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.. - ' Seven Energy International Limited ("SElL")/Accugas Environmental Impact Assessment Supplement In Support of the Application for an IDA Partial Risk Guarantee Under the Nigeria Electricity and Gas Improvement Project April, 2013 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

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Page 1: World Bank Document€¦ · • Minimise condensate from pigging operations and dispose of them appropriately. • Undertake good in-house practices to control domestic/industrial

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Seven Energy International Limited ("SElL")/ Accugas

Environmental Impact Assessment Supplement

In Support of the Application for an IDA Partial Risk Guarantee

Under the Nigeria Electricity and Gas Improvement Project

April, 2013

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Page 2: World Bank Document€¦ · • Minimise condensate from pigging operations and dispose of them appropriately. • Undertake good in-house practices to control domestic/industrial

1. TABLE OF CONTENTS

2. FOREWORD

3. ANNEX 1: CHAPTER 6 SUPPLEMENTARY ANNEX 1 A: CHAPTER 7 SUPPLEMENTARY

4. ANNEX 2: PIPELINE SCHEDULES

ANNEX 2A: FEDERAL MINISTRY OF ENVIRONMENT FINAL APPROVAL OF THE EIA

5. ANNEX 3: EMERGENCY RESPONSE GUIDELINES FOR COMMUNITIES ANNEX 3A: CATHODIC DESIGN PROTECTION PHILOSOPHY ANNEX 3B: PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

6. ANNEX 4: UPDATED GRIEVANCE MECHANISM

7. ANNEX 5: DISCUSSION OF ESI MAP ANNEX SA: ENVIRONMENTAL SENSITIVITY INDEX MAPPING FOR THE ROW

8. ANNEX 6: ALTERNATIVE PIPELINE ROUTES FOR UQUO -USUNG PIPELINE ANNEX 6A: WILDLIFE/INVERTEBRATE FAUNA ANNEX 6B: ALIGNMENT OF THE UQO-USUNG GAS PIPELINE

9. ANNEX 7: SEPTA SOP FOR HYDROTESTING

10. ANNEX 8: CHANCE FIND PROCEDURE

r

Page 3: World Bank Document€¦ · • Minimise condensate from pigging operations and dispose of them appropriately. • Undertake good in-house practices to control domestic/industrial

FOREWORD

This document has been prepared as a supplement to the Environmental Impact Assessment (EIA) report of the Uquo to Oron gas pipeline project, approved by the Federal Ministry of Environment, to meet the safeguards requirements of the World Bank.

Accugas Limited hereby undertakes the obligation to construct and operate the pipeline in accordance with the mitigation and monitoring measures and health and safety provisions it contains, in addition to the measures detailed in the approved EIA.

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/

SEPTA ENERGY. Partners In Performance

CHAPTER SIX

MITIGATION I CONTROL MEASURES

(A) Environmental

6.1 Introduction

The rationale for impact quantification and significance has earlier been discussed in the

previous chapter. The results indicate that various components would be impacted

positively or negatively. In order to preserve the present integrity of the environment

certain steps have been recommended to mitigate or control the major negative impacts

identified in this study. The control/mitigation measures have been based on the

baseline conditions with regards to the biophysical environment, socio-economic and

health status of the host communities. Also considered were the project activities and

their envisaged impacts and concerns of stakeholders during consultation meetings,

community contacts and socio-economic/health status of the host communities.

6.1.1 Planning Phase

Septa Energy shall:

• Pay adequate compensation for the land take and farmlands in line with Septa

Energy procedure and Federal Government Land use Act.

6.1.2 Site Preparation

Septa Energy shall:

• Use route of minimal environmental impact for site survey.

• Enforce "no hunting of game animals" during site preparatory activities.

• Manually dislodge sedentary animals on the ROW and relocated them in

similar habitats.

• Avoid excess land take and minimize bush clearing during site survey.

6.1.3 Construction Phase

Septa Energy shall:

• Use equipment, which emit low levels of noise with acceptable exhaust gases, which

conform to National standards and Septa Energy specifications.

• Enforce proper waste management practices and good in-house sanitary practices for

base camp workforce.

• Carry out major construction/civil works during dry season or provide silt curtains to

control suspended particles in construction run-offs during the wet season.

Final Report (Supplementary) January 2013 6-1

,

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SEPTA ENERGY. ENVIRONMENTAL IMPACT ASSESSMENT OF UQUO-ORON NEAR ORON GAS PIPEUNE PROJECT AKWA IBOM STATE

• Reduce river and road crossing for pipeline, and plan for run-offs resulting from

project activity during wet season.

• Reduce time frame between clearing, trenching, pipe laying, and backfilling/re­

vegetation.

• Prevent intruders' and inquisitive onlookers from work site to protect them against

welding radiations.

• Avoid interference/destruction of foreign objects such as power and

telecommunication lines.

• Use noise defenders at high noise zones.

• Educate road users on road regulations especially those involved in the project.

• Use qualified and experienced staff to undertake project.

• Reduce to the barest minimum contamination of soil, water and vegetation, with

liquid fuel/lubricants from machines and vehicles during refueling.

• Guide road users on days for moving equipment etc.

6.1.4 Pre-commissioning Phase

Septa Energy shall:

• Enforce the installation of cathodic protection devices on the pipes to maintain their

integrity/prevent corrosion.

• Use qualified/experienced staff for test running of facilities during the pre­

commissioning phase.

• Use appropriate PPE including ear defenders at high noise zones.

• Place/caution signs on all pipeline road crossings.

6.1.5 Operation Phase

Septa Energy shall:

• Ensure regular maintenance of machines and right of way for pipeline.

• Minimise condensate from pigging operations and dispose of them appropriately.

• Undertake good in-house practices to control domestic/industrial wastes.

• Use machines of required specification to reduce noise and noxious exhaust gases.

• Enforce the use of ear defenders when working in areas with high noise levels (80-90

dB(A)).

• Instal! catalytic, converters and scrubbers to reduce the concentration of N02 and

S02 which would otherwise enhance corrosion

• Use pressure reducers, automatic pressure control valves (PCVs) along the pipeline

route to reduce the incidence of gas venting.

• Undertake regular maintenance of equipment to sustain their efficiency.

• Provide security for facilities to prevent vandalisation.

Final Report (Supplementary) January 2013 6-2

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SEPTA ENERGY. Partners In Performance ENVIRONMENTAL IMPACT ASSESSMENT OF UQUO·ORON NEAR ORON GAS PIPELINE PROJECT AKWA IBOM STATE

• Keep residential areas within safe distance from pipeline.

6.1.6 Decommissioning and Abandonment Phase

Septa Energy shall:

• Re-vegetate all bare areas including the ROW and restore site.

• Educate/guide road users on days of movement of dismantled parts.

• Place caution signs on roads which would be obstructed/diverted during haulage of

equipment/parts/old pipeline.

• Keep a clean environment after the decommissioning and abandonment.

---:--:----:-:~---··--·-······"······---

final Report (Supplementary) January 2013

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SEPTA ENERGY. Partners In Perk:Jrmance ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPEUNE ROW BETWEEN UQUO AND ORON NEAR USUNG

Table 6~_1: Summary of Identified Impacts and Proposed M!~g_ation M~.~!Jre~ Project Phase Project Activity Environmental Potential/ Associated Impacts Mitigation/Control Measures Timing/ Action Party

Comoonent Pre- construction Land acquisition Soil, Vegetation Loss of land, loss of economic crops, Septa Energy shall: During land take/SEPTA ENERGY

Increase in income . Compensate communities for landtake and farmlands.

Site Survey Vegetation, Soil, Vegetation removal exposes soil to Septa Energy shall: Bush clearing/SEPTA ENERGY Soil Testing Wildlife weather conditions. Migration of wildlife . Use existing route/path for i I Bush Clearing I site survey.

i . Avoid excess landtake and minimize bush clearing. . Enforce no hunting ban during bush cleaning . Manually relocate the

sedentary organisms or

allowed to migrate to join

existing populations through

selected corridors on the sides

of the ROW with similar

! habitat

• Construction Phase Trenching Soil Such as communication cables/fibres Septa Energy shall: Trenching/SEPTA ENERGY

• Plan to prevent damage to

! foreign bodies roads etc. . Undertake trenching with care.

Water System Change in water quality due to inflow of Septa Energy shall: Trenching/SEPTA ENERGY run-offs, suspended particles etc. . Plan for run-off into water

bodies/rivers by using silt trap to remove

-------··· ···--·· sedimentsL[!articl~,--: Air Quality Changes in noise and exhaust gases Septa Energy shall: Trenching/SEPTA ENERGY

from excavators. Increase in dust . Use equipment, which emits during the dry season. Temporal road obstruction/ diversion low exhaust gases, and noise,

which conform to National standards and Septa specification. . Use ear defenders in high

·-·

Final Report (Supplementary) January 2013 6·4

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SEPTA ENERGY. Partnersln Performance ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG

!-=:-.--·····-·-· ! noise zones Pipe laying I Exposure of welders to heat and light SeptaEnel-gy shall: Pipe laying/SEPTA ENERGY

radiation. Integrity testers exposed to • Prevent intruoers/inquisitive X-rays. on-lookers from work site to protect them against welding radiation. . Protect integrity testers from exoosure to X-rav.

Back filling Soil, water systems Increase in turbidity due to exposure of Septa Energy shall: Pipe laying/SEPTA ENERGY soil surface run-offs carrying sediment • Carry out excavation during Alteration drainage pattern due to

the dry season or provide silt l changes in topography and improper traps to control impact on re-instatement water system. . Reduce water crossing for pipeline ROW plan for run-offs during wet season.

• Undertake proper re-instatement procedures after backfilling exercise to

I maintain existing drainage I pattern. Restrict the landtake

to selected areas tor the various facilities. . Use noise defenorers at high noise zones --

Operations of Air Quality, Noise Emission of exhaust gases from the fuel Septa Energy shall: Construction/SEPTA ENERGY machines and combustion engines can alter the local . Use equipment, which emits vehicles ambient air quality. Soil contamination

and loss of aesthetics from liquid leaks low levels of noise, and exhaust gases. . Ensure no contamination from machines and vehicles to soil . Use ear defenders in high noise areas.

Tie-in of the Noise, air quality, Changes in noise level and exhaust Septa Energy shall: Construction/SEPTA ENERGY pipeline to the Soil gases from machines

Use equipment, which emits 1 NDPHC 24" .

I pipeline to low levels of noise, and

Calabar at Usung exhaust gases. • Ensure no contamination from near Oron and

machines and vehicles to soil I ;ook-op of Use ear defenders in high noise Toromont gas facility areas --~------------ --- i ----

Final Report (Supplementary) January 2013 6-5

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SEPTA ENERGY. Partners lnF!eriJ:xrna.ncJ ... __ _ ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG -·-

Base camp Vegetation, soil, Domestic waste from base camp shall Septa Energy shall: Base camp/SEPTA ENERGY water alter the water quality if dumped in • Enforce implementation of

water system. Poor aesthetic if it is proper waste management dumped on soil and vegetation plan and good in-house

sanitarv practices. Pre-Commissioning Pressure testing, Water, Soil, Air Maintain the integrity of pipelines and Septa Energy shall: Pre-commissioning/SEPTA

cathodic quality prevention of corrosion. Pressure test Treat hydrotest water and ENERGY

protection water can contaminate soil and water. • dispose responsibly.

Increase in temperature due to thermal . Enforce the installation of Lightening Air quality loading or discharged hydrotest water.

cathodic protection devices to conditions lightening maintain the integrity of

- _.eipeline. --Operation Pigging Soil, water Contamination of soil and water system Septa Energy shall: Pigging/SEPTA ENERGY

! with condensate Contain oily condensate 1 •

sludge using sealed skip and I treat in DPR aooroved TDU I

l Disposal of Soil, water, Odour and aesthetic devaluation may Septa Energy shall: Waste generation/SEPTA industrial and vegetation. result from improper handling. Increase Enforce good in-house ENERGY domestic wastes in disease if dumped in water. Odour •

practices to control domestic and industrial waste; enforce the implementation of a waste

Gas leaks Air quality Increased incidence of fire management plan at site. Septa Energy shall: . Make contingency for fire

-------· I out:b...r.:eak. Maintenance ·soil; water, air Occurrence of work place accidents I Septa Energy shall: Maintenance/SEPTA-ENERGY

quality during operations due to lack of . Ensure regular maintenance maintenance, or during maintenance as

of machines and ROW. a result of human error. Extensive, • Use skilled workers for liquid spills (lubricants, fuel, chemicals). maintenance and operation Release of gases through isolation valves or equipment failure. exercise.

Decommissioning Decommissioning Land use, Soil, Return of land to indigenes for farming; Septa Energy shall: Decommissioning/SEPTA Vegetation Increase in income, re-vegetation of . Re-vegetate all bare areas ENERGY !

areas previously occupied by structures. and restore site to original Contamination of soil/vegetation by land use by adopting SEPTA

1•"~'· ":"'"' •goo3m ENERGY procedure. l . Keep a clean environment I

l after the decommissioning I -------and abandonment

Final Report (Supplementary} January 2013 6-6

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SEPTA ENERGY---~~~~~~~==~~~~~~~~==~~77~Ba~n~., ~!'I~!RON~ENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO ANO ORON NEAR USUNG

B. Socio- Economic

Mitigation measures are measures designed to address the impacts of projects. The

measures are largely a function of the adverse social impacts of projects since it is such

impacts that require mitigation. The expected impacts of the Proposed Gas pipeline

Project include the following:

• Demographic Impacts (influx of people into project area).

