharge to

sea

Water-based drilled cuttings, re-inject or ship-to-shore; no discharge

except:

- Mercury 1 mg/kg dry weight in stock barite

- Cadmium 3 mg/kg dry weight in stock barite

- Maximum chloride concentration must be less than four time’s

ambient concentration of fresh or brackish receiving water

- Discharge via a caisson at least 15 meters below sea surface

Produced

water

Re-inject, discharge to sea maximum one day oil and grease discharge should

not exceed 42 mg/l; 30 day average should not exceed 29 mg/le

Completion

and well

work-over

fluids

Ship-to-shore or re-inject, no discharge to sea except:

- Maximum one day oil and grease discharge should not exceed 42

mg/l; 30 day average should not exceed 29 mg/l

- Neutralize to attain a pH of 5a or more

Produced sand Ship-to-shore or re-inject, no discharge to sea except when oil concentration lower than 1% by weight on dry sand

Hydrotest

water

- Send to shore for treatment and disposal

- Discharge offshore following environmental risk analysis, careful

selection of chemicals

- Reduce use of chemicals

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

Desalination

brine

Mix with other discharge waste streams if feasible

Sewage Compliance with MARPOL 73/78b

Food waste Compliance with MARPOL 73/78b

Storage

displacement

Compliance with MARPOL 73/78b

Bilge water Compliance with MARPOL 73/78b

Deck drainage Compliance with MARPOL 73/78b

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4.1 Compliance with Guidelines

There was no non-compliance issues during the reporting period.

5. Monitoring Activities in Offshore and Onshore

The monitoring program is developed to monitor the compliance status of the operational

activities. This monitoring demonstrates compliance with legal standards and TEPM’s internal

requirements, provides evidence of the effectiveness of the implemented control measures and

ensures the accuracy of impact predictions for the Project. This monitoring program is also

designed to allow for appropriate management actions to be taken as soon as possible in the

event of any accident or incident. When developing the monitoring measures, the following

strategies have been applied; 1) Consistent with internationally and locally acceptable practices

2) Logistically practical and 3) Cost effective.

Actions follow up of ECD’s approval letter comments and the monitoring table are shown in Table

3 and 4 in the following;

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Table 3: Monitoring Measures for Offshore Facilities

Environmental

Aspects

Monitoring Parameters Duration / Frequency of

Monitoring

Location of Monitoring Implementation Date of

Monitoring

Remark

1. Cuttings

(Water-Based

Mud, WBM)

Required by NEQG

Total Mercury

(Total Hg)

Cadmium (Cd)

Chloride (Cl-)

Once during drilling at

each well

All WPs Method

Cuttings samples was analyzed for

heavy metals according to globally

recognized standard e.g.US EPA

after drilling campaign in fig 6.

Number of samples

1 sample from section drilled with

WBM per well.

Lab analysis

report

received on

12/04/2017

See in Fig 6

2. Produced

water

Required by NEQG

Oil & Grease

Monthly summary of

volume discharged

Daily onboard

Analysis/Monitoring

for Oil and Grease

Record at

produced water

treatment unit.

Collect after

treatment at the

produced water

treatment unit

prior to discharge

overboard.

Method

Record produced water volume after

treatment prior to discharge

overboard.

Produced water samples analyzed

onboard.

Nil Produced water is

reinjected in the

well. There is no

produced water

discharge in the sea

directly.

3. Produced

sand

Required by NEQG

OOC %

Analysis/monitoring as

required (i.e. frequency

depends on sand

production volumes and

intervals)

Processing Platform Method

Record produced sand volume.

Produced sand samples will be

collected for analysis according to

international guidelines and

requirements such as USEPA.

TEPM There is a negligible

volume of sludge

collected monthly. If

there is a

considerable

amount produced, it

will be sent to

DOWA for the

treatment. Fig 7 is

the laboratory

record of produced

sand.

The implemented monitoring plan for offshore facilities is described in below;

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Cutting: Cutting discharge during the WP4 drilling campaign was sampled and analyzed for

heavy metals according to globally recognized standard US EPA. The results indicated that all

the test parameters are below the threshold limit values as see in below.

Figure 6: Test Result of Cutting Discharge

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Produced Water: Since the beginning of the Yadana project, produced water is injected into the reservoir so as to protect the marine

environment. Therefore, there is no produced water discharge into the sea.

Produced Sand: As estimated previously in the WP4 drilling campaign, an insignificant and negligible amount of produced sand

specifically mixed with liquid residue is collected and analyzed monthly in an in-house laboratory located at Yadana offshore platform.

The sampling result is shown in the below picture. Besides, a sand removal package is installed in production platform which constituted

solid-liquid cyclone de-sander and it is designed for the removal of fine sand, scale and other solids from inlet stream (produced water).

In the future, if there is a significant amount of produced sand is collected, it will be sent to a proper treatment facility onshore e.g.

DOWA.

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Figure 7: Laboratory Result of Produced Sand

The monitoring plan implemented for onshore facilities is discussed in below.

Table 4: Monitoring Measures for Onshore Facilities (including Thaketa Logistics Base)

Environmental Aspects

Monitoring Parameters

Duration/Frequency of Monitoring

Location of Monitoring Implementation Monitoring Date

Remark

Noise Required by NEQG

One Hour LAeq

(dBA)

In event of or

response to

complaints

At site of complaint Standard noise sampling

methods. Compare results with

data from nearest baseline

station and NEQG

TEPM Attached the noise map

in Appendix 1.

Storm Water Drainage

Required by NEQG

Oil & Grease

6 Monthly

In event of spillage

or leakage

In response to

complaints

Storm water

discharge

locations

Samples will be collected for

analysis according to

international guidelines and

requirements such as USEPA.

TEPM Attached the relevant

records in fig 8 and in

Appendix 2

Noise Monitoring in Onshore Sites: Being the International Oil and Gas Company, TEPM implemented the internationally recognized

Oil and Gas standards on noise conservation program for the employee exposure protection. The industrial standard for noise exposure

is 85 dBA, 8 hours per day without hearing protection. The uses of hearing protection are enforced in all TEPM facilities when the

sound level reaches 85 dBA over 8 hours or the peak sound level reaches 140 dBC or the average maximum sound level reaches 110

dBA. The noise maps are displayed in all public areas and the area where noise is exposed (See in appendix 1).

The national emission quality guidelines (NEQG) impose to address the impacts of noise beyond the property boundary of the facilities.

According to this guideline, the noise level should not exceed 70 dBA at the nearest receptor location. To fulfill the requirement, TEPM

prepared the maps based on the measurement made around the noise source and around 50 m intervals in all onshore facilities as

shown in the followings. The receptor location is quite far from the noise source in most sites. Except for the gas engine generator run

in the PLC and MS, the noise source generators existed in Thaketa and Yangon head office is used for emergency only. That means

the generator of Thaketa and Yangon head office runs during the power cut off. There is no complaint received so far from the

neighboring communities.