• Socio-economic Impacts (redirection of labour, inflation).

• Impacts on Lifestyles (sexual laxity, alcoholism, youth militancy).

• Impacts on Cultural Properties (religious sites/shrines, etc).

• Impacts on Social Infrastructure (schools, health care facilities, water supply).

• Impacts on natural resources (land uptake, destruction of vegetation and farms).

The usual practice is to differentiate these impacts for purposes of analysis. However, In

reality they tend to be closely interrelated. For example, an increase in population

(demographic impact) can increase pressure on natural resources and social

infrastructure. Project activities will be very visible and transient in the pipeline

communities during the construction phase. They will be much less visible in these

communities during the operation phase. This low visibility should not be seen as

reducing the stake of the pipeline communities in the project. The company would

continue to sustain consultation with these communities after the construction phase for

the maintenance of good community relations.

Mitigation Measures

The possible adverse social impacts of the project were spelt out in the previous chapter.

These impacts were derived from experience elsewhere and from the views of

respondents in the host communities of the gas pipeline project. The impacts provide

the basis for the articulation of appropriate mitigation.

Relevant measures needed at each stage of the project, i.e. construction, operation and

decommissioning are indicated in the discussion.

Final Report (Supplementary} January 2013 6-7

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• SEPTA ENERGY. Partners In F'erformance

ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG

T bl 6 2 K M"t" t" M a e . : ey I 1ga IOn easures

Impacts Mitigation Measures

1. Population growth due to in-migration Septa Energy shall:

a. Use local labour as much as possible

2. Redirection of labour from agriculture Septa Energy shall:

a. Make provision for agricultural inputs b. Organize farmers into cooperatives.

3. Inflation in the local economy Septa Energy shall:

a. Make provision for agricultural inputs b. Organize farmers into cooperatives.

4. Pressure on local infrastructure Septa Energy shall:

a. Use local labour as much as possible in order to minimize additional demand for infrastructure

b. Reduce impact on local infrastructure

5. Destruction/Loss of farms Septa Energy shall:

a. Pay adequate Compensation for land take and farmlands

6. Deforestation Septa Energy shall:

a. Minimize land take and use existing ROW as much as possible. b. Facilitate reforestation

j /. '-"'-"'"''-'" ""'" Ul KVVV Septa Energy shall: Liaise with Government and security agencies at all levels

8. Youth militancy/unemployment Septa Energy shall:

Undertake youth empowerment and public enlightenment.

Table 6.2 shows the major mitigation measures required to address each impact.

Population growth, consequent on in~migration, which will be particularly a feature of the

construction phase in all the project areas and the operation phase, may be addressed

through the use of local labour as much as possible. This approach is necessary in order

not to create disaffection in the communities since the local people will find it difficult to

understand why a project located in their area should be beneficial to strangers rather

than themselves. In the decommissioning phase where local labour earlier engaged may

become unemployed, skill acquisition programmes will be necessary.

The mitigation measure of engaging local labour, as Table 6.2 indicates, applies to

several of the impacts. Farmer/farm relocation and compensation are very sensitive

issues that need to be addressed after effective consultation with, and participation of

the local people. Where displaced people are not satisfactorily compensated, the

consequent discontent will adversely affect the effective operation of the project.

Final Report (Supplementary) January 2013

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SEPTA ENERGY. Partners In Performance ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG

c. Health

Some of the activities involved in all the phases of the pipeline project have some

significant adverse potential health impacts. The adverse health Impacts will require

appropriate mitigation measures while the beneficial health impacts will be enhanced.

The proposed mitigation/enhancement measures for the respective impacts are

summarised as follows:

Impairment of health/safety

The focus here is on the health of the communities and the workforce.

The health facilities in the communities will need to be expanded and strengthened with

regard to:

• Number of doctors, nurses, pharmacists, and other paramedical staff in some of the

existing hospitals, and primary health care centres;

• Maintenance of existing infrastructure

• Sustain the supply of vaccines for immunization against communicable diseases,

especially the childhood diseases;

• Maintenance of accurate health statistics through further training;

• Disease control through monitoring and surveillance programmes.

Environmental Sanitation/Waste Management

The objective here is to achieve proper management of refuse, sewage and vectors of

diseases. The Environmental Health Unit of each Local Government Area should be

empowered to manage this.

Refuse Management

The current unsatisfactory refuse management needs to be overhauled. The proffered

mitigation measure includes:

Collections of refuse by households and deposited at designated sites, local councils to

collect from such sites and manage appropriately. The ultimate goal is refuse collection

in waterproof polythene bags in each household. Biodegradable organic matter should be

collected in a separate bag from that of non-biodegradable materials (cans, plastics,

glass etc.). The biodegradable matter can be used for compostlng while the non -

biodegradable can be sold for recycling.

Sewage

The use of sanitary latrines should be encouraged. Households should be encouraged to

use flush toilets with septic tanks. The contents of the septic tanks should be removed at

regular intervals treated and disposed of appropriately.

Final Report (Supplementary} January 2013 6-9

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SEPTA ENERGY. Partners lnPedormance

Disease Vectors

Vectors of disease such as malaria can be controlled by use of bed nets, and spraying of

rooms with insecticides, proper sanitation measures such as clearing of bushes around

houses, elimination of stagnant pools of water and construction of drain channels and

destruction of breeding sites for mosquitoes.

Water Quality Impairment

Boiling and filtering of water for drinking should be encouraged. The ultimate measure is

the provision of regular potable water, accompanied by hygienic practices in homes.

Noise

The present low noise level (38 - 68) dBA should be sustained. In the project area,

excessive noise from heavy machinery used in construction activities requires mitigation

as follows:

• Ear protection devices (muffs) should be provided and worn by construction staff

within the working zone.

• Provide functional acoustic environment in campsites lodgings near construction

sites.

• Silencers and mufflers on the exhaust systems of construction equipment.

• Deploy low noise type equipment

• Execute noisy operations during the day rather than at night.

Housing

Housing shortages will become more acute with influx of people into the communities.

The problem associated with housing can be solved by:

• Encouraging private housing development by investors by supporting them.

• Septa Energy or sub-contractor to provide housing for its field staff by managing a

base camp

• Planned development of available land to be encouraged with the assistance of the

Department of Town Planning, Local Government Councils, and State Government.

• Education on overcrowding and spread of contagious diseases

Health Education

Most of the mitigation measures recommended up to now need proper health education

to succeed (e.g. control of infectious diseases, sanitation etc). Success of the health

education programmes depends on the Involvement of health education specialist to

develop suitable materials and train participating staff.

Final Report (Supplementary) January 2013 6-10

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SEPTA ENERGY. Partners In Performance

The health impacts discussed above shall be reduced to the barest minimum when

indigenes are engaged in the project.

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-~-"'-.

SEPTA ENERGY. PartnerslD Performance ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG

Table 6.3: SAFETY ANALYSIS (SAFAN) WORKSHEET

Item Type of Exposure situation Information required for Recommendation Action party Hazard assessment (Kevword)

..... ---.-· 1 Explosion Pressure -

Generators -Stringing of pipes/ Use of torque tools Installer Welding -

-Operator

Hazardous areas to be demarcated ·-·~---..

2 Physical Danger Site construction

1 Personal protection to be used Personal protection equipment to be provided

I I Designer/Installer

I Install warning notices "Danger, this machine starts

1 automatically" !

-----·--··-

L3 __ .......... Radiations 1 Personal protection equipment x-rays - Operator --- -------- Radio active - I

Final Report (Supplementary) January 2013 6-12

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SEPTA ENERGY~ Partners In Performance ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG

HAZID WORKSHEET GUIDE WORD POTENTIAL HAZARDS AND THREATS CONTROLS DEVELOPMENT PHASE P*

EFfECTS Proximity to Damaging noise Proximity to host community 1. Acquire suffident land Acquisition I Design and L population 2. Acoustic enclosure Construction

! Adjacent Land Materials storage yard Effluent/oil discharge, Adequate land and good Design/Operation L

I Use Storage of combustible and 1 waste management.

Host community farm flammable materials. I Layout design, Design

I Community interference M

I Compensation process Acquisition/Construction Acquire sufficient land.

1----I 1 Environmental Low steady noise (levels<85dB) Community Buildings Design philosophy Construction H r ,,,.. l

ocial issues Local attitude Community interference 1. Access control Design and Construction I M 2. Community Assistance l

Proiects ! - --~-.--~--

Supply Road • Driver competence . Training Procurement/Construction M Support Transport hazards • Journey Management • Journey management

procedure . Weather condition . Compliance with pre-. Road condition mobilisation standards . Vehicle condition . Maintenance Philosophy . Traffic condition . Compliance with road • Lighting condition safety regulations c----

Storage Hazards . Falling objects • Compliance with Design and construction M storage and material . Heavy loads handling procedures

• Poor spacing • Dedicated storage yard • Unauthorised entry with access control . Handler competence • PPE

• Training

P* = HSE priority H =High severity M = Medium severity L = Low severity

Final Report {Supplementary) January 2013 6-13

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SEPTA ENERGY~ PartnerslnPertormance ·-----------ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPELINE ROW BETWEEN UQUO AND ORON NEAR USUNG

HAZID WORKSHEET GUIDE WORD POTENTIAL HAZARDS AND THREATS CONTROLS DEVELOPMENT PHASE P*

EFFECTS Contaminated Contaminated Ground . Rain Compliance with spill Construction M Ground Contaminated ground water . Micro-organisms control procedures.

1 Odorous compound • Soil permeability Soil investigation

i . Odorous compound Work procedures

Construction Transportation hazards ! • Rain, Muddy terrain Compliance with Construction & Operation rM timing (Wet ' . Wet ground transportation procedures

1

season) Materials handling • Cloud Flooded roads ' .

Construction Excavation hazards • Rain Develop job hazard analysis Construction M timing (Wet Compaction hazards . Muddy terrain season) • Wet ground

• Flooded site Welding hazards Wet working environment Develop job hazard analysis Construction M

Use qualified welders ·-Erosion Poor drainage Soil investigation Design & M

Site topography Drainage systems to Construction Soil aeo!oav standard specification -=--- ·--

Construction ! Transportation hazards . Dust Compliance with Construction M timing (Dry I . Harmattan driving/working procedures season) High Temperature • Heat, thermal

expansion Machine Inadequate protective measures Operators exposure . Close supervision on Construction & Operation M

Operator Inadequate provision site protection Wrong use of PPE • Compliance with

I Non standard PPE regulations on PPE

I Communication • Staff induction and

I training

I • Compliance with SEPTA ENERGY HSE policy

Final Report (Supplementary) January 2013 6-14

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SEPTA ENERGY. .eactnersc.!LIInL:.!Per!or;.a.LI.tLma!J..JJaLincews;;L--_____ _ ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPEUNE ROW BETWEEN UQUO AND O:::.R::O:::.N:::::,N::E::.A:::.R::_U:::S:::U::.:Nc:.G=----------------------­

HAZID WOKSHEET

GUIDE WORD THREATS CONTROLS DEVELOPMENT PHASE P* POTENTIAL HAZARDS AND EFFECTS I Tie-in I Excessive nitrogen (for purging) I Operator error I Competence assurance I Contracting, Construction and I M I

commissioning f.--- Equipment failure Maintenance philosophy

Spurious shutdowns Un-co-ordinated construction Contractor selection Construction and I M manaqement commissioninG

Mobilization/de I Construction hazards -·--·-·· Poor pre-mobilization Inclusion of full pre- Project definition/contract and mobilization inspection mobilization inspection in the construction

terms/conditions of contract

Diseases Malaria transmitting mosquitoes Stagnant water

1 Lack of mosquitoes screen i

III health (weak anti bodies)

Follow existing mobilization procedure during construction 1. Design project site

drainage to avoid stagnant water

2. Administrative control (induction for expatriates)

3. Mosquitoes screen for building

4. Use prophylactic drugs

Design and Construction

M

M

5. Premobilisation medical certification

Food/Drinks I Catering Hazards: Food borne I Indiscriminate eating and Messing facility I Construction I M I bacteria Catering Hazards: Water 1 drinking borne bacteria 1

Alcohol, smoking, recreational l1 Unauthorised food/drink drugs vendors

I Psychological diseases

I Messing facility

Compliance with 'No Smoking' Policy, Drugs and alcohol

li . Human Immune Deficiency virus Body fluids contact Administrative control: Design construction and M Other communicable diseases i induction and briefings operation

Blood transfusions

I Personal hygiene

L,-,---:-:-==:---:---:-.L----------:-::---:-:c::--:-J Inadequate sanitary facilities

P* = HSE priority H = High severity

Endemic situations

Final Report (Supplementary) January 2013

Medical retainership and site clinic for all workers Awareness campaign Provide sanitary facilities to standard specifications M = Medium severity

Design and construction

L = Low severity

I M

l ---

..

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I I

i

SEPTA ENERGY- ParlnersJn PertamanaJ ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPEUNE ROW BETWEEN UQUO AND ORON NEAR U~:.:U:.:.N.:.:G=-----------------­

HAZID WORKSHEET GUIDE POTENTIAL HAZARDS AND THREATS CONTROLS l DEVELOPMENT PHASE WORD EFFECTS I

Physical Loud steady noise Equipment selection Safety procedures at the Commissioning & Operations work site Acoustic enclosure PPEs for specific work areas

Ionising radiation Radiographic activities Compliance with PTW Construction proc..~~ures

Physical Ergonomic hazards: Incompatible Poor design Integration of ergonomic Construction & Operations hand controls specifications standards in project Awkward location of work places and specifications machinery Lighting of work stations Long and irregular working hours and Poor organisation Administrative control shifts Indoor climate & high humidity Ventilation and air

.. cpnditionino Physical Lighting of work stations Poor design Integration of ergonomic Construction

Long and irregular working hours and specifications standards in project shifts specifications Indoor climate & high humidity

Administrative control Poor organisation

Ventilation and air conditionino

Level of Indigenous competence Unrealistic demand from Compliance with existing Construction indigenous host community guidelines on labour Training employment

HSE awareness of local Induction requirements, labour force training and close

suoervision I I --

P* = HSE priority H = High severity M = Medium severity l = low severity

Final Report {Supplementary) January 2013

P*

M i

M

M !

__ ,_,.

M

H

-1

6-16

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SEPT~~ ENERGY:_ ··- PartnerslrlPBtlrxrnance .. ·-ENVIRONMENTAL IMPACT ASSESSMENT OF GAS PIPEUNE ROW BETWEEN UQUO AND ORON NEAR USUNG

HAZID WOKSHEET GUIDE WORD! POTENTIAL HAZARDS AND THREATS CONTROLS DEVELOPMENT PHASE P* •

i EFFECTS ' External Environmental hazards Construction works Comply with Design and construction M •

Environmental environmental assessment I

constrain_t.s recommendations Hazard and Hazard studies, HSE case, Hazards Low awareness 1. Apply structured Design and construction M

.

Effect and Effect register, Project Controls review techniques Management Poor application tools (Detailed HAZID, Process HAZOP, SAFOP, (HEMP) Inadequate expertise to FIREPRAN, EA, pre- '

deploy HSE start-up audit etc) to management tools design and

construction 2. Comprehensive

I Review at Design •

stage 1 Recovery Poor organization I job design Inadequate medical Medical facility (first aid) Construction L I Measures attention Medical retainership

Insufficient stock of clinic/doctor medication Site medical facilities

j Faulty firefighting Equipment routine tests

I equipment Fire fighting {operator) Training Construction L incompetence Inadequate spill clean- Compliance with up support emergency response Construction L Security operatives procedures incompetence. Training

I -Recovery Poor organization I job design Inadequate security Provision of adequate level 1 Construction L Measures of security equipment

Incompetence inventory

--·- Training Obscure muster point : Visible muster point Construction M

I Inadequate MEDEVAC 1 Provide MEDEVAC Provision I Facilities

- ·-

P* = HSE priority H = High severity M = Medium severity L = Low severity

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SEPTA ENERGY- Partners In Petformaace

CHAPTER SEVEN

ENVIRONMENTAL MANAGEMENT PLAN

7.1 Introduction

The project specific Environmental Management Plan is one of the key components

within company's Environmental Management System that clearly defines the proposed

project initiatives to ensure protection of the environment and all affected stakeholders

from the construction and operational activities. The programme will form the key

reference document for ensuring that environmental issues are addressed and would be

fully communicated· to all project staff, and contractors involved in the project. The

environmental management plan has been developed to meet the following specific

plans which shall be put in place to manage the project environment.

(1) Project Environmental Impacts/Mitigation Plan; Potential project environmental

impacts have been identified in this EIA along with mitigation measures through

engineering design or by site management during construction and

commissioning activities identified.

(2) Project Environmental Monitoring Plan for identified impacts.

(3) Measures to mitigate identified impacts

(4) Social & Health Management plan

(5) Noise control plan

(6) Waste management plan

(7) Contingency plan

(8 Audit Plan

(9) Training Plan

(10) Abandonment & Rehabilitation Plan

Detailed environmental procedures will be developed as the project progresses from

design through construction to operation. The plans and procedures would be co­

ordinated by the project Environmental Advisor and distributed to the Engineering team.

Best practices to protect the environment would be adopted. During the construction,

operational and decommissioning phases of the project the detailed environmental plans

will form the basis against which audits will be conducted in the field.

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7.1.1 Demonstrable Management Leadership, Planning, Commitment and

Review

Management and supervision shall be regarded as being fully committed to HSE by all

staff and contractors. They are to be seen as providing a leading role towards constant

improvement through leadership and action planning. Management shall regularly review

the suitability and effectiveness of the system.

7.1.2 Policy and Strategic Objectives

Contractors involved in the project shall have a written HSE policy, covering the Septa

HSE Policy elements as a minimum.

HSE objectives shall be challenging, and understood by all and consistently incorporated

in policies.

In setting objectives, management shall consider the overall risk levels of its activities

and identify those critical operations and installations which require a fully documented

demonstration that risks have been reduced to as low as reasonably practicable (ALARP).

7.1.3 Organization and Responsibilities

The organisation and resources available within SEPTA Energy, NIPP, FOL and other

interest groups shall be adequate for its purpose. Responsibilities at all levels shall be

clearly described, communicated and understood. Staff shall be developed following

structured competency assessment and training systems.

7.1.4 Hazards and Effects Management Process

The process for those critical operations and installations shall include:

• An inventory of the major hazards to the environment and to health and safety of

people of all the activities, materials, products and services.

• An assessment of the related risks, implementation of measures to control these

risks and to recover in case of control failure.

Health risk assessment shall address physical, chemical, biological, ergonomic and

psychological health hazards associated with work.

Environmental {impact) assessment (including a consideration of social impacts) shall be

conducted prior to all new activities and facility developments, or significant

modifications to existing ones.

Product stewardship shall be applied at all stages of product life cycle relevant to the

company's activities.

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SEPTA ENERGY- Partners In Performance

7.1.5 Standards, Procedures and Document Control

Adequate standards and procedures shall be in place and understood at the appropriate

organizational levels. Preparation, review and distribution of all key reference

documentation shall be adequately controlled.

Emergency response procedures (including medical emergencies) shall be regularly

tested.

7.2 Environmental Management Plan

Objectives of Environmental Management Plan

The Environmental Management Plan has the following specific objectives:

• The adoption of a systematic procedure to ensure that the Project activities are

executed in compliance with all applicable legislations and SEPTA HSE (and other)

policies and guidelines;

• Demonstrate that mitigation measures for all impacts and effects have been put

in place and that the measures shall be adhered to throughout the project

development life cycle;

• Demonstrate that effective recovery measures for managing 'lost control'

situations are in place throughout the Project life cycle;

• Establish a structure that will ensure compliance by SEPTA, Accugas and its

Contractors with the EMP.

7.3 Social Management Plan

This is essentially concerned with the social action plan (SAP) for the host communities.

SAP consists of measures designed to mitigate the adverse social impacts of projects.

Among other things, SAP lists mitigation measures, the means by which the measures

will be implemented, the time schedule for the implementation, as well as the

implementing agency. SAP is therefore based on clearly identified mitigation measures.

These measures are usually designed in collaboration with host communities in order to

engender a sense of ownership. This can be achieved by holding wide-ranging

discussions with cross sections of the communities. This is necessary for the success of

the measures.

Mitigation

It is clear from literature and from experience that development projects do generate

some adverse social impacts, in addition to other positive effects. Mitigation measures

are therefore designed to address the adverse impacts. The mitigation measures for the

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respective adverse social impacts were spelt out in previous chapter. On the basis of the

proposed mitigation measures, a proposed SAP is provided in Table 7.1:

Goals Actions Implementing Agency Time Frame/Phase

1. Stem population a. Initiate skill acquisition Personnel Department in Site preparation, construction and pipe

growth due to in- programme for the locals conjunction with local laying migration b. Recruit and train locals organisations

for project jobs.

2. Minimize the depletion a. Meet with farmers or Community Relations Site preparation, construction and pipe

of the farming farmers' groups. Department laying population and b. Assist with agricultural agricultural production extension service.

c. Subsidize agricultural inputs

3. Ensure the availability a. 2a, b and c above Community Relations Site preparation, construction and pipe

of commodities and curb b. Facilitate the Department laying inflation transportation of goods

and services

4. Ease pressure on local a. 1 a and b above Personnel Department. Site preparation, construction and pipe

infrastructure b. Expand or improve Community Relations laying existing infrastructure Department (e.g. water supply) c. Provide infrastructure for project staff

5. Minimize disruption of a. Relocate farms and Community Relations Site preparation, construction and pipe

means of livelihood farmers where necessary. Department laying b. Pay compensation where necessary

6. Curb deforestation due a. 1 a and b above in Community Relations Site preparation, construction and pipe

to demand for fuel wood order to minimize Department laying additional demand for fuel wood b. Initiate reforestation programme.

I' Site preparation, 8. Reduce the potentials a. 1 a and b above Community Development construction and pipe for youth militancy and b. Facilitate the Department laying and operation disruptive activities strengthening of public

safety Institutions. HSE Department c. Cultivate good community relations

Table 7.1: Proposed Social Action Plan

Location

The Location of the activities would depend on the nature of the activity in question.

For 1 (a) and (b), recruitment should be coordinated at the District or Local

Government Headquarters, while training can either take place in the

Headquarters or wherever Septa Energy has the facility, depending on the level of

training required.

2 (b) and (c) should be coordinated in the District or Local Government

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Headquarters.

3 (a) and (b): Same as (2) above. The activity may involve upgrading or

rehabilitation of roads.

4 (a) and (b): To be coordinated at the District Headquarters and the Local

Government Headquarters. Work on infrastructure should be in all sizeable host

communities.

5 (a) and (b): To be coordinated at the District Headquarters and Local

Government Headquarters. Relocation and compensation should take place in

the affected host communities.

6 (a) and (b) to be coordinated in the Local Government Headquarters.

Reforestation should take place in affected host communities.

7 (a) and (b): To be coordinated in the Local Government Headquarters. The

health education pr~gramme should take place in all host communities.

8 (a): To be coordinated in the Local Government Headquarters. 8 (b): To take

place in local police stations.

Monitoring and auditing

The monitoring and auditing of the activities can be handled by the same team. The

auditing functions should consist of examining the number, state and efficiency of the

activities while they are being put in place. On the other hand, the monitoring function

will involve periodical checks to ensure that the activities/facilities are working properly.

The monitoring and auditing programmes should involve visits to activity sites/host

communities, in conjunction with local/community leader.

Monitoring is particularly necessary in the case of youth militancy and disruptive

activities. The experience in other parts of the country, particularly the Niger Delta

region, has shown that militancy and the associated disruption of activities usually

emerge gradually. The implication is that with effective monitoring any discontent could

be effectively addressed before it becomes disruptive.

7.4 Health Management Plan

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To address the health problems enumerated above, a health management plan is

incorporated into the project plan (Table 7 .2). The health management plan provides the

measure of assessing the accuracy of the project impact and monitoring of the

effectiveness of the proposed mitigation measures. The present relatively low health

status of the communities would be improved if the mitigation measures suggested

below are implemented.

Table 7.2: indicators

Recommended health intervention activities and performance

Health intervention Phase Performance indicators Time frame Action party activity Formation and meeting of All Activities of community- Quarterly Community Community Health Health Dev Committees Leaders Development Committees Provision and equipment All Number of Health facilities At inception Government, Septa of Health facilities with adequate Energy

infrastructures Health education All Number of community- Quarterly Government, Septa on common health Based Health Education Energy problems especially activities carried out HIV/AIDS Provision of safe water All Number of communities Yearly Government, Septa

with functional potable Energy, Community water supply system development

committee Provision of toilet facilities All Number of toilet facilities Quarterly Community

per community development committee

Train and equip Operational Number of communities Quarterly Government, Septa Community selected with functional VHWs Energy, Community Volunteer Health development Workers(VHWs) committee

7 .s Project Specific Waste Management Plan

The Plan will include procedures for safe handling, control and disposal of projected

generated waste in accordance with the company procedure.

Wastes emanating from operational activities are mainly effluents, atmospheric

emissions, spent oil and pigging wastes. These wastes shall be handled in compliance

with the Petroleum (Drilling & Productions) Regulations, 1969, Sections 25, 36 49 and

(b), (c) and (d), which stipulate inter alia that:

"The licensee or lessee shall adopt all practical precautions, including the provision of up­

to-date equipment to prevent the pollution of inland waters, rivers, creeks, water

courses, the territorial waters of Nigeria or the high seas by oil, mud or other fluids or

substances which might contaminate the water or marine life, and where any such

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pollution occurs or has occurred, shall take prompt steps to control and, if possible, end

it."

Waste Management Strategies

The strategies of waste management for the proposed project are summarised as

follows:

• To reduce the volumes of wastes generated through appropriate technology,

• To recycle and re-use wastes where appropriate,

• To treat hazardous waste and make them inert before disposal

• To ensure safe and responsible collection, separation, storage and disposal of all

wastes.

• To provide auditable records of all waste streams.

• To monitor waste disposal"activities in order to prevent future liabilities.

• To reduce the negative impact of our activities on the environment.