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Storm Water Drainage and Sanitary Wastewater Monitoring

Total EP Myanmar’s onshore site’s storm water includes surface runoff, flow resulting from

rainwater, drainage or other sources. Oily water separators and grease traps are installed and

maintained at the refueling facilities before discharging the surface runoff. The storm water is

connected to the sanitary waste water streams in PLC and MS due to the former plant designs

which were built since the beginning of the project in 1995.

The sanitary wastewater from onshore facilities includes effluents from domestic sewage, kitchen,

laundry facilities and clinics. These wastewaters discharge into the sewage treatment system

after passing through the grease traps where regular collection and maintenance are made by

catering crews. During the summer, the treated effluent is not available due to the treatment of

conventional reed bed system (see in appendix 2). That means this conventional system is

functioning well and no compliant received from the employee and neighboring communities.

Therefore, regular monitoring is not applicable due to the treatment system design. However, due

to the regulation required by ECD, TEPM would consider analyzing the outlet of the treated

effluent which is sieved through during the raining season only from June – October period to be

compliance with the effluent standards of the conventional treatment system. The results will be

reported in next six-monthly reporting periods.

Thaketa logistics base is located in MOGE compound where other companies’ facilities and

MOGE office are residing. Its storm water drainage is connected to the sanitary wastewater

treatment system. The domestic water from a tube well is treated and analyzed regularly to know

the efficiency of the treatment system installed for utilizing. Besides, the nature of work related to

Thaketa logistics base is mainly storage of the goods and transferring of stocks to offshore and

onshore facilities. Therefore, the monitoring of storm water and sanitary wastewater is

impracticable due to previous aged-old design and the influence of neighboring environment such

as MOGE’s car workshop, PTTEP’s pipe storage facilities etc…

In Yangon head office, the sanitary wastewater is discharged into the sewage treatment system

where effluents are treated and discharged into the nearby drainage system. The discharge

effluent is sampled and analyzed monthly in the laboratory. The sample results (no grease

parameter analyzed, but it will be included in the next reporting period) are shown below.

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Figure 8: Sample results of sewage water from Yangon Head Office

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Verification Audit

The TEPM‘s environmental management plan is in line with international standard like ISO

14001and ISO 5001. TEPM has achieved the first ISO 14001:2004 in 2005 and now a new

standard of ISO 14001:2015 was certified in 2017. This certificate will be renewed every three

years in 2020. Being the responsible business company in Myanmar and multi-international

company, TEPM has verified its HSE system under the scrutiny of internal and corporate audits.

There is internal and corporate HSE system audit annually performed to monitor and evaluate the

effectiveness and efficiency of the affiliate HSE system. As per comment from ECD stated to

perform the verification audit with registered third party organization or consultant, the recent ISO

14001 audit performed in 2018 is attached in Appendix 3.

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7. Conclusions

This environmental monitoring report is the very first for TEPM when it comes to existing Yadana

Facilities. Despite the legal requirement do not specify the detail information for producing this

kind of report, TEPM produced this report based on the availability and most relevant information

so that the requirements will be fulfilled.

TEPM manage its operation according to the updated international industrial standards in terms

of environmental protection. There are no complaints received so far regarding the environmental

conservation practices of TEPM in the onshore and offshore environment. In terms of

environmental management and monitoring, annual HSE audit, which focuses on the health,

safety and environmental protection and an annual external ISO 14001 audits which focus mainly

the practices and performance of environmental management in TEPM facilities are conducted

annually.

The operational procedures applied by TEPM have been different when it comes to adopting the

government’s legal requirements which are mainly IFC standard, for example, Industrial noise

thresholds 85 dBA whereas 70 dBA of NEQG. The IFC standards are designed for those

organizations which required loans or funding from the bank like the World Bank or ADB etc…

Their standards are quite demanding for the loaners or fund seekers to protect the environment

where they are operating. Therefore, the requirements imposed by IFC standards are slightly

different for the Oil and Gas sector. The environmental authority should review their requirements

with the updated industrial norms and standards.

The TEPM’s environmental management system is quite robust in terms of environmental protection and conservation. Since the application of ISO 14001:2004 in 2005, TEPM’s environmental management system has been improved, especially in the area of pollution prevention, legislation compliance, stakeholder confidence, increased employee morale, effective environmental aspects/impacts management, and new business opportunities with environmentally aware customers and continual improvement etc... In 2017, TEPM acquired a new ISO 14001:2015 version to be updated with several new requirements such as leadership accountability, risks associated with threat and opportunities, life cycle perspective, value chain control and influence, etc. TEPM successfully achieved the new ISO 14001:2015 version in Dec 2017 and it will be renewed in 2020. Last but not least, TEPM will execute systematically and continuously of the monitoring measures for onshore and offshore facilities described in the EMP report. TEPM will also incorporate the required parameter like grease and oil of the effluents of Yangon Head Office and Pipeline center in the next reporting period and will also include the environmental performance of all TEPM sites’ monthly and annual data.

31 | P a g e

8. Appendixes

Appendix 1. Sample Noise Map in Offshore

32 | P a g e

Appendix 2. Sample of PLC Sewage system

PLC SEWAGE SYSTEM

Meeting: Yangon xx/09/2016,

PLC SEWAGE SYSTEM

PLC Sewage System – September 2016 2

15 m3

2008

ST5

ST 4 ST 3 ST 2 ST 1

ST 5

Old Soak

Pit

New Soak

Pit

Aeration

Pond

Small creekOutlet of aeration pond

To A3 main entrance gate

Local reed growing in old soak pit

Local reed growing in new soak pit

Restaurant

Laundry

Clinc

New Working

Space

Sagaing

Dawei

Bagan

Mandalay

Inlay

Office

Security

Workshop

Control

PLC SEWAGE SYSTEM

Aeration Pond


PLC SEWAGE SYSTEM – SEPTIC TANKS

ST5

ST4


PLC SEWAGE SYSTEM

ST1, ST2 & ST3 DESIGN


● The primary treatment (Septic Tank) is the separation of most of the solids from the liquid effluent, slowly digested by naturally occurring bacteria.(The bleaches and soaps from laundry are killing the bacteria)

Most of the solid material will either sink as sludge or float to the top as scum, leaving the effluent between to flow out to a secondary treatment stage.

● But they will gradually build over time and need to be removed occasionally (de-sludging process). The sludge is withdrawn at a frequency of 6 months to year in large tank. For small tank it can be 2 to 3 years.

● To speed up the process bacterial dozing such as (Aqua Clean) will be needed.

If this process is not functioning properly, solids particulates will washed out into the soak pit which may lead to a blockage resulting bad smell in the vicinity of the soak pit.

PLC SEWAGE SYSTEMPRIMARY TREATMENT


PLC SEWAGE SYSTEMSECONDARY TREATMENT

● A secondary treatment at PLC sewage system is a ‘Reed Bed Treatment System of sewage’ where a system of perforated pipes is laid in under ground gravel trenches.

● A reed bed system is the subsurface flow of natural treatment system in which “Reed” species such as “Phagramites kaka” is planted over the prepared bed.

● In this system the liquid effluent percolates through the gravel, sand and geo-textile where solids are removed and digested by microorganisms associated with the root system of reeds known as rhizodegredation.

● As a result the remaining liquid is clean enough to filter into the ground water. This process is the main mechanism for the removal of contaminants in an environmentally acceptable manner.


PLC SEWAGE SYSTEM - DESLUDGING

c. The total of the scum and sludge depths are equal to or greater than half the

liquid depth.

The sewage odour and sewage overflow are indications of a system overload.


PLC SEWAGE SYSTEM – SCUM LAYER MEASUREMENT


PLC SEWAGE SYSTEM – SLUDGE LAYER

MEASUREMENT


PLC SEWAGE SYSTEM – RETENTION TIME

● This is the time that elapses from the entry point of sewage into the

clear zone to the time of exit of the sewage from the clear

zone of the septic tank.

● The septic tank is generally designed with a minimum retention time

of 24 hours and should be able to provide up to two or three days of

retention time.

● If the sewage is not retained in the clear zone of the septic tank for

the minimum retention time period, then the effluent does not get

treated to the desired level.

● Therefore, the solids in the waste do not separate and can go

untreated and the solids may also flow out of the tank along with the

effluent into the soak pit.


PLC SEWAGE SYSTEM – RETENTION TIME


PLC SEWAGE SYSTEM – DRAINFIELD (SOAK PIT)

● About 60 percent of the C that makes up the incoming BOD is removed

in the septic tank during the settling processes. The remaining 40

percent of BOD enters the soil absorption field trenches.

● This growth results in a thick layer of cells, commonly called a biomat.

This biomat is where the bulk of biological wastewater treatment occurs

in a septic system soil absorption field.

● the biomat thickens and subsequently reduces the wastewater infiltration

rate in the trench.

● So that PLC sewage system have Reed bed and biomat treatment.

● Manholes are installed before / after Soak pits to inspect the odor smell

and solid wastes.


PLC SEWAGE SYSTEM - ADDITIVES

The majority of additives are a combination of the various types of bacteria commonly

found in a septic tank.

There is no scientific documentation that chemical additives will improve septic tank

operation. The number of bacteria contained in a chemical additive is very small in

relation to the bacteria already present in septic system.


PLC SEWAGE SYSTEM

● Detention time for flow in septic tank : 2 daysSeptic

Tank

Location Man-

day

flow (L)

Total

Flow

Max

POB (2-

days)

Max

POB (24

hrs)

Capacit

y (m3)

Remark

Average flow

ST 1

Workshop

70 22 42 3Control Room

ST 2

Admin Office 50 x 15 750 15

24

10

15

57

10

11Bago Dormitory 167.5

Guard Post 70 x 10 700

ST 3

Bagan Dormitory 167.5

167.5

167.5

45 90 15 167.5 L/dayMandalay

Dormitory

Inlay Dormitory

ST 4

Sagaing

Dormitory

167.5

167.5

45 90 15 167.5 L/day

Dawei Dormitory

ST 5

Restaurant 25

52 104 15 145 L/dayClinic 70

Community

Building

50


PLC SEWAGE SYSTEM

● No liquid discharge at aeration pond and soak pit outlet - Env law and regulations in line

● No foul smell nor odor at soak pits area PLC septic tanks and soak pits are working normal

● Current system- ko Thant zin?

The way forward

● Regular monitoring of odor smell at septic tanks and soak pit (daily)

● Removal of Sludge and Scum from septic tanks as required (monthly visual check, Quarterly thickness level measurement)

● Improvement of efficiency of Soak Pits – odor smell, any anomaly identified clean the distributed drained perforated pipes and biomat layer shall be visually checked the pipes and biomat layer area at end 2017 or 2018 even though no anomaly

● Continue dosing of Aqua Clean as per Site Standing Instruction 3-SI-DOK-HSE-05-002

CONCLUSION AND RECOMMENDATION

33 | P a g e

Appendix 3. Internal and External Audit reports

AUDIT PLANNING & ORGANIZATION

Internal Environmental and IH audit debriefing, October 2018

Audit Team Member- Khin Maung Lwin (HSE)- Soe Oo Kyaw (HSE) - Onshore- Ei Phyu Phyu Htun (HSE) - Thaketa Base- Etienne TOURNEBISE (HSE) - Offshore- Lu Lu Tin Oo (EC) - Yangon Office

Audit PLANNING- 15/24/27-08 & 07-09-2018 - Briefing at Yangon Office- 28-08-2018 - Audit at Thaketa base- 29~31-08-2018 - Audit at PLCMS- 03~05-09-2018 - Audit at Yadana- 11-09-2018 - Audit at Yangon Office- 03-10-2018 - Debriefing at Yangon Office

Audit Interviewees- HSE Superintendent- HSE Supervisors- Logistic Supervisor- HSE technician- Electrical / Instrument team- Site Doctors- Camp boss- Contractors- Laboratory technician

REFERENCES


● Myanmar National Environmental Quality (Emission) Guideline● ISO 14001-2015 : Environmental Management System Guidelines● ISO 50001-2011 : Energy Management System Guidelines● DIR-GR-HSE-001 One-MAESTRO HSE principles● CR-GR-HSE-001 One-MAESTRO HSE expectations● CR EP HSE 052 : Waste Management in Exploration and Production activities● GS EP MED 062 : Hygiene offshore and onshore base● 1-PR-HSE-01-001: HS3E Management System Manual● 2-PR-DS-05-002: Environmental Monitoring and Reporting● 2-PR-DS-05-003 : Waste Management plan● 2-PR-DS-12-001: HSE Performance Indicators: Definition & Monitoring● 2-PR-HSE-01-001: Compliance Obligations Procedure● 2-PR-HSE-05-004: Identification and Evaluation of Environmental Aspects and Impacts● 2-PR-HSE-05-006: Identification of EMS interested parties, Issues, Risks & Opportunities● 2-PR-HSE-02-001: HSE Communication & Feedback● 2-PR-HSE-02-003: H3SE Objectives, Targets and Action Plan● 2-PR-DS-05-005: Energy Management System Documents● HRAFs● Environmental Aspect/Impact register

SCOPE OF AUDIT

● ISO 14001-2015 Environmental Management systems requirement - Environmental Management System- Objectives and planning to achieve them - Environmental objectives- Objectives and planning to achieve them - Planning actions to achieve environmental objectives- Operational planning and control

• Chemical Handling

• Waste Management

- Emergency preparedness and response- Monitoring, measurement, analysis and evaluation – General