Waste Management Options

a) The Environmental Management activities of the Uquo to Usung Gas Pipeline

Project are to be implemented in line with Septa Energy policy on waste

management strategies arising from the project as follows:

i) Drums I Containers

Metals and plastic containers are used for a wide range of lubricants and chemicals and

they invariably contain variable quantities of residue. In order to reduce these residual

effects, the following would be considered:

~ Bulk transport and storage for high volume consumption items.

~ Refill and reuse of containers. Where possible, non-refillable containers could be

returned to the vendor for reuse or to company specializing in container

refurbishment.

ii) Industrial wastes

These include electrode studs and scrap metals, plastic caps for protection of pipeline

ends. These shall be disposed off site. Plastic caps may be reused or returned to the

vendors.

iii) Garbage - Solid Waste

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These include plastics, paper, food waste and general garbage. In the area, the plan

considers the idea to:

> Reduce packaging wastes such as paper and plastics by the use of bulk handling

systems or "big bags"

> Segregate components such as wood, plastics and paper for recycling or reuse or

incineration. Paper wastes are shredded at designated points.

> Felled tree trunks shall be donated to the indigenes for use as fuel wood.

> Compost organic garbage for agriculture.

> Sawn timber used for pipeline support shall be disposed off appropriately or allowed

to biodegrade at site.

iv) Pigging Wastes, Grit and Condensate

> Improve housekeeping procedures to reduce the volume of solids collected in water

storage tanks.

> Sludge, pigging waste condensate containing significant oil are reclaimed either on

site or off site for the removal and recovery of hydrocarbons and recycle at CPF. If

this is not possible, it will be sent to DPR approved TDU for incineration.

> Grit from pigging activities would be given to construction companies to be mixed

with bitumen for road construction.

v) Sanitary I Medical Wastes

These include but not restricted to soiled materials, used needles and syringes, expired

drugs and materials, blood and blood products, microbial cultures and stocks. The

disposal methods include incineration and burial. A waste consignment note shall cover

clinical waste disposal by contractors.

Waste Segregation Guidelines

For effective implementation of appropriate disposal methods, it is important that wastes

are segregated at source. It is the responsibility of contractors, during their operations to

provide enough clearly marked bins at strategic locations to ensure this. Particular

attention should be given to work areas where a variety of wastes are generated like

kitchen and living quarters.

The differential colour codes for the waste containers are:

• Food I vegetation .................................. Green

• Glass waste ............................................. Biue

• Plastic waste ......................................... Brown

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• General (un-useable) ......................... Black

• Medical waste (combustible) .............. Yellow

• Toner I developer.............................. White

The segregated waste shall be handled in the same way as it is handled by Eket LGA

contractors for collection and effective disposal of domestic and garden waste using the

method of landfill at various dump sites, sale of photocopier drums to scrap buyers for

reuse or recycle.

Sources and Inventory of Wastes

Wastes are expected from bush clearing, excavation, domestic wastes from base camp,

pigging and atmospheric emissions from engine exhausts.

7.5.1 Contingency Plan

SEPTA ENERGY has established a contingency plan for prompt and effective response to

emergency situations as may be detected near a public or private building or near SEPTA

ENERGY pipeline facility or explosion occurring near or directly involving SEPTA ENERGY

pipeline facility, as well as fire disaster near or directly involving SEPTA ENERGY facility.

Pipeline surveillance shall be maintained through regular patrols. The first indication of

an emergency may come from one or several sources, depending on the type of

emergency. It may come from within the Company or from outside - from employees,

customers, the public, civil authorities such as Police or fire services.

No matter what the source, an indication that an emergency exists shall be evaluated

(verified as true or proven false) without delay. If an emergency involving Company

facilities is verified, a course of corrective action shall be pursued with the utmost

diligence.

Pipeline emergencies (whether a notice is received, or discovered directly, by field

personnel) will immediately be reported to the Pressure reduction and Metering Station

Control room, which shall become the "clearing house" for information and plans

regarding appropriate responses. The control room shall be staffed to receive and record

all internal and external reports 24 hours per day, 7 days a week. The Supervisors of

control Room shall be administratively responsible for reviewing all emergency

notifications and actions taken each day. Each notification of a pipeline emergency shall

be recorded on the "Notice and Disposition of reported Happening" form, using all

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available details and information. The Control room Supervisor shall be notified of the

following emergency situations within a nominal 15 minutes (i.e., "as soon as possible")

after discovery. For this purpose, "emergency situation" is defined as any of the

following events:

• Rapture or leak in a pipeline or related facility.

• Other pipeline or related facility event which causes a public evacuation or closes

a public road;

• A serious injury to an employee or contractor that requires medical attention (or

a fatality);

• An "environmental" event that involves a reportable (or potentially reportable)

release of hydrocarbons or other chemicals;

• Any accident that has the potential to involve local, state or nationa1 media

attention.

When a possible emergency is initially identified in the Control room Office, the Control

room supervisor on duty will immediately notify the appropriate Operators/supervisors

for field evaluation, response and for taking the necessary steps to effect immediate

implementation of the emergency action that applies to the situation. The names of

essential Company personnel (and means of contacting them) shall be listed on a "Key

Employee emergency action telephone List". Each Area Operations Engineer (and higher

level of management) shall be responsible for reviewing the Emergency Call Lists

affecting their area of operations and reporting needed changes to names or contact

numbers to the QHES Coordinator, who shall administratively be responsible for issuing

updates to the lists as needed.

The contingency plans for the envisaged emergencies include:

• Maintenance of functional firefighting equipment and fire fighting team with an

"on scene commander" on duty 24 hours daily.

• Presence of portable fire extinguishers on the premises of all consumers and

training of fire fighters/wardens for all consumers. Occasional activation of fire

drills to keep fire wardens/consumers alert.

• Telecommunication facilities to inform Control room, Police (serious fires), the

exact location of the fire and to mobilize assistance from SEPTA ENERGY and 1 or

state fire service authority for serious I major fires.

• Purchase and maintenance of ambulance vehicle with medical facilities for first aid

and evacuation of wounded personnel during fire outbreaks 1 injury to employee

or contractor.

• Provision for closing blow down valve that vented gas could be ignited.

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SEPTA ENERGY- Partners In Performance

7 .5.2 Audit Plan

An audit programme shall be in place to review and verify effectiveness of the EMP and

Environmental Management System (EMS) in general. It shall include audits by auditors

independent of the process or facility audited. Audit follow-up shall be timely, thorough

and auditable. A schedule of environmental audits/reviews will be developed for all

phases of the project to monitor site activities and the effectiveness of the EMP. Reviews

and audits will be carried out including reviews of design drawings, specifications and

other documents to verify that environmental objectives and requirements will be

satisfied. Audits of site operations at key stages and during the construction phase will

be conducted to ensure procedures are carried out in the field. Particular emphasis will

be placed on reviewing activities carried out in any environmentally sensitive areas.

7 .5.3 Training Plan

A training programme is an essential part of an EMS. Environmental Training will be

given to key operators on those who are responsible for informing their teams. Topics

will include pertinent environmental legislation, health and safety procedures,

environmental awareness, and identification of environmental risks, and the plans and

actions, which the project is committed to carry out as part of the EMP.

7.5.4 Abandonment Programme'

The facilities for the Uquo to Usung pipeline project are designed to serve the planned

useful life of the project after which they shall be decommissioned and abandoned. It is

the policy of SEPTA ENERGY to carry out abandonment of its facilities in a safe and

environmentally responsible manner such that it constitutes no harm to the environment

and health of the host communities through various remediation strategies to the status

quo ante as far as possible.

Physical abandonment of the facilities is the reverse of the construction and

commissioning process. The technical aspects, HSE studies, detailed engineering and

abandonment execution planning would normally be undertaken before the actual

implementation of abandonment. Generally, abandonment would be carried out in a

structured manner. Prior to abandonment, the drawings and inspection records for all

the facilities and each item of the equipment shall be obtained to determine their status

and integrity as well as personnel, spares and special tools required to perform the

demolition of the facilities - heavy life equipment, specialists etc. and all authorization

for the work to be carried out safely shall be obtained. These include:

• Permit to work procedure (PTW system)

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• Permit to work in confined 5pace, and

• Permit for excavation work.

The abandonment process will involve the following:

• Plant shutdown

• Removal of all hydrocarbons from system

• Purging of buried pipeline with inert gas such as Nitrogen

• Dismantling I removal of all surface facilities and safe-guarding of facilities I parts

• Capping and sealing of all open ends of buried pipeline

• Remediation of impacted sites in order to restore them to their original condition

as far as possible,

• Civil structures shall be broken up and disposed off at approved sites or handed

over to the host communities for use. Pavements shall be scarified and prepared

for re-vegetation.

Handover of site:

SEPTA ENERGY will maintain a record of the abandoned facilities and a copy will be given

to the Department of Petroleum Resources (DPR), FMEnv, host communities and other

stakeholders.

7.6 Environmental Monitoring Plan

The FEPA (FMEnv) interim guidelines and DPR EGASPIN (2002) Provisions require

environmental monitoring for E & P operations. Monitoring may require the installation of

boreholes or wells within and on the margins of the site with facilities for sampling of

ground water (or leachate in the waste), and sampling and analysis of emissions and

effluents to the environment.

Monitoring will be for two purposes:

• To verify company's compliance against the approved EMP and Regulatory

requirements ;(DPR, State Ministry of Environment)

• To identify any sign of environmental degradation within the project area, resulting

from Project activities.

• Monitoring reports will be submitted to regulators (DPR, State Ministry of

Environment) twice a year for review. Meanwhile anomalies/non-compliance will

receive immediate attention.

• DPR, State Ministry of Environment and FMEnv shall fully participate in the Monitoring Plan

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Atmospheric Emissions

Noise

Vegetation

Wild life

Soil

Water Quality Surface

Fisheries

Air Quality: Acid Gases Air quality SOx NOx SPM Meteorological Data : Air temperature, Atmospheric pressure, Relative humidity, wind velocity and direction

Noise amplitude in decibels

Quantification of vegetation materials removed during construction

pH, EC, nutrients and heavy metals

pH, TDS, EC, TSS, Total Alkalinity, Turbidity, HC02 Hardness, Colour, Odour, Ca, Mg, so. ,N03, P04, BOD, COD, Benthos, THC and Heavy metals (Pb. Cr, Cd, Fe, Hg, Ni, Cu, and Mn) Microbiology: E. coli, THB, and TPF.

: Oil and arease.TPH. Conditional factor of fish catch and fishery activity: stress, diversity and

Final Report (Supplementary} January 2013

Weekly during construction

24 hours each time venting is carried out during the first six months of operation and bi­annually during operation.

Weekly during construction

Biannually during operation at emission samolina ooints Once during site preparation

Every 3years during operation

Document Sedentary animals on the ROW prior to ROW preparation/clearing

Weekly during construction biannually after construction along river crosses used as drinking water by host communities

Annually after construction along water courses within the project

8 Points {1 sample site per Skm of the ROW).

4 Points at venting locations

8 Points (1 sample site per Skm of the ROW) during construction.

4 Points

Entire ROW

SOOm on either side of

Along SOOm on either side of oioeline ROW 8 Points within SOOm on

either side of the ROW.

Four comprising of SOOm and1000m upstream,SOOm and 1000m downstream of point of river crossing.

3 commonest fish species at 4 locations

7-13

SEPTA ENERGY and DPR/FMEnv

SEPTA ENERGY and FMEnv

SEPTA ENERGY; and FMEnv

SEPTA ENERGY CDC

SEPTA ENERGY /Contractor

SEPTA ENERGY/Contractor, CDC and FMEnv/DPR

SEPTA ENERGY /Contractor

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ENVIRONMENTAL IMPACT ASSESSMENT OF UQUO-USUNG NEAR ORON GAS PIPELINE PROJECT AKWA IBOM STATE

Total Alkalinity, Turbidity, HC02 Quarterly after construction using ENERGY/Contractor, CDC Hardness, Colour, Odour, Ca, Mg, S04 existing communities' boreholes. and DPR/ FMEnv ,N03, P04, BOD, COD, Benthos, THC and Heavy metals( Pb. Cr, Cd, Fe, Hg, Ni, Cu, and Mn) Microbiology: E. coli, THB, and TPF. Organics: Oil and grease.TPH.

Socio Economics/ Income levels, crowding, demographic, Quarterly during construction in Communities within Skm SEPTA Health settlement pattern, disease prevalence, affected communities. corridor of pipeline ENERGY/Contractor, CDC

Changes in life style etc Biannually after construction in I affected communities

Waste Management Odour, Hydrogen sulphide, visual quality Quarterly during construction and 8points and 1 at base SEPTA of site biannually during operation along camp ENERGY /Contractor; DPR

ROW of pipeline surroundings and and FMEnv at base camp

------------

Final Report (Supplementary) January 2013 7-14

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ENVIRONMENTAL IMPACT ASSESSMENT OF UQUO-USUNG NEAR ORON GAS PIPELINE PROJECT AKWA IBOM STATE

Final Report (Supplementary} January 2013 7-15

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SEPTA ENERGY- Partners In Performance ENVIRONMENTAL IMPACT ASSESSMENT OF UQUO-USUNG NEAR ORON GAS PIPELINE PROJECT AKWA IBOM STATE

7.7 Project Management Team

The management structure of the Uquo to Usung Gas Pipeline Project will change as it

moves from Design/Procurement phase, via Construction/Commissioning phase to

operation phase. The respective teams will be responsible for the implementation of the

environmental management considerations associated with each phase of the project.