● IH – Health and Hygiene● Energy Management

● Audit for ISO 14001-2015 Surveillance audit (5th to 6th Nov)● Audit for ERNST & YOUNG Audit-Group Audit (29th Oct to 2nd Nov)


GOOD POINTS


● Good house keeping and proper waste segregation on Yadana andPLCMS

● Regular monitoring on Diesel, Water and Electrical consumption toreduce on average consumption compared with previous year

● Weekly H&H performed by site doctor, HSE, logistic, maintenance onYadana and PLCMS and weekly follow up actions

● Chemical MSDSs folder are updated on 2018 and kept at Yadanacontrol room

● Food wastes and garden refuse are composted to use as fertilizer inYangon Office (Reduce non-hazardous wastes disposal)

● Rain water are collected to safe water taken from YCDC in Yangonoffice and to use gardening water at PLC to save ground water takenfrom tube wells

● Solar water heater is installed in Yangon office to save electricity usagefrom Government

● Waste water outlet is continuously monitored and analysed in Yangonoffice together with local contractor to get the results within target range– BOD – 25.2 (20-60ppm), COD – 72 (<200ppm)

● Waste inventories are recorded with different colour for different sites’waste received at Thaketa base

ENVIRONMENT & IH AUDITFINDINGS AND RECOMMENDATIONS

TEPM ENVIRONMENTAL OBJECTIVE


● FindingTEPM HSE Environmental objective (Reduce non-hazardous waste 3%) is not included in site HSE objective.

● RecommendationReduce non-hazardous waste by 3% should be included on site HSE objective and review in site HSE committee meeting.

YDN TKA

● Sites commentsEnvironmental objective included in site action plan and presented in every bi-weekly HSE meeting & committee meeting. (PLCMS)

Non-haz Waste reduction 2017 vs 2018 reviewed in HSE committee meeting (YGN)

No comments from other sites.

ENVIRONMENTAL ASPECT/IMPACT REGISTER


● FindingEnvironmental Aspect / Impact Register doesn’t include:

- 4D Seismic, EMoS activities, ROV campaign. (YDN)

- CI (Corrosion Inhibitor dilution process) (TKA)

- Decommission of old 6” diesel line at wharf (PLCMS)

● RecommendationEnvironmental Aspect / Impact Register should be updated with new activities.

YDN PLCMS TKA

● Sites comments• Old 6” diesel line at wharf has been decommissioned in June 2018

(PLCMS), need to confirm still need to add in PLCMS Env Aspect / Impact register

WASTE MONTHLY REPORTING


● FindingSome hazardous / non-hazardous waste are consolidated in Environmental monthly report template not in line with current waste disposal options:- kitchen/ gallery waste, garden refuse filled in “Tonnage sent to biological treatment, composting”

(PLCMS, YDN)

- Packaging material / paper filled in “Incinerated tonnage in burn pit” (TKA)

- Mix burnable filled in “incinerated tonnage in burn pit”, Glass “Tonnage permanently stored on site” (YGN, YDN)

● RecommendationMonthly waste report format should be reviewed and revised inline with current TEPM waste produced and waste disposal process (YGN HSE)

● Sites commentsN/A



● FindingSome waste is missed to report in site Environmental (waste) monthly report;

- Garden refuse, condensate produced from MS, (PLCMS)

- Spent oil, black waste (YGN)

- Fluorescent lamp, black waste, spent oil (TKA)

● RecommendationAll kind of wastes produced from sites should be reported in site Envoronmental monthly report

PLCMS TKA YGN

● Sites commentsNo comments from sites



● FindingSome hazardous wastes received from other sites are mistakenly reported together with site produced wastes in PLCMS site monthly Environmental report (wastes); - Fluorescent light bulbs / neon tubes, medical wastes, paints / paint pot, aerosol, contaminated soil,

other wastes

● RecommendationAll received hazardous wastes from other TEPM sites should not reported as site produced wastes.

PLCMS

● Site commentNo comment from site

WASTE SEGREGATION


● FindingClinical waste from Medical waste bin (Yellow bin located outside of clinic) is sent together with hazardous waste to onshore.

● RecommendationNot follow the company waste management procedure biological waste to be separated from hazardous wasteMake sure all other sites followed as per recommendation for clinical waste

YDN


WASTE SEGREGATION AND MANIFEST


● FindingKitchen wastes (galley, glass, cans/tins, plastic bottles, plastic bags) are recorded as catering dry waste in waste manifest, and then reported as dry waste in site monthly Environmental (waste) monthly report

● RecommendationKitchen wastes should record as different waste categories in waste manifest to report different waste in site monthly Environmental (waste) report by site Logistic.

YDN


WASTE MANIFEST


● FindingWaste manifest are recorded both non-hazardous waste and hazardous waste in one sheet that waste destination / waste receiver are not same

Hazardous waste are sent with manifest from Yadana to PLC through Thaketa base and Thaketa base sign on manifest as hazardous waste receiver instead of waste will be transferred to PLC (there is no waste transit acceptance available on waste manifest)

● RecommendationNon-hazardous waste and hazardous waste should be transferred with different waste manifest.Waste manifest should be reviewed especially for hazardous waste transfer from Yadana to PLC which may need waste transit acceptance and two mean of transporters’ acceptance on waste manifest

YDN


WASTE MANIFEST


● FindingWaste manifest is not properly filled in:- Smart fresh food waste manifest designated to PLCMS HSE, actually food waste taken by villager for

animal feed (PLCMS)

- Hazardous waste (used cooking oil, oily grease) are recorded at non-hazardous waste location in waste manifest which transport from MS to PLC (PLCMS)

- Vessel stamp and Master sign on waste receiver location on waste manifest instead of transporter acceptance location (YDN)

● RecommendationWaste manifest to be properly filled up.

YDN PLCMS

● Site commentNo comment from sites

WASTE TRANSFER


● FindingWaste cooking oil, oily sludge waste and dry waste (garbage waste, glass bottles, cans/ tins, plastic bottles, plastic) are sent to Thaketa base with SMART container and all wastes are taken by Yangon SMART.

● RecommendationHazardous waste (waste cooking oil, oily sludge) disposal to be followed as per company procedure.

YDN


WASTE STORAGE AND PACKAGING


● FindingChemical liquid waste are stored without secondary containment in laboratory.

Chemical liquid waste (chloroform) is going to be sent without proper packaging / labelling. (pack with cartoon box, no pictogram on box)

Dedicated broken glass waste bin for laboratory is located outside of laboratory. (safety point of view)

● RecommendationLiquid waste to be stored with secondary containment.Chemical liquid waste to be transported with proper packing and labelling.Dedicated broken glass waste bin can be arranged inside laboratory with small waste bin.

YDN


WASTE STORAGE


● FindingSome waste drums stored without label and signage

● RecommendationWaste liquid drum should be labelled to know the content of waste

PLCMS


INDUSTRIAL HYGIENE


● FindingCartridge mask is used by both laboratory technicians by sharing.

● RecommendationCartridge mask should be used individually to protect contamination one person to another person.

YDN


CHEMICAL MANAGEMENT


● FindingLaboratory chemical lists and MSDS folder are last updated on August 2016 (YDN)

Some chemicals are still kept in laboratory since long time ago (e.g benzene – 10 liter) (YDN)

MSDSs from cylinders storage area are still with old GHS sign (TKA)

● RecommendationLaboratory chemical MSDS should be reviewed and updated as required.

Review necessity of Chemicals stock which to be kept in laboratory and to be disposed unnecessity chemical.

MSDSs from cylinders storage area to be updated with new GHS sign.

YDN TKA

● Sites commentsNo comment from sites

TRAINING MATRIX


● FindingSite training matrix follow up is not updated for key personnel. (TKA)

SMART provided training is recorded same training date / due date for all catering crew. (YDN)

● RecommendationTraining matrix to be updated and corrected.

YDN TKA

● Sites commentsSMART provide the correct training follow up sheet after debriefing at Yangon Office

INDUSTRIAL HYGIENE MANAGEMENT


● FindingThaketa logistic base noise map has last updated on Year 2007.

Domestic water samples for analysis are taken raw water from storage tank and treated water from water treatment unit.

Shower head, basin tag cleaning procedure have been implemented and not included PPE requirement.

● RecommendationThaketa logistic base noise map should be updated.

Treated water sample for analysis should be alternately taken different place from end user points (basin tag, shower head…etc) and free chlorine level should be maintained minimum 0.2 ppm.

Shower head, basin tag cleaning procedure should be updated including with PPE requirement (chemical glove, mask…etc)

TKA


OBSERVATION


● All mini MSDSs should be placed in catering chemical storage area in 2nd deck camp boss office (noticed “Bleach” chemical MSDS missing in audit time)

● Some waste bins located on site are not same with TEPM waste bin color code. ● CI(corrosion Inhibitor) mixed water tank is kept at PP weather deck without MSDS

available and hazard sign is needed to replace.● Flammable liquid store cabinet are stored together with other personnel

belongings at paint store PP mezz deck.

YDN


ENVIRONMENT & IH AUDITONSHOREAudit debriefing: PLC 31-08-2018

PLCMS NON-HAZARDOUS WASTE MONITORING


Monitoring non-hazardous waste generation

PLCMS


YANGON


YADANA


THAKETA


PLCMS

THAKETA


YANGON

YADANA

Waste taken by SMART


THAKETA

PLCMSCondensate produced from MS is missed to report

YANGONSpent oil from maintenance / black waste are missed to report


THAKETA BASEFluorescent lamp, black waste, spent oil (?) are missed to report in monthly report.


Hazardous waste reported together with waste received from

other sites


Waste destination to Thaketa / PLC

Waste receiver from Thaketa

Non-hazardous waste to Thaketa

Hazardous waste to PLC


This food waste go to animal feed

These wastes to be recorded as hazardous waste

Vessel Master signed in waste receiver location


Dry waste bags

Waste cooking oil


Chemical liquid waste packed with cartoon box

Chemical liquid waste without secondary containment


Waste chemical drums without labelling


Last updated on August 2016

MSDS with Old GHS sign


All catering persons are same date recorded


Metal waste bin

Non hazardous waste bin

General waste bin with green color

Metal waste bin with gray color


CI mixed water storage tank is kept at PP weather deck, no MSDS available,

hazard label is needed to replace.

Flammable liquid cabinet are stored together with other personnel

belogings

WASTE MONITORING FROM THAKETA INCLUDING OTHER SITES


To compare only waste from TKA

THAKETA


Waste not traceable, no name and sign

This food waste go to animal feed

These wastes to be recorded as hazardous waste

GOOD POINTS


CN : 01 104 1734929 Audit Report as per TRCert - ISO 14001:2015;

for

Total E&P Myanmar

No. 5 Sacred Tooth Relic Lake Avenue, Punn Pin

Gone Quarter, No. 5 Mayangone Tsp, Yangon,

Myanmar

Audit Report

Client Standard(s) Certification Number(s) Audit Type

Total E&P Myanmar ISO 14001:2015 01 104 1734929 1st Surveillance Audit

Rev. 20180910 Page 2/17

Contents

1 Audit result ................................................................................................. 3

2 Scope ........................................................................................................... 4

2.1 Description of the organization ................................................................ 4

2.2 Scope of certification ................................................................................ 4

3 Changes in the management system / Contract review .......................... 5

4 Audit findings ............................................................................................. 5

5 Dates ............................................................................................................ 7

Audit Report



Rev. 20180910 Page 3/17

Audit Leader : Mr. Kittipong Tungprasert

Audit Team : Mr. Natthasorn Kosumchotiros, Mr. Phubodee Krichphurin(only5)

Management System Representative : Mr.Khin Maung Lwin

Audit Date : November 5-6, 2018

1 Audit result

Management system effectiveness was verified on site by means of random sampling by an appropriately selected auditor. This applies in particular to the compliance of workflows with standard requirements and the descriptions in management system documentation. The special features of the organization’s business activities, the applicable statutory and regulatory requirements and the requirements set forth in other generally applicable documents were also taken into account. This was done by means of a sampling approach, by conducting interviews and reviewing the appropriate documentation. Audit findings and recommendations regarding opportunities for improvement have been set forth in Sections 4 of this report.

The last audit revealed nonconformities which have been demonstrably corrected. The corrections and corrective actions taken in this respect have been verified.

A stage 1 audit was performed and the organization found ready for certification. Identified weaknesses, if any, have been eliminated and the respective corrective action verified.

The current audit revealed the following nonconformities:

Standard(s): No. of nonconformity

ISO 14001 0

The major nonconformities (No. x) with individual standard elements require a re-audit to verify the effec-tiveness of the corrections and corrective actions (probable date:.ddmmyyyy)

X

The organization has established and maintains an effective system to ensure compliance with its policy and objectives. The audit team confirms in line with the audit targets that the organization’s management system complies with, adequately maintains and implements the requirements of the standard(s).

The auditor therefore recommends (provided the effectiveness of corrections and/or corrective actions addressing the identified nonconformities has been verified):

Award of the new certificates.

X

Maintenance of the existing certification.

Inclusion of the changes (see Section 3) in the scope of application of existing certifications

Maintenance or issue of the certificates only after successful completion of a re-audit.

Audit Report



Rev. 20180910 Page 4/17

2 Scope

2.1 Description of the organization

Total Exploration and Production Myanmar is located at No. 5 Sacred Tooth Relic Lake Avenue, Punn Pin Gone Quarter, No. 5 Mayangone Tsp, Yangon, Myanmar

Total E&P Myanmar extract the gas offshore platform at the Bay of Bengal and send to the gas to the customer by pipeline. Other 4 sites (Yanada offshore, Thaketa Logistic Base, Pipe Line Center (PLC) and Metering Station (MS) are related to their gas production and transportation works.