The task of executing the Uquo to Usung Gas Pipeline Project in a sustainable manner

and ensuring protection and conservation of the environment are vested in the Project

Team Manager. This is to guarantee management commitment to all environmental

issues concerning the project including:

• Ensuring compliance with the project EMP by all staff and contractors involved in the

project.

• Interfacing with SEPTA ENERGY and Authorities (FMEnv and DPR) and other agents

(PHCN) on project related environmental matters;

• Overall co-ordination of project related environmental matters;

• Further development, implementation and revision of the Environmental Management

Plan and procedures;

The project team manager may delegate some or all of these responsibilities to other

staff in the SEPTA ENERGY organization but he will ultimately remain accountable for the

successful implementation of the EMP.

Resources and Responsibilities

For the project, the Environmental Liaison Officer (ELO) must possess a thorough

knowledge of site conditions, and must be appointed to the project team. During the

detailed design phase, this officer has the responsibility to liaise with all parties involved

in the project, especially the engineering team and environmental consultants. He shall

provide advice on environmental matters in conformity with SEPTA ENERGY QHSE

guideline and policies.

However, to adequately cover the monitoring, inspection and reporting requirements of

the construction and operations phase, greater resources will need to be deployed. Two

options are apparent:

(i) Establish within SEPTA ENERGY an environment-monitoring group as indicated in

Table 7.4

Final Report (Supplementary) January 2013 7-16

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SEPTA ENERGY. Partners In Performance

Table 7.4 Environmental Monitoring Group

Position Requirement Environmental Project Manager Permanent 1 Inspector (HSE Supervisor) Permanent in construction

Part time during operational and ROW maintenance

1 Noise, 1 Air Quality and 1 each of Part time Water Quality, Soil, wild life and Vegetation Experts Laboratory support As required with QA/QC back UlJ support Specialist technical support As required, production chemistry laboratory

or Accredited Laboratory

(ii) Contract

The alternative to an internal environmental monitoring group is to contract out the job

to an appropriately qualified group.

SEPTA ENERGY has established schedules for responsibility to which all levels of staff

owe accountability. Responsibility of environmental issues lies with the management

through a specialist whose role is advisory. SEPTA ENERGY management however,

affirms total commitment to ensure that all environmental considerations are integrated

into related activities. Induction and training courses for staff are part of an effective

environmental management scheme which SEPTA ENERGY holds in high regard.

Ta bl e 7.5: s ummary o fC omm1tments /R 'bTt' f th esp_ons1 II leS or e pro]ec t S/N Commitment/issue Action Action Party

1. Project planning and Setting up of an environmental focal point SEPTA ENERGY schedulina

2. Project mobilization Supervision of the process SEPTA ENERGY 3 Construction phase Supervision including inspection, monitoring SEPTA

supervision and auditing of activities ENERGY /Project contractor/ FMenv/AIMEnv

4. Construction Supervision of the process SEPTA ENERGY demobilization

5. Post pipelaying and Supervision including inspection, monitoring SEPTA ENERGY maintenance phase and auditing of activities supervision

6. Contingency planning Training plan develqpment and implementation SEPTA ENERGY 7. Project decommission ina Post project monitorina and auditina SEPTA ENERGY

• DPR, State Mm1stry of Environment and FMEnv shall fully part1c1pate 1n the ProJeCt by supervising 1 inspecting all aspects of the Project in order to protect the environment.

Final Report (Supplementary) January 2013

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SEPTA ENERGY- Partners In Performance

7.8 Undertakings

Throughout the planning of this project, SEPTA ENERGY will continue to consult with the

public, statutory authorities and affected individuals as well as local communities in order

to ensure that the pipe laying activities and operation have minimum adverse

environmental impacts.

To further support its policy on the environment, SEPTA ENERGY would undertake to:

• Prepare a detailed restoration and after-care plan for maintenance of the pipeline

working width (ROW);

• Monitor all environmentally sensitive areas during pipeline construction and

operation to ensure compliance with SEPTA ENERGY and statutory standards;

• Land uptake for temporary use, which will require clearance, will be kept to the

barest minimum, and restoration after use will be undertaken;

• At crossings of rivers normally subjected to domestic use, commercial and

industrial traffic, construction time will be reduced to minimal and restoration of

riverbanks to avoid erosion will be undertaken.

7.9 Decommissioning and Abandonment

At the end of the life span of the Gas pipeline Project. SEPTA ENERGY shall invoke its

standard decommissioning and abandonment programme. The tasks shall include the

following:

• Ensuring that the decommissioning and abandonment are done with the same care

and respect for the environment with which the project was designed, constructed

and operated.

• Assessing residual impacts that the project has had on the environment during its life

span.

• Monitoring the abandoned environment.

• Restoring the environment to its original state as much as possible.

To accomplish these, the decommissioning and restorative/rehabilitation programme

shall be managed by a team of competent personnel including the Environmental Liaison

Officer (ELO) as well as Engineering and Operations personnel.

Final Report (Supplementary) January 2013 7-18

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SEPTA ENERGY- FartneromPaaoanance

Final Report (Supplementary) January 2013 7-18

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fEDERAL MINISTRY Of ENVIR NMENT Environment House

Independence Way South, Central Business District, Ahuja. FCT. Tel: 09·2911 337 www.environmentgov.ng, ea-environment.org

ENVIRONMENTAL ASSESSMENT DEPARTMENT

F~·!ENV;CONFtEIA/123 i6l7!VOL 11/39 17'' Octot{;r, 2012

The Managmg Dtrector, Septa Energy Limited, 7B Anlfuwoshe Street, Victoria lsianct Lagos.

FINAL EIA APPRQVAL FOR TljE ENVIB,QNMENIAL IMPACT ASSESSMENT (ElA) OF THE UQUO fiELD TO USUNG (ORON} GAS PIPELINE PRQJ~

Please refer to your letter dated 3'0 November, 2010 requesting for EIA permit to embark on the above project and the Hinistry's letter Ref. No. Ffv1EIW iCONf/EIAi 123:1617 /voU 1/236 dated 23" December, 2011 granting Provisional EIA Approval for the commencement of the project

2. Following the submission of satisfactory Final EIA Report and payment of the Finai Assessed Charge U'AC)1 1 am directed to convey the Ministr)!'s Final EIA AJ,?proval for the proJect subJect to the following conditions.

i. This Approval covers only the 18" x 38km Uquo Field to Usung Gas Pipeline and ancillary facilities.

ii. There shall be implementation of the E:nwonrnental Hanagement Plan (E -lP) and mitigation measures as contained in the EIA report.

111 fhere shall be EIA Impact Mitigation f¥1oflitormg ex:eroS<:: of the prOJeC by the f'.1inistry in collaboration with other relevant regulatory AuthoritieS. This ! 1a!! be facilitated by Septa Energy Limited.

iv. Environmental Compliance Monitoring and Environmental Audit shall be conducted on the project according to extant laws and approved by tl1e Fedi.Cral Ministry of Environment. This shall be facilitated by Septa Energy Limited.

v. There shall be continuous consultation with the relevant stakeholders' throughout the lifespan cf the project.

vt. Full implementation of memoranciurn of Understand:ng 'Nith the hu~t community.

·•11. An Env1ronmentai fv1anagernent. System (Et•1S) shall be ;nstituted for lhe project. 3. The Environmentallrnpact Assessment (EIA) Certificate and Enwonrnent Impact Statement (EIS) shall be issued in due course. 4. Congratulations,

AiL Dr. (l"lrs.)i4.T. Odubela

Director, Environmental Assessment Dept. For: Honourable f-iimster.

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1\CCIJGA.$ UMITEO, A

PTA ENERGY OF ORON GAS PIPELINE <.ON'JULTitl(o

GROUP COMPANY

, Project m;m l•,,:r: ' /\CCUGAS No 1!0450'1 Rev. [3

PIPEUNE AND PIPING PRESSURE TEST PHILOSOPHY

Reason tor Issue Checked Appmved

Issued tor neview Horr.1<1inscn1

Issued for RevleviiApproval

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--------·----------,·--·--·------, DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F45Er--~ Doc No: 1204501-ILFL-PHS-A-0005 I Rev: B ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

REVISION CHANGE HISTORY

Revision Reason for Related Explanation /List of Changes Change Correspondence

Ref. No.

Comments

B Internal Needs

X N/A Internal comments updated

Comments l i -

Internal Needs

Comments --- . -·-·· ---··

Internal Needs

Comments

Internal Needs

Comments

Internal Needs

Comments I

Internal Needs

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DETAIL DESIGN OF

ORON PIPELINE CONSULTING ENGiNEERS

Rev: D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

Reason for lssua Checked

Issued for !DC

Issued for Review

Re-Issued for Review

UNSON HWLLED UNLESS WiTH ORIGINI<L SIGN!\TURE:S

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DETAIL DESIGN OF ORON GAS PIPELINE 1---:::--:---:---:--=-:-:::-::--.-------·--·-·-----·········-················----------····--·-r-----------l

Project number: F456 I Doc No: 1204501-ILFL-PHS-E-0001 I ACCUGAS No: 1204501

Rev: D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS ~---~~~~~~~~~~~~~~~~~~~~~~~~~~~~--~

REVISION CHANGE HISTORY

Revision Reason for Related Explanation /List of Changes i Change Correspondence

Ref. No.

Comments

B Internal Needs

X N/A Internal comments updated

Comments X JU11917B-PEL-Company's comments implemented

ILF-T-0144 c f---····-············- -···-·--·--- ·-·- !

Internal X N/A Internal comments updated

Needs

Comments X JU11917B-PEL-

Company's comments implemented !LF-T-0191

D Internal Needs

Comments

Internal Needs

Comments 1

-·· ----Internal Needs

Comments

Internal Needs

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DETAIL DESIGN OF ORON GAS PIPELINE ...

Project number: F456 I ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 I Rev:D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

TABLE OF CONTENTS

1 GENERAL ................................................................................................................................ 4

1.1 INTRODUCTION ...................................................................................................................... 4

1.2 SPECIFIC DEFINITIONS AND ABBREVIATIONS GIVEN IN ADDITION ............................... ..4

1.3 SCOPE .................................................................................................................................... 4

1.4 REFERENCED DOCUMENTS ................................................................................................. 4

1.5 APPLICABLE CODES AND STANDARDS ............................................................................... 5

2 DESIGN BASI$ ........................................................................................................................ 6

2.1 SITE SURVEY .......................................................................................................................... 6

2.2 DESIGN CONSIDERATIONS ................................................................................................... 7

2.3 DESIGN CRITERIA .................................................................................................................. 7

2.3.1 DESIGN LIFE ........................................................................................................................... ?

2.3.2 CURRENT REQUIREMENTS .................................................................................................. 7

2.3.3 CURRENT DENSITY ( J * FC) .................................................................................................. 8

2.3.4 PIPE-TO~SOIL POTENTIAL ..................................................................................................... 8

3 TECHNICAL DESCRIPTION .................................................................................................... 9

3.1 CURRENT DEMAND CALCULATION ...................................................................................... 9

3.2 SACRIFICIAL ANODES CALCULATIONS ............................................................................... 9

3.2.1 CURRENT CRITERION ........................................................................................................... 9

3.2.2 WEIGHT CRITERION ............................................................................................................ 10

3.3 PIPE-TO-SOIL POTENTIAL ................................................................................................... 11

3.4 CP SYSTEM CONFIGURATION ............................................................................................ 11

4 EQUIPMENT .......................................................................................................................... 17

5 INSTALLATION ...................................................................................................................... 18

5.1 GENERAL .............................................................................................................................. 18

5.2 CABLE LAYING ..................................................................................................................... 18

5.3 CABLE CONNECTIONS ........................................................................................................ 18

5.4 TEST STATIONS ................................................................................................................... 18

5.5 TEMPORARY CATHODIC PROTECTION ............................................................................. 19

5.6 NEGATIVE JUNCTION BOX .................................................................................................. 19

6 PRE-COMMISSIONING ......................................................................................................... 20

7 COMMISSIONING ............................................................................................................... :.21

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DETAIL DESIGN OF ORON GAS PIPELINE f---:::---:--:---:-----:=-:-o:-::--r------------------r------------------~-------

Project number: F456 I Doc No: 1204501-ILFL-PHS-E-0001 I ACCUGAS No: 1204501

~----"-'-=-=--=...=.c..:.:CA::.....;_T_;_:::.H.;;_O=-D=....::I-=-=C;_;,_P_.R_O_T_E_C_T_IO_N_P_H_I_LO_S._O_P_H_Y_A_N_D_C__,A_L_C_UL_A_T_IO_N_S ____ _ Rev:D

1 GENERAL

1.1 INTRODUCTION

The project description, abbreviations, and definitions are contained in the 1204501-ILFL-GDE­

A-0001 -Project Introduction and will not be repeated here.

1.2 SPECIFIC DEFINITIONS AND ABBREVIATIONS GIVEN IN ADDITION

In addition to the definitions provided in the document 1204501-ILFL-GDE-A-0001, following

definitions will be used throughout the document:

Inspector:

Contractor:

Vendor:

Company's nominated representative entitled to conduct inspections;

Company which executes construction works;

The party which manufactures and supplies the equipment and/or

services to perform the duties as specified by the Company.

1.3 SCOPE

1.4

~

The scope of this document is a description of cathodic protection system for designed pipeline.