Rotation works implement at

-Yadana Offshore: 06:30AM -18:30 PM,

- Onshore-PLC : 07:00AM - 19:00PM,

- Onshore-MS : 07:00AM – 19:00 PM,

- Yangon Office and Thaketa Logistic Base : (08:00AM-17:00PM)

Main Process:

1)Offshore process;

Wells Compressor ( MCP and LCP platform) PP Water, moist removal PLC MS

Customer( PTT)

Key process offshore

PP (Production Platform) : Free water knock-out drum( to remove free water from raw gas)

-Raw gas filter separator ( to remove moist from raw gas with Ethylene Glycol)

2) Pipe Line Center(PLC):

- Transportation of Gas and Associated Hydrocarbons. Onshore Installations including Onshore Pipelines.

Implement of CSR activities for Local Communities.

3) Metering Station (MS)

- Transportation of Gas and Associated Hydrocarbon. Onshore Installations including Onshore Pipelines.

4) Thaketa Logistic Base

- Logistic Support for Operation and Warehousing

2.2 Scope of certification

Scope of certification: (per standard):

Exploration, Production and Transportation of Gas and Associated Hydrocarcons

ISO 9001 standard requirements to be excluded from the scope:

-

Reasons for exclusions: -

In cases involving multi-site certification: Internal auditing throughout the multi-site organization was verified with a positive result. The management representative has appropriate authority over the sites included in the multi-site organization.

The audit took appropriate account of multi-shift operations and provided for representative auditing of all shifts.

No significant difference between each shift, so auditor decided to audit only morning shift.

Audit Report



Rev. 20180910 Page 5/17

The following sites and their scopes are included in the scope of certification:

Site No. (CN ext.)

Sites included in cert. Name/address of site

No. of emp.

Scope and processes Stand-ard(s)

Au-dited

01 Yangon: No. 5 Sacred Tooth

Relic Lake Avenue, Punn Pin Gone Quarter, No. 5 Mayan-gone Tsp, Yangon, Myanmar

260 Scope: Management of Exploration, Pro-duction and Transportation of Gas and Associated Hydrocarbons

ISO14001:2015 X

02 Yadana Offshore Bay of Bengal, The Republic of the Union Myanmar

100

(rotate by 200)

Scope: Production and Transportation of Gas and associated Hydrocarbons.

Offshore Installations including Pipelines and Satellite Platforms.

ISO14001:2015

03 Thaketa Logistic Base

Address: Shu Khin Tha Myo Pat Road, Thaketa Township, Yangon, The Republic of the Union My-anmar

33 Scope: Logistic Support for Operation and Warehousing

ISO1400

1:2015

X

04 Pipe Line Center(PLC): 138(rotate by 276

Scope: Transportation of Gas and Asso-ciated Hydrocarbons. Onshore Installa-tions including Onshore Pipelines.

Implement of CSR activities for Local Communities.

ISO1400

1:2015

X

05 Metering Station (MS)

Address: Nat Ein Taung,

Yebyu Township, Tanintha-yi Division, Myanmar, The Republic of the Union My-anmar

28(rotate by56)

Scope: Transportation of Gas and Asso-ciated Hydrocarbon. Onshore Installa-tions including Onshore Pipelines.

ISO1400

1:2015

3 Changes in the management system / Contract review

No major changes have been made to the management system and the management system documentation since

the last audit.

The order details which form the basis of the audit (including number of employees, scope and sites) reflect the

actual situation in the organization.

Current audit program is appropriately and no need to change for next audit.

The description of the scope in the certificate appropriately reflects the scope of the management system.

The audit plan was not changed during the audit.

Audit Report



Rev. 20180910 Page 6/17

4 Audit findings

The audit findings related to the audited standards are listed in the Annexes to this report (see. Annex ISO 14001:2015).

All information gained during the audit will be treated with strict confidentiality by the auditor and the certification body. In view of the sampling approach applied to the audit, weaknesses and nonconformities may still exist which have not been identified during the audit.

No. Unit/Department

Site

Positive findings

1 Management Highly commitment to upgrade ISO 14001 to New version.

The following recommendations and opportunities for improvement provided by the auditor are intended to contrib-ute to the continuous improvement of the management system.

No. Unit/Department

Site

Recommendations and opportunities for improvement

1 Yangon office There was opportunity for improve the PH parameter of effluent discharge it was

not comply with YCDC regulation (7 < PH <8) actual get 5.8 (Acidity) in May 2018

at site Yangon office

Audit Report



Rev. 20180910 Page 7/17

5 Dates

Due Date for the next audit

November 17, 2019

Agreed date for the next audit -3,+1 from due date

2018.11.27

Mr. Kittipong Tungprasert

Date Audit Leader / Auditor(s)

The auditor confirms his check that there is no conflict of interest, especially that neither he, nor his employer, the

organizational unit to which he belongs or an associated partner in the private sphere has provided consulting ser-

vices - including in-house training and internal audits - to the client on the implementation, development and

maintenance of a management system within the last two years.

Audit Report



Rev. 20180910 Page 8/17

Annex ISO 14001:2015 Item Audit result

Policy / objectives The environmental policy established by top management was communicated and implemented in the organization. It is suitable for the activities of the organization and its context. It includes the commitment to the protection of the environment continual improvement to enhance environmental performance and compliance with the bind-ing obligations. It provides the framework for establishing and reviewing environmen-tal objectives. The organization has determined suitable objectives, associated indi-cators to monitor progress and actions to achieve them.

Key environmental objectives and associated indicators are:

To reduce on average 3% of consumption of electricity from 2017 ; result: under monitoring

To control SO2 emission < 7.606 tons/year ; result : under monitoring

Environmental aspects,

determination of risks

and their changes since

the last audit

Key environmental aspects are identified and their significance and impact on prod-

ucts and services reviewed and updated at regular intervals. The procedure is de-

fined in 2-PR-HSE-05-04 Environmental aspect and impact register, Last update

30/10/2017. The evaluation criteria include SC (Severity of Consequence) and Occur-

rence the overall impact is calculated by Severity x Occurrence . Total 193 activity

of evaluation.

Aspects were updated on 30/10/2017.

Aspect of life cycle perspectives , impact, situation and obligation was evaluated and

determined cover normal ,abnormal and emergency.

Life cycle perspective

- Upstream: There was consider the impact of environmental aspect during ex-ploration as Energy consumption, Hazardous chemical control and utilize of gas per energy consumption etc.

- Downstream – The waste water came from gas separator process it was con-trol the waste water return to well by pressure of machine.

Risk, opportunities and environmental aspects and identified with their significant

And impact for the environmental management system have been determined (re-

garding environmental aspects, binding obligations and other issues) as below

Key environmental aspects include :

Processes/

Activi-

ties/products

Aspects of

risk

Impact Control of limit impact Pollution control

equipment/ Preven-

tion/Operational control

Gas to explora-

tion and trans-

portation

Gas leak

o Xylene emission from painting

Air pollution ROW Maintenance

Periodical monitoring

Weekly emergency drill

o Disposal by licensed waste service

o Offsite Recycle

Audit Report



Rev. 20180910 Page 9/17

Item Audit result

o Thinner us-ing

o Electri-cal/water us-age

o Heat

o Potential of fire


o Exhaust blower

o Awareness control/ EMP

o Program

Waste disposal by

Cinerator

Emission of

Oxides into air

Air pollution Own incinerator at PLC

Site

Operate by competence

Person

Ash store under control

Procedure is provided


o Onsite treatment by sludge precipitation before discharging

o Awareness control/ EMP

Purge gas to flare o Gas burnt Atmosphere

Air pollution Rate adjusted to air

Monitoring


o Ear plug, operation

TG running Dieseal gas

Burn to atmos-

phere

Air pollution

Noise

Vibration

Monitoring

Maintenance plan

Energy management

System.

o WI o Claim supplier


Watermaker

chemical han-

dling

Reject to sea Water pollution Monitoring of fresh water

Quality and rejected wate

o Operational control procedure and MSDS

Waste Collection

Segregation

Disposal

Waste type

Classification

(packing,

Hazardous,

food,

Scrap material

Waste pollu-

tion

Soil contami-

nate

Waste disposal by

Permitted supplier.

o Operational control procedure

o Disposed by licensed supplier

o Disposed by licensed supplier

o Disposed by local governor

o Operational control procedure and li-censed by Thai gov-ernment.

o Operational control procedure and EMP

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Rev. 20180910 Page 10/17

Item Audit result

Mud discharge

To sea

Sea quality

Degrading

Water pollution Use high biodegradable

Water and low toxicity

additive

-Installation of water

tank (for internal use

and fire pump) - 2017

-New toilet-ware for sav-

ing water 2017-2018

- monthly monitoring

consumption in ESC

meeting

-Awareness

-Objective to energy

saving

Sewage system

And water drain-

age

Production of

black wa-

ter/grey water

Water pollution Drainage system and

Bio remediation

Major accident

Gas leak

Gas release to

atmosphere

Air pollution

Noise pollution

Vibration

Emergency contingency

Plan

Leak on pipeline,content

Of whole PL section would

be vented

Use of vehicles//

Heavy equip-

ment

Diesel burnt to

Atmosphere

Particulate

Emission

Air pollution

Noise pollu-

tion/Vibration

Limited Speed

Maintenace

Identification and moni-

toring of compliance

obligations

The organization identifies the relevant legal and other requirements at regular inter-

vals and makes them accessible to all relevant functions. The procedure is defined in

2-PR-HSE-01-001 Process card Law and regulation management. The legal re-

quirements are classified into 8 subjects and evaluated twice a year. It is recorded in

EMS compliance Obligations Register list.

Examined with the list of August, 2018.

Evaluation of compliance

Compliance with applicable legal and other environmental requirements is evaluated

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Rev. 20180910 Page 11/17

Item Audit result

at regular intervals or every month, recorded in EMS compliance Obligation Register.

Last evaluation was in August 2018 – All complied

The following permits and licences are available at the organization including the

evidences of compliance :

Type of

obligation

Obligation

name

Requirment Compliance status Requirment

National

Legisla-

tion

Environemnt

conservation

Law

2012

Aim of this regulation

is to implement the

enviromental conser-

vation leading to

The sustainable de-

velopment of the

country

Comply - -

National Envi-

romental

Quality (Emis-

sion) Guidlines

(2015)

Specific the environ-

mental quality of off-

shore/onshore Oil and

Gas atmosphere

emission

Waste wa-

ter,noise,odor etc.

Comply - -

EIA procedure

2015

The business depsrt-

ment

Organization shall

carry

Out enviromental im-

pact

Assessment for his

plan

Business or activity

Comply - -

Forest Law This law specific the

managment of forest

Comply

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Rev. 20180910 Page 12/17

Item Audit result

1992 land,the establishment

of forest planta-

tion,permission and

removal of forest pro-

duce and the offenced

and penalties relating

to it.

Union of My-

anmar Marine

Fisheries

Law,1990

Pollution control

,disposal of polluting

material into

The union of marine

fisheries

Comply - -

Interna-

tional

Conven-

tion

MARPOL 73/78 Any discharge into the

sea of oil or oily mix-

ture

From ships is prohibit-

ed

Grinded food waste

can be discharged to

sea at

4 nautical miles of the

nearest

coast.MARPOL re-

quires the develop-

ment

Of a Shipboard oil

pollution emergency

plan for every oil tank-

er of 150 gross ton-

nage and above and

all other ships of 400

gross tonnages and

above

Comply - -

ICAO:

Annex 16 to

the conven-

tion on inter-

national Civil

aviation envi-

ronmental

Aircraft noise and

Aircraft

Engine Emission pre-

vention

Comply

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Rev. 20180910 Page 13/17

Item Audit result

protection Vol

1 and II

United Nations

Convention on

the Law of the

Sea ,Montego

Bay 1982

Prevention of Pollution

at Sea

Comply

Vienna Con-

vention for the

Protection of

The Ozone

Layer 1985

Ozone Layaer Protec-

tion

Comply - -

Company

Rule

CR EP HSE

052

Waste manag-

ment in Explo-

ration and pro-

duction process

This company rule

sets out the minimum

requirments for man-

aging waste.

Comply - -

Etc.

Leadership, responsibil-ity and authority and communication

The management demonstrates commitment with respect to the environmental man-agement system and integrates its requirements into the organization´s business processes. The following persons also have significant responsibility for the environ-mental management system:

·The each of the responsibility and authority has defined on the HSE02.04: HSE

Roles & Responsibilities in “Health, Safety, Security, Sustainable Development, Envi-ronment, and Energy management System Manual”.

·Environmental related Communication structure has defined in HSE Board meeting

The organization has set up an effective communication process for both internal and external communication.

Operation and perfor-mance evaluation

The organization identifies all environmentally relevant operations and activities and has established adequate processes for their planning and control. Consistent with a life cycle perspective this includes upstream and downstream activities as far as pos-sible as well as outsourced processes and changes.

The following activities are of particular relevance:

- Upstream: There was consider the impact of environmental aspect during ex-ploration as Energy consumption, Hazardous chemical control and utilize of gas per energy consumption etc.

- Downstream – The waste water came from gas separator process it was con-trol the waste water return to well by pressure of machine.

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Rev. 20180910 Page 14/17

Item Audit result

Factory Tour (Yangon Head office):

Waste management :

There were 3 types (Garden waste, Kitchen waste, Recycle waste ). The disposition of waste was done by the licensed suppliers.

Waste separation was inspected daily and recorded in Waste Tracking system

During audit sampling Waste manifest as Garden waste disposal by YCDC in 11.10.18

and seen monthly waste report .