REFERENCED DOCUMENTS

List of reference documents:

1204501-ILFL-DRA-E-0001

1204501-ILFL-SHD-E-0001

1204501-ILFL-DTS-E-0001

1204501-ILFL-MTO-E-0001

1204501-ILFL-SPC-E-0001

1204501-ILFL-L YT-E-0003

1204501-ILFL-DRA-Y -0001

1204501-ILFL-SPC-Y -0003

1204501-1 LFL-DRA-E-001 0

1204501-ILFL-DRA-E-0011

UGPF-V015-DRW-Z-00003

Cathodic Protection Typical Drawings,

Cathodic Protection Test Stations Schedule,

Cathodic Protection Equipment Data Sheet,

Cathodic Protection MTO,

Cathodic Protection Equipment Specification,

UGPF Cathodic Protection Installation Layout

Alignment Sheets (1 :5000)

Construction Specification (Pipeline),

Cathodic Protection System Overall Scheme,

UGPF Negative Junction Box Extension,

General Arrangements, Schematics for Hydrants and

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DETAIL DESIGN OF ORON GAS PIPELINE r--project number: F456 I [ ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 Rev: D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

lnplant Piping CP System.

1.5 APPLICABLE CODES AND STANDARDS

The latest editions or revisions of the following, as minimum, standards shall be complied with:

EN 14505

ISO 15589·1

IEC 60529

NACE SP0169-2007

NACE SP0177-2007

NACE SP0286-2007

1204501-ILFL-PHS-E-0001 __ RevD

Cathodic Protection- Cathodic Protection of Complex Structures,

Pipeline Transportation System - Cathodic Protection - Part 1:

Onshore Pipelines,

Degree of Protection Provided by Enclosure,

Control of External Corrosion on Underground or Submerged

Metallic Piping System,

Mitigation of Alternating Current and Lightning Effects on Metallic

Structures and Corrosion Control Systems,

Electrical Isolation of Cathodically Protected Pipelines.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I · ----~- j .·

ACCUGAS No: 1204501 Doc No. 1204501-~~~L-PH=~-~0002_ ___ -------------~~~:_D ___ ---1

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

2 DESIGN BASIS

ORON pipeline is designed as underground and shall be protected against external corrosion by

high integrity external coating system supplemented by an impressed current cathodic

protection system. Pipeline shall be protected by cathodic protection station (CPS) located at

UGPF. Temporary protection with sacrificial anodes shall be provided for the period from the

beginning of the pipeline construction till the commissioning of impressed current installation.

2.1 SITE SURVEY

Prior the installation of the CP system facilities site survey shall be taken by the CP Contractor

along the pipeline route in order to:

• define soil resistivity,

• define type of terrain,

• define crossing and other neighboring structures (other pipelines, overhead power lines,

rails),

• determine location of test posts.

Soil resistivity measurements shall be taken along the pipeline route, according to requirements

given in 1204501-ILFL-SPC-G-0001.

Since site survey report is not available, following assumptions are taken into consideration

during design:

~· •

soil is corrosive or slightly corrosive, resistivity <1000m,

there is no electrical railway crossing,

there is no expected crossing or parallelism with high voltage overhead transmission line,

there is no expected crossing or parallelism with low voltage overhead line which could

impact on the pipeline and its CP,

• there is no cased road crossing,

• there are no neighboring cathodically protected structures along the pipeline route.

Cathodic protection of UGPF and Adanga - Calabar pipeline do not impact on the pipeline

CP and vice versa, because of high integrity external coating system,

there is no cathodic protection station at OGRF.

Above mentioned assumptions shall be verified by Contractor after site survey report is

available.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F45tf .. ,r -

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 I Rev:O

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

2.2 DESIGN CONSIDERATIONS

Basic pipeline data:

• Pipeline length -37km,

• Pipeline OD 24" (610mm considered for calculations),

• Wall thickness 12,7mm /15,9mm (depends on location),

• Material API5LX65,

• Coating 3LPE,

• Unit pipe-to-soil resistance 1050/m2.

Basic requirements:

• Pipeline shall be electrically isolated from UGPF and OGRF,

• -2,5km of the pipeline between OGRF and Tie-in shall be protected by Adanga- Calabar

pipeline CP,

• If possible, an extended UGPF CPS shall be utilized instead of new one,

• Monitoring test posts shall be installed along pipeline route with 1-2km intervals.

2.3 DESIGN CRITERIA

2.3.1 DESIGN LIFE

All equipment and installations shall be designed for m1n1mum 25 years operation time.

Temporary sacrificial cathodic protection system shall be sufficient for 2 years operation time.

2.3.2 CURRENT REQUIREMENTS

Current requirement shall be determined using following formula:

I = f * Fe * 2 * rr * r * L

Where:

Required CP current (A),

J Base current density (mA!m2),

Fe Coating breakdown factor,

Outer pipeline radius (m),

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501·1LFL-PHS·E·0001 1'- Rev:D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

l Pipeline length (m).

2.3.3 CURRENT DENSITY { J * Fe}

Current density of 0,01mA/m2 (same as considered for existing UGPF CP. It is maximum

practical required density for pipe!ine well isolated with 3LPE coating, Designer experience with

3LPE coatings shows that current density shall not exceed 0,003mA/m2.) at 30°C shall be used

for current calculation. Temperature correction, +25%, shall be applied for each 10oc rise above

30°C.

2.3.4 PIPE· TO-SOIL POTENTIAL

Following pipe-to-soil potentials (off) shall be achieved depends on soil conditions:

• -0,85V w.r.t Cu/CuS04 for aerobic soil,

• -0,95V w.r.t. Cu/CuS04 for anaerobic soil.

To avoid detrimental effects to the external pipeline coating, overprotection shall be avoided.

Most negative allowed pipe-to-soil potential (off) shall be -1, 15V w.r.t. Cu/CuS04.

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I Doc No: 1204501·1LFL·PHS·E·0001 1· Rev: D ~A=C~C~U~G~A=S~N~o~:~12=0~4~5~01~~==~~~=-~~~~~----~~··~~---=----------4

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS ~--------------------------------------------------------------------

3 TECHNICAL DESCRIPTION

3.1 CURRENT DEMAND CALCULATION

Current demand is calculated using the current density of 0,01 mA!m2, as justified in paragraph

2.3. Temperature correction is not required for underground pipeline.

I = j • Fe • 2 • n * r * L

I ::::: 0,01 * 2 * TC * 0,305 * 37000

I= 0,71A

Where:

Required CP current (A),

J Base current density (mA!m2),

Fe Coating breakdown factor,

Outer pipeline radius (m),

L Pipeline length (m).

3.2 SACRIFICIAL ANODES CALCULATIONS

Sacrificial anodes for temporary protection of the pipeline shall be calculated taking into consideration current and weight criteria.

3.2.1 CURRENT CRITERION

I nl =­

Ia

I:::: 0,71A

Ea -Eo la = _.;.:__~ . R

p Lz R= ln-

2 * TC * L hd

Where:

n, Required anodes quantity, according to current criterion,

Required CP current (A),

Ia Single anode current (A),

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DETAIL DESIGN OF ORON GAS PIPELINE f·-=--:--:---:---:=-:-::-::--.----------- ------.----·-····-····--·--··---·-·-·····-

Project number: F456 I . I . ACCUGAS No: 1204501 Doc No. 1204501-ILFL-PHS-E-0001 Rev. D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS-·---

Ea Single anode-to-soil potential (V),

Eo Pipe-to-soil potential (V),

R Anode resistance (0),

L Anode length (m),

d Anode diameter (m),

h Depth of anode burial (m),

p Soil resistivity (Om).

100 0,72

R = 2 * rr * 0,7 111 1,5 * 0,2 = l1,2

1,5-0,95 Ia =

11,2

= O,OSA

/ n1 =- = 14 2

Ia ' According to current criterion, 15 anodes are required.

322 WE~HTCRITER~N

I* 8766 * t Mr=---­

U*t Where:

n2 Required anodes quantity, according to weight criterion,

Mr Required weight (kg),

Ma Anode weight (kg),

Life time (years),

u Breakdown factor,

E Current capacity (ah/kg).

0,71 * 8766 * 2 Mr = 0,5 * 1100 = 22,6kg

_ ZZ,6 _ l 6 Hz- 14.5- ., According to weight criterion, 2 anodes are required.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 1 Rev:D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

More demanding result from two stated above is taken into consideration, therefore 15 anodes shall be provided for the entire pipeline length as a temporary cathodic protection. It is proposed

to install 5 galvanic anodes stations distributed at similar intervals along the pipeline, each

containing 3 anodes.

3.3 PIPE-TO-SOIL POTENTIAL

Taking into consideration that pipeline is routed mainly through swamp areas, stricter criterion

for pipe-to-soil potential shall be considered. Therefore off potential at the end of the pipeline

shall not be less negative than -0,95V w.r.t. Cu/CuS04, keeping in mind that off potential -1, 15V

w.r.t. Cu/CuS04 shall not be exceeded at any place.

Off potential at drainage point corresponding with assumed potential at the end of the pipeline is

calculated using following equation:

Excosh oc: L Eo = cosh oc: (L - x)

Where:

Eo Pipe-to-soil potential at drainage point (V),

Ex Pipe-to-soil potential at the end of the pipeline (V),

a Pipeline attenuation constant (m·\

L Pipeline length (m),

x Distance between drainage point and end of the pipeline (m).

-0,95 * cosh0,0000113 * 37000 Eo= cosh0,0000113(37000- 37000) = -l,034V

To ensure required off potential at the end of the pipeline, -1 ,034V w.r.t. Cu/CuS04 off potential

at the drainage point shall be set, which is less negative than the most negative potential

allowed (-1,15V w.r.t. Cu/CuS04). It shows that the pipeline could be protected on the entire

length only by UGPF CPS without exceeding allowable -1,15V w.r.t. Cu/CuS04 at any place ..

3.4 CP SYSTEM CONFIGURATION

Taking above calculations and assumptions into consideration, following cathodic protection

configuration shall be applied.

Drawing No. 1 presents the pipeline CP simplified configuration. The pipeline section between

UGPF and OGRF shall be protected by the extended UGPF CP station. The pipeline section

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I Doc No: 1204501-ILFL-PHS·E-0001 Rev: D ACCUGAS No: 1204501

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

between OGRF and Tie-in to Adanga - Calabar pipeline is installed under the water and isolating joint cannot be installed there. Therefore this short (about 2,5km) section shall be

cathodically protected by the Adanga - Calabar pipeline CP system. There is also no possibility to install test stations at OGRF - Tie-in section, so the pipeline CP system ends at OGRF incoming isolating joint.

1::\. I For details please refer to Cathodic Protection System Overall Scheme - Doc No. 1204501-~ ILFL-DRA-E-0010.

For remaining test stations location please refer to Cathodic Protection Test Stations Schedule -Doc No. 1204501-ILFL-SHD-E-0001.

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DETAIL DESIGN OF ORON GAS PIPELINE

-:cr~tr~~u~:e;~~::~1 j Doc No: 1204501-ILFL-PHS-E-0001 I Rev: D CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

9 l NEGATIVE CABLE L .... Ji] AG

~------~~tG km 00+000 POTENTIAL TEST I ·~:::.:... .. ....... STATION WITH PERMANENT REFERENCE ELECTRODE

BONDING CABLE

km 35-t580 POTENTIAL TEST _ . .c::::c .. -·····--· .......... ... ······t . .. .......... ---STATION WITH PERMANENT j REFERENCE ELECTRODE !

NEGATIVE JUNCTION BOX

ISOLATING JOINT

UGPF FEJ<;CE

OGRFFENCE

ISOLATING JOINT

ISOLATING JOINT

OGRF FENCE

·------......C...--··-··~·-···· AOANGA -CALABAR PIPELINE

/ \

/\

\, I

Drawing No. 1 - UGPF CP system overview diagram

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DETAIL DESIGN OF ORON GAS PIPELINE

~~~~~u~:e~~~:;~1 I Doc No: 1204501-ILFL·P~S-E-0001 j . __ Rev: D

CATHODIC PROTECTION PHILOSOPHY AND CALCULA-T-IO_N_S __ -1

Cathodic Protection Station

UGPF plant piping is protected by impressed current cathodic protection installation consisting of deep anode ground bed and transformer rectifier unit. Transformer rectifier is sized for 30A

current output, while ground bed for 25A. Calculations of UGPF CP system shows that maximum current demand is 15A and it covers pipelines, hydrants and station earthing requirements. Therefore there is 1 OA spare current output which could be used for the pipeline protection and there is no need to provide new CP station.

Transformer rectifier DC output (negative) is connected to Negative Junction Box which distribute DC current to Bond Boxes (4 Nos.} and through resistor to existing outgoing pipeline. Negative Junction Box shall be extended to accommodate additional resistor (same as existing)

I and feeder for the designed pipeline. It shall provide DC current to the pipeline and allow

potential adjusting to required value. For details please refer to UGPF Negative Junction Box Extension- Doc No. 1204501-ILFL-DRA-E-0011.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS·E-0001 I Rev:D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

EXISTING POSITIVE JUNCTION BOX

T!NGGROUNO BED I~ .. ..., I I

EX IS

l

I 1\:-r-~" I ~

I v l

I

+ i EXISTING TRANSFORMER RECTIFIER

~ L~

EXISTING BONO BOXES

-----······-······--·-------

Drawing No. 2- UGPF CPS overview diagram

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F4SS I Doc No: 1204501-ILFL-PHS-E-0001 Rev: D ACCUGAS No: 1204501

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

Test Stations

Test stations shall be installed at following locations:

• UGPF,

• OGRF,

• Every 1-2 kilometers along the pipeline.

Test station at fenced areas shall be above ground plastic post, Big Fink type to be in line with

existing installation. Along the pipeline flush posts, e.g. Flush Fink, shall be installed to prevent

damaging and stealing.

Test stations at UGPF and OGRF shaH be "type D", pipe to soil potential measurement, and

shall and shall be equipped with permanent reference electrode.

Along the pipeline 3 types shall be used interchangeably:

• "type A"- pipe to soil potential measurement. It shall be located every 1-2km;

• "type B" - pipe to soil potential and monitoring coupon measurement. It shall be located

with spacing about 5km, in areas where soil resistivity is <200m;

• "type C" - pipe to soil potential measurement and galvanic anodes station. There shall be

5 "type C " stations installed along pipeline route. Exact location shall be decided during

execution works, however soil resistivity at installation area shall not exceed 1 000. After

disconnection of temporary CP, stations will serve as "type A".

Temporary CP

Temporary protection shall be provided for period between pipeline installation and CP system

commissioning. 5 galvanic anodes stations (each containing 3 magnesium anodes) are

foreseen as temporary protection. Their location shall be defined depend on execution I testing pipeline sections.

~ ITo provide temporary protection for the pipeline section between OGRF and Tie-in, u~til Adanga ~ - Calabar pipeline connection to Wye (Tie-in), isolating joints at OGRF shall be bonded.

Before commissioning of impressed current protection system galvanic anodes shall be

disconnected. Test stations shall then serve as simple pipe to soil potential measurement

~ IOGRF isolating joints bonding shall be disconnected before Adanga - Calabar pipeline ~ connection to Wye (Tie-in).

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DETAIL DESIGN OF ORON GAS PIPELINE _______ .,,, .. " .... ,.,.., ........... ~ ........

Project number: F456 I ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 I Rev:O

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS ... ~·-

4 EQUIPMENT

For detail requirements for test station, spark gap, test coupon, sacrificial anodes etc. please

refer to:

1204501 ~ILFL-DTS-Y-0001

1204501 ~ILFL-SPC-Y -0006

1204501-ILFL-DRA-Y-0020

Cathodic Protection Equipment Data Sheet,

Cathodic Protection Equipment Specification,

Cathodic Protection Typical Drawings.

Pin brazing details are shown on typical drawing:

1204501-ILFL-DRA-Y-0020 Cathodic Protection Typical Drawings.

For details of existing negative junction box, which shall be extended, please refer to:

811204501-ILFL-DRA-E-0011 UGPF Negative Junction Box Extension,

For isolating joints requirements please refer to:

1204501-ILFL-DTS-Y -0006 Isolation Joint Data Sheet.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 T Doc No: 1204501-ILFL-PHS·E-0001 I Rev:D ACCUGAS No: 1204501

¥ --~·P••·-~--

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS ----5 INSTALLATION

5.1 GENERAL·

General guidelines are given in ''Construction Specification (Pipeline)"- doc. No. 1204501-ILFL­

SPC-Y-0003.

5.2 CABLE LAYING

Cables to test stations shall be laid in pipeline trench, above pipeline center line preferably. In

other case cables shall be laid in 0,8m deep trench, on 1 Ocm layer of clean sand, covered with

1 Ocm clean sand layer and marked with warning tape. On road and other installations crossings

cables shall be protected by PVC sleeves. Cables leaving ground shall be protected by using

galvanized steel, PVC coated sleeves. Cables shall be laid keeping minimum allowable bending

radius. Cables shall be equipped with ID labels installed every 1Om, next to the pipeline

connection point, at cable incoming to test station and next to terminals. All cables shall be laid

as a continuous length.

At UGPF area cables shall be laid in existing cable trenches and marked as per existing

specifications.

5.3 CABLE CONNECTIONS

Cables shall be connected to the pipeline using pin brazing method and pin brazing

encapsulation sets as a connection isolation. Resistance of connection shall not be higher than

0,1 0. Connections shall be made at least 150mm from the pipeline welds and seams.

Connection to the pipeline bend is not allowed.

Negative drain cable at UGPF and bonding cable at OGRF shall be connected to isolating joints lugs using lugged, bolted connections.

Cable connections shall be made as close as possible to test station to limit cable length.

5.4 TEST STATIONS

Aboveground test posts (UGPF and OGRF} shall be installed on 1 ,5m PVC pipe support

stabilized in the ground by using concrete support. Flush mounted test posts (linear part) shall

be installed on 1 foot PVC pipe support stabilized by concrete support. Posts shall be located in

easy accessible, dry areas and protected against damaging. Test post shall be equipped with UNCONTROLLED UNLESS WITH ORIGINAL SIGNATURES

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 -·r---- Rev:D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

mounting plate with appropriate number of terminals. Flush mounted posts shall be additionally

equipped with magnetic tape to allow post localization after its burial. Flush mounted post

construction and installation shall ensure dry post interior even under flood water.

Permanent reference electrodes shall be installed 0,2m from the pipeline wall and on 1 ,2m

depth. It shall laid in the way that active electrode part is in continuous contact with electrolyte.

Test coupons shall be installed 0,2m from the pipeline wall and 0,1m below its centre line.

Coupon shall be inclined with respect to the pipeline by 45° and exposed part shall be directed

opposite to the pipeline. Contractor is responsible for soil resistivity measurement for these

points. If resistivity near the post location exceeds 200m, test station shall be relocated, or

coupon shall be installed in different test station.

5.5 TEMPORARY CATHODIC PROTECTION

Temporary cathodic protection shall be provided by sacrificial galvanic anodes. Galvanic

anodes connected to the pipeline through test station shall provide temporary cathodic

protection for the period between pipeline construction and impressed current CP

commissioning (assumed 2 years). Contractor is responsible for soil resistivity measurement for

galvanic anodes location. If resistivity exceeds 1000m, test station shall be relocated, or

galvanic anodes shall be installed in different test station. Requirements given in Test Stations

paragraph and in anodes data sheets shall be followed during installation.

5.6 NEGATIVE JUNCTION BOX

Existing negative junction box at UGPF shall be extended to accommodate additional negative

feeder (with resistor) for designed pipeline. New feeder shall be same as existing one for

outgoing pipeline. Under extension new bus bar shall be installed to accommodate additional

cable lug. Also bottom cable gland mounting plate shall be replaced by one with additional

opening.

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DETAIL DESIGN OF ORON GAS PIPELINE - -----------.,..-------------------------·--

Project number: F456 I Doc No: 1204501-ILFL-PHS·E-0001 I Rev:D ACCUGAS No: 1204501 .

CATHO=D.:...;Ic::.:C;_;_P_,_R-=o-=T-E-CT=-1-=o--N-=P::-:--H-IL-O-=s-=o-=P-=H-::-:Y· AND CALCULATIONS

6 PRE-COMMISSIONING

Following tests shall be performed during mechanical completion:

• continuity measurement of the cable connection to the pipeline,

• mechanical test of the cable connection to the pipeline,

• visual inspection of the cables and cable connection to the pipeline,

• check of the cable 10 labels and their correctness,

• verification of the galvanic anodes installation and distance between individual anodes,

• check of the depth of cables installation,

• check of cable route marking.

After the installation, prior to commissioning, following inspections and tests shall be conducted:

• permanent reference electrodes potential and their resistances to soil measurements,

• test coupons free corrosion potentials and resistances to soil measurements,

• galvanic anodes potentials and resistance to soil measurements,

• grounding installations measurements,

• isolation joint measurements,

• cable insulation measurements,

• resistance measurements of the output circuit of the cathodic polarization sources,

• switching on test of the transformer-rectifier units, verification of the connections and

polarization at output,

• visual inspection of the installed equipment for possible damages,

• adjustment of the current measurement test stations.

A pre-commissioning report shall be provided by Contractor for Client approval.

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DETAIL DESIGN OF ORON GAS PIPELINE ¥~ _ _.,__. ___ ~--·· ----~.~~

Project number: F456 I ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-E-0001 I Rev:D

CATHODIC PROTECTION PHILOSOPHY AND CALCULATIONS

7 COMMISSIONING

Commissioning shall be started after finalization of the mechanical works on the pipeline.

Temporary cathodic protection realized by sacrificial anodes shall be disconnected and the pipeline shall be deenergized. Following measurements shall be conducted before the first

polarization:

• pipe-to-soil resistance measurements on the different sections of the pipeline,

• change of the foreign structures potential measurement after switching on/off of the

polarization sources,

• change of the pipeline potential measurement after switching on/off of the polarization

sources before and behind isolation joint,

• potential and resistance to soil measurements of the permanent reference electrodes,

• isolation joints resistance measurements.

After the measurements, CP installation can be energized, adjusted and pipeline shall be

polarized. After one week of the polarization following measurements shall be conducted:

• output voltages of the transformer-rectifier units,

• polarization current,

• switch-off potentials in the drainage points and at the ends of the pipeline.

Contractor shall conduct also DCVG surrey in order to check for possible pipeline coating damages. After three month of the polarization Contractor shall conduct CIPS survey in order to

confirm that pipeline have been correctly polarized. Appropriate protocols from above listed measurements, test and surveys are prerequisite for installation take-over.

Commissioning procedures, as well as operation and maintenance instructions, are under

Contractor scope.

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BsEPTA ENERGY OF

PlPEUNE AND PIPING PRESSURE TEST PHILOSOPHY

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·-DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 "l"" ACCUGAS No: 1204501 Doc No: 1204501·1LFL-PHS-A·0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

REVISION CHANGE HISTORY

Revision Reason for Related Explanation /List of Changes Change Correspondence

Ref. No.

Comments

B Internal Needs

X N/A Internal comments updated

Comments

Internal Needs

Comments .u.-.-••·~~··••

Internal Needs

Comments

Internal Needs

Comments

Internal Needs

Comments

Internal Needs

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I . I ACCUGAS No: 1204501 Doc No. 1204501-ILFL-PHS·A-0005 Rev: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

TABLE OF CONTENTS

GENERAL ................................................................................................................................ 5

1.1 INTRODUCTION ...................................................................................................................... 5

1.2 SPECIFIC DEFINITIONS AND ABBREVIATIONS ................................................................... 5

1.3 SUBJECT OF SPECIFICATION ............................................................................................... 5

1.4 APPLICABLE CODES AND STANDARDS ............................................................................... 6

2 BASIS FOR PRESSURE TESTS ............................................................................................. 7

2.1 GENERAL ................................................................................................................................ 7

2.2 UGPF SITE CONDITIONS ....................................................................................................... 7

2.3 OGRF SITE CONDITIONS ....................................................................................................... ?

2.4 ENVIRONMENTAL CONDITIONS ........................................................................................... 8

3 HYDROSTATIC I AIR PRESSURE TESTING .......................................................................... 9

3.1 PIPELINE TESTING- ASME B31.8 ......................................................................................... 9

3.1.1 GENERAL ................................................................................................................................ 9

3.1.2 CLEANING PIG RUNS ............................................................... ,. .......................................... 10

3.1.3 GAUGING PIG RUNS ............................................................................................................ 10

3.1.4 WATERFILLING ..................................................................................................................... 11

3.1.5 HYDRO TEST PROCEDURE ................................................................................................. 12

3.1.6 HYDRO TEST PERFORMANCE ............................................................................................ 14

3.1.7 AFTER TESTING ................................................................................................................... 15

3.2 PIPING TESTING- ASME B31.3 .......................................................................................... 17

3.2.1 GENERAL .............................................................................................................................. 17

3.2.2 TESTING ................................................................................................................................ 18

3.2.3 AFTER TESTING ................................................................................................................... 18

3.3 HYDRO/AIR TEST DOCUMENTATION ................................................................................. 18

4 INSPECTION ......................................................................................................................... 20

5 ENGINEERING ...................................................................................................................... 21

6 TIME SCHEDULES ................................................................................................................ 22

6.1 TIME SCHEDULE .................................................................................................................. 22

6.2 WORK SCHEDULE ................................................................................................................ 22