Chemical Management,

Chemical storage was checked weekly and recorded,no spills or leaks, SDS and etc.

Chemical dispersion at points of use was monitored once a year.

Verified with evidences of Glass cleaner SDS.

Process wastewater treatment

The Septic tank was controlled by aeration pump including the annually clean sep-tic tank was provided. The result of effluent it demonstrate conform to YCDC legal (BOD, COD, DO and PH) but only PH is out of legal limit which result of Monitor-ing and measurement by external lab (AMD).

Production Method& Support, Field Operation

The main activity are office and concern only document.

The aspect was review in Sep 18.

Monitoring and measurement :

Monitoring and measurement of the environmental performance takes place accord-ing to adequate criteria and methods. Environmental indicators have been estab-lished for the analysis and evaluation of environmental performance.

The procedure is defined in GP HSE-05-02 Concerning parameters, for example,

- Atmosphere emission (VOC, TSP, SOx, NOx, HCL, Benzene and H2S)

- Water and liquid effluent

- Oil spill

There was monitoring and measurement in every month which result of monitoring

Conform to obligation since January 2018 until now.

Emergency Preparedness and response

ERP is defines under TERPM Emergency response Plan 2-PR-HSE-09-03.Emergency drill are exercised on weekly basic with exercised and test report pre-pared. Record of emergency response training done for ERP team all sites are avail-able.

Annual Emergency Exercise

•Thaketa Annual Exercise on 17 May 2018

• Yangon Annual Exercise in Jul’2018

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Rev. 20180910 Page 15/17

Item Audit result

• PLANNED: Large Scale Exercise in Nov’2018 All equipment was provided the preventive maintenance plan and check follow up that plan as fire pump, Extinguisher, Vessel, Helicopter etc. its was record result of inspection in SAP.During audit sampling record of preventive maintenance the Fire motor pump in 1 November 2018.

Maintenance :

Aspect evaluated in 30/10/2017 that significant is electricity consumption which got improvement plan.

Risk and Opportunity: waste and electricity consumption per unit from maintenance activities

Maintenance and facilities record and PM plan were checked as below:

- Glycol System Last Preventive maintenance in November 2018.

- Closed drain Vertical closed pipe plan and preventive maintenace record in Feb 2018.

- Condensate injection pump ,last preventive maintenance in 6 September 2017.

All work order was generated in SAP system for check the condition each machine.

PLC site

Waste control area located in the double fenced with entrance key locked. Waste control area is separated from office, and pipeline area. Main waste such as chemical liquid, contaminated container, Pigging sludge, etc. Waste were separated suitable. PLC site had an incinerator for disposal waste. Work instruction for operate incinera-tor was prepared. Air emission from an incinerator was monitored such as CO, SO2, NO2, the resulted was passed standard. Wastewater from canteen and toilet was treated by septic tank. The objective target such as reduce fuel consumption 3% from 2017. The environmental aspect was review in Sep 18.

Thaketa site

Auditor walked thru areas of this site, this site consists of

- Main warehouse of Raw materials for Platform: steel, epoxy resin, chemical and equipment,

- Workshop: for machining work, Fabrication work >> during an audit there was no activity done,

- Store of spare parts to support both offshore and onshore, - Chemical store - Cool room (23 Celsius degree) for storage sealant, silicon, glue and some

chemical, - DG store for storage Paint, Thinner, Tri-ethylene – Glycol, - Waste segregation area/bin: General waste/White bin with identification, Plastic

waste/White bin with identification, Metal waste/Blue bin and Hazardous waste/Red bin,

- Diesel thank 5,000 liter 1 tank, - Generator room has grounding system 4 nodes.

Auditor walked thru all areas, observed environment including environment aspects, interviewed the auditee and verified the objective evidences of operational controls, it was found that overall environment and environment conditions are acceptable with

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Item Audit result

no NC raised.

Objectives and targets base HSEQ of Y2018 are established as below,

- HSE: no personnel injury / no fatality or lost time injury (recorded as LTI), - Lifting

- All CCU Shall be DNV 2.7.1 standard, - No anomaly from site for 1 unit with 2 color code (including contractor’s

equipment), - No container door anomaly, including contractor’s own, - No drop object anomaly for container including contractor’s own.

- Warehouse - “0” discrepancy for stock cycle counting and partner’s audit.

- Operation - Material cost less than 30KUSD for TKA ops, - Overall budget for variable part to reduce 5%

- Administration - Review and update procedures which are over two years from issue date.

Overall results of the existing objectives and targets are acceptable; however, the existing objectives and targets should be more focused Occupational Health and Safety.

Environment risk / the existing system defined in the Environment manual has been maintained, the risk rating are 1/first priority, 2/tolerable and 3/acceptable. The last risk reviewed in Oct 2017. Overall audit results are acceptable.

Emergency / the existing system defined in the documented procedure / 3-PR-TKA-09-001, Rev. 01. There are 9 scenarios (fire or exploration, serious human accident, oil spillage, bomb terrorist threat, mobilization of assistant means for another entry, road accident, man missing, mass casualty and major natural disaster.

Overall implementation results of emergency preparedness and response of 9 emer-gency situations are acceptable; cut off statistics since Oct 2018.

Internal audit and man-agement review

The organization measures MS implementation, maintenance and effectiveness by means of annually scheduled system audits. The organization reliably carries out these audits.

Internal audit - Organization has been maintained an internal audit as per defined in Procedure 2-PR-HSE-11-001, Rev.04 by yearly (12 months). The last internal audit done in Sept 2018 as planned covering both Offshore and Onshore. Auditor verified the list of qualified auditors (Mr. Ayar Min., Mr. Soe Oo Kyan, Mr. Zaw Min Aung and Mr. Lu Lu Tin.)

The internal audit has no NC raised, however, there are around 20 OFI concerned Waste management, Noise and SDS.

Top management reviews the organization’s environmental management system at regular intervals and in line with the requirements to ensure its continuous suitability, adequacy and effectiveness. The management review of 2018 was carried out in accordance with the requirements and was effective.

Use of certificate and logo

The logo and the certificate are used in compliance with the requirements. This has been checked by sampling. The sampling included business cards, company bro-chures or websites or others.

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Rev. 20180910 Page 17/17

Chapter of standard 4.1 4.2 4.3 5.1 5.2 5.3 6.1 6.2 7.1 7.2

Rating*) 1 1 1 1 1 1 1 1 1 1

No. of nonconformity - - - - - - - - - -

Chapter of standard 7.3 7.4 7.5 8.1 8.2 9.1 9.2 9.3 10

Rating*) * 1 1 1 1 1 2 1 1 1

No. of nonconformity - - - - - - - - -

* Rating: 1 = conforming

2 = not audited in this audit

3 = failed/nonconformity (see nonconformity report))

4 = not applicable

Environmental Monitoring Report - TotalEnergies

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