6.3 WORK REPORTS .................................................................................................................. 22

7 DOCUMENTATION ................................................................................................................ 23

7.1 GENERAL .............................................................................................................................. 23

7.2 CONTRACT DOCUMENTATION REQUIREMENTS .............................................................. 23

7.2.1 INTRODUCTION .................................................................................................................... 23

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-DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I ACCUGAS No: 1204501 Doc No: 1204501·1LFL·PHS·A·0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

7.2.2 LANGUAGE ........................................................................................................................... 23

7.2.3 UNITS .................................................................................................................................... 23

7.2.4 DOCUMENTATION DELIVERY ............................................................................................. 24

7.3 FINAL DOCUMENTATION ..................................................................................................... 24

8 SCHEDULE FOR INFORMATION EXCHANGE ..................................................................... 25

9 PROJECT SCHEDULE .......................................................................................................... 30

10 REFERENCED DOCUMENTS ............................................................................................... 31

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I ACCUGAS No: 1204501

Doc No: 1204501-ILFL-PHS-A-0005 I ------·--·--

Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

1 GENERAL

1.1 INTRODUCTION

The project description, abbreviations, and definitions are contained in the 1204501-ILFL-GDE­

A-0001 - Project Introduction document and will not be repeated here.

1.2 SPECIFIC DEFINITIONS AND ABBREVIATIONS

In addition to the definitions provided in the document 1204501-ILFL-GDE-A-0001, following

definitions will be used throughout the document:

Inspector Authority Company's nominated representative entitled to conduct inspections

Vendor The party who execute construction works as specified by the Company

DPR Department of Petroleum Resources- Nigerian gas sector regulator

ITP Inspection and Test Plan

QAP Quality Assurance Plan

UGPF Uquo Gas Process Facility

OGRF Oron Gas Receiving Facility

1.3 SUBJECT OF SPECIFICATION

The subject of this specification is the minimum requirements for the pressure test of:

• Pipeline system,

• Piping systems, laid above or underground within the boundaries of UGPF station,

• Piping systems, laid above or underground within the boundaries of OGRF station.

Vendor shall obtain prior written approval of Company for any deviations from the requirements of the following:

• This specification,

• Norms and Standards referred,

• Related documents mentioned in this specification,

• Accompanying Attachments listed in this specification.

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DETAIL DESIGN OF ORON GAS PIPELINE ---:::----;·····--·:---:----:::-:-=-::----.------------------,-----·

Project number: F456 j Doc No: 1204501-ILFL-PHS·A-0005 I Rev: B ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

1.4 APPLICABLE CODES AND STANDARDS

The latest editions or revisions of the following standards are part of this specification and shall

be taken into consideration:

DPR (HOLD)

DPR P-1P

ASME 831.3

ASME 831.8

EN 12502

Procedure guide for the design construction of oil and gas surface

production facilities

Guidelines and procedures for the design, construction, operation and

maintenance of oil and gas pipeline system in Nigeria

Process Piping

Gas Transmission and Distribution Piping Systems

Protection of metallic materials against corrosion.

National standard and codes applicable for tests shall be applied.

In case of contradiction in requirements of mentioned standards, more restrictive have to be

taken into account.

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I Doc No: 1204501-ILFL-PHS-A-0005 I Rev: B ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

2 BASIS FOR PRESSURE TESTS

2.1 GENERAL

The reference conditions of the process gas (normal conditions) are defined as follows:

• Pressure: 1.013 bara

• Temperature: 273.15 K

2.2 UGPF SITE CONDITIONS

Seismic Zone Zero (0) zone

Elevation 35 m above sea level

Design barometric pressure 1.013 bara

Design Wind Speed for Structural 144 km/hr (40 m/s).

Design -·~-~~-.. -·

Soil resistivity measurements < 10 O.m to> 1,000 O.m

Soil temperature zooc at 1.5 m depth

Ground Temperature +25oc- +27SC

Thermal insulation design criteria 23"C@ 100% humidity

Table 1 UGPF Site Conditions

2.3 OGRF SITE CONDITIONS

Seismic Zone Zero (0) zone

Elevation 20 m above sea level r-----------··-·····-·--···-----------

Design barometric pressure 1.013 bara

Design Wind Speed for Structural 144 km/hr (40 m/s). Design

Soil resistivity measurements < 10 O.m to> 1,000 O.m

Soil temperature 20oc at 1.5 m depth

Ground Temperature +25aC- +27.SOC

Thermal insulation design criteria 23°C @ 100% humidity -----~-- ·----·

Table 2 OGRF Site· Conditions

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DETAIL DESIGN OF ORON GAS PIPELINE ~~~~--~-~~-------------------------------,,-----------------·-

Project number: F456 I Doc No: 1204501-ILFL·PHS-A-0005 l Rev: B ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

2.4 ENVIRONMENTAL CONDITIONS

The Project area is located in the semi-hot equatorial zone. The climate reflects conditions

of the equatorial rain forest where the temperatures and humidity are high. High and persistent

rainfall, even in the dry months, characterizes the project area.

It is a very corrosive environment with soil pH value of 6.2 and prevalent acid rains.

About 689-749 mm of rainfall between July- September.

Heavy rainfall can be expected in the rainy season April through October.

Lightning is very frequent in the rainy season (April - October).

Sand, Dust: Prevalent during the Harmattan season (November I December- January). During

this period the atmosphere is laden with fine dust of about 5 microns or less. ·······- •~•••m

Seasonal

Prevailing Wind From April to September: South west

From September to April: North

Design wind velocity 128 km/hr (35.6 m/s) -- ·····~-

Design Wind Speed for Structural Design 144 km/hr (40 m/s)

Peak maximum ambient temperature 41°C

Minimum ambient temperature 18"C ··-

Mean maximum ambient temperature 31°C -------·-··-·---

Mean minimum ambient temperature 23°C

Black Bulb Temperature 60°C

Minimum average relative humidity 84% . P~·-

Maximum relative humidity 100% ..

Mean annual total rainfall 4345 mm ··················------

Design average annual rainfall 4500 mm ( 180 in)

Design mean maximum hourly rainfall 100mm --····-······-·--- .

Table 3 Environmental Condition for the Oron Pipeline Project

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number: F456 I Doc No: 1204501-ILFL-PHS-A-0005 I Rev: 8 ACCUGAS No: 1204501 ..

PIPELINE AND PIPING PRESSURE TEST=-=p~~H::-::LIL--=o=-s-=o-=p-=-=H=-=Y----1

3 HYDROSTATIC I AIR PRESSURE TESTING

3.1 PIPELINE TESTING- ASME 831.8

3.1.1 GENERAL

In general the hydrostatic pressure tests shall be performed in accordance to ASME 831.8.

As soon as possible after the start of construction (this information shall be provided by

the Company), the Vendor shall submit a proposal for dividing the pipeline into pressure test

sections for the approval by Inspection Authority and Company. As far as possible only one

golden weld (final tie in weld, not subject to pressure strength testing) shall join the hydrostatic

testing sections. The number of tests and the section length are listed below (see Table 4}.

The Vendor has to supply and install all auxiliary materials necessary for the pressure test, such

as provisional scraper traps (if required), scrapers, end caps, fittings, flanges, gaskets, pumps,

compressors, measuring equipment, etc. All such auxiliary materials shall be suitably rated to

the maximum test pressure; the assembled test equipment shall be approved by Inspection

Authority and Company.

Vendor is obliged to locate an approved water supply for filling and testing, and is responsible for disposal of water. The required water demand and the water extraction are defined in

the planning approval application.

Personnel, vehicles, communications equipment, warning signs, supervision of crossings and

public places is in the scope of the Vendor.

Vendor has to prepare a detailed procedure for cleaning, gauging, hydrostatic testing, drying

and caliper pigging of the pipeline test sections according the standards above and the following

descriptions.

No later than six (6) weeks before start of pressure testing a detailed program for the pressure test has to be submitted by the Company. This program is subject to the approval of the Inspection Authority, involved Inspection Authority and Company.

The Vendor has to obtain written approval for the starting of every pressure test from the Inspection Authority and the Company.

A preliminary edition of the test procedure based on the project drawings including all

calculations shall be revised according to comments by the Inspection Authority and the Company.

The final procedure will be defined together with the Inspection Authority and the Company, and will be based on pipe-log and as built measurements.

The following table lists the Contractor's proposal of anticipated major hydro test sections. This proposal needs to be verified by Construction Company.

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DETAIL DESIGN OF ORON GAS PIPELINE

Project number! F456 1· r·

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-A-0005 Rev: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

In addition a number of crossings shall be hydro-tested separately (pre test) and will be defined

in the crossing list.

Start End Item Type Name Point Point Length Water from Water to

Name Name m Stream

UGPF or 1 Pipeline

Oron Gas UGPF

crossing 17172 Stream at Stream at

Pipeline at 17+172 17+172 17+172

Stream stream at Stream at

2 Pipeline Oron Gas crossing OGRF 18328

17+172, 17+172, Pipeline at OGRF or OGRF or

17+172 Cross River Cross River

Tie-in To

3 Pipeline Oron Gas OGRF

Adanga 2291 Cross River Cross River Pipeline -

Calabar oioeline

Table 4 Contractor's proposal of testing sections of pipeline. ()

3.1.2 CLEANING PIG RUNS

Before starting any water filling and hydro-test pressure works on the pipeline, the Vendor shall

have undertaken cleaning pig runs using a series of scraper pigs and swabbing pigs, to ensure

that all extraneous materials have been removed from the pipeline section and that

the respective section is sufficiently clean to permit water filling to commence.

The Company shall make the final decision in respect of pipeline cleanliness, and if so required,

the Vendor may require undertaking additional cleaning runs.

3.1.3 GAUGING PIG RUNS

After line cleaning is completed, the Vendor shall be required to carry out a gauging pig run with

an aluminum plate fixed behind the first cup rubber of the pig.

The size of the gauging plate shall be 98% of the minimum nominal internal diameter minus 10

mm of the test section and shall be made from 10 mm thick aluminum.

Gauging pig runs shall have an induced back pressure of 0.5 bar minimum adjusted at

the receiver end.

The gauging run shall help identify obvious reductions in pipe bore caused by buckles, dents,

wrinkles or flattening. The introduction of the gauging pig into the pipeline and removal of

the pig from the pipeline shall always be undertaken in the presence of the Company. UNCONTROLLED UNLESS WITH ORIGINAL SIGNATURES

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DETAIL DESIGN OF ORON GAS PIPELINE

:~~~~~~~:e~~~:~g1 I Doc No: 1204501-ILFL-PHS-A-000~- --~- Rev: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY ________________ __J

A detection device shall be applied to the gauging pig and tracked by the Vendor.

If damages noted to the gauging plate after completion of the gauging run, the Vendor shall be

responsible to locate the defect and repair it at his own costs. The sole approval of the gauge

plate is at the discretion of the Company.

3.1.4 WATERFILLING

Once the gauging plate has been accepted by the Company, the Vendor shall then continue

with his hydro-testing operations by filling the test section.

The required water demand and the water extraction are defined in the planning approval

application. Test water shall be fresh, clear and clean and shall have a pH-value between 5 and

8. The proportion of corrosive salts shall not exceed 1000 mg/1.

If test water is to be maintained in a pipe section for more than 7 days, the pH-value shall lie

between 6 and 7.5, and the salt content shall not exceed 500 mg/1.

The quality of the water has to be analyzed by an accredited laboratory according EN 12502

and the report delivered to the Inspection Authority and the Company.

The Vendor shall be required to minimize water volumes used in the pipeline hydro testing

process. Wherever possible, water shall be passed from one completed test section into

the next adjacent section passing downstream between the various test sections wherever

practicable. The procedure of water filling and removal of the sections shall be approved by

the Company.

For the prevention of vacuum (air locking) during the water filling, the minimum back pressure of

the air in front of the pig and the water filling has to be 0.5 bar higher than the pressure of the water column plus 0.5 bar reserve pressure at the highest point in the filled water line.

The filling has to be performed with a filling rate of 0,5 - 1,0 m'/sec, with minimum two pigs with

a water batch in front of the pigs and a water batch of approx. 200m between.

The filling should be performed without interruption, and the design of the suction line of

the pump should prevent sucking of air and foreign material.

Venting of all devices, valves and nozzles shall be carried out.

When the test section is completely filled, a period of time shall be permitted to allow thermal

stabilization between the soil temperature and that of the fill water.

The Vendor shall also consider the use of environmentally suitable and non pollutant chemicals

to prevent internal corrosion of the pipeline section.

The Company shall be required to approve any corrosion inhibition products to be used by

the Vendor prior to any use of such products.

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DETAIL DESIGN OF ORON GAS PIPELINE

:~~j~~~~u~:e~~~:~~1 I Doc No: 1204501-ILFL·PHS-A-0005 I Rev: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

The Vendor shall identify in his test procedures how he will safely and environmentally dispose

of such additives, and protect the workers handling such additives

3.1.5 HYDROTESTPROCEDURE

The procedure should be performed as follows:

General hydro test procedure

The general hydro test procedure with cleaning, gauging, filling, hydro testing, dewatering and

final swabbing is defined as a general procedure for carrying out hydro test activities.

The general hydro test procedure shall include all relevant technical details such as stress

levels, test pressure, durations, time schedule, testing equipment specifications and installation

typical, pre-testing procedures, limitations, climate conditions requirements, personnel

qualification, safety aspects etc.

This general hydro test procedure is expected to be issued for approval by the Vendor and be

approved by Inspection Authority and Company.

The Vendor shall identify the location of both ends of the sections to be hydro tested by

chainage, showing information about elevations of the end points, the high and low points and

the point of change in pipe material together with the calculated pressures at these points and

the location of the pump {low point of section where possible).

The sectioning, the pressures, and the section sequence has to be agreed by Inspection

Authority and Company.

Detailed hydrostatic test procedure

Vendor shall schedule high pressure testing sufficiently in advance and submit his test

procedures and test plans to the Inspection Authority and Company for approval.

All details of the hydro tests for each pipeline section to be tested shall be submitted at a minimum of six (6) weeks prior to the commencement of work for each section to

the Inspection Authority and Company for approval. As-built pipe log and as-built survey data

for the hydrostatic testing section shall be available at least two (2) weeks prior to

commencement of pressure testing.

The detailed hydrostatic test procedure shall include but is not limited to the following:

• Hydraulic Profile of test section showing low and high points, test pressure at all key

locations, fill and test pump location, water ingress and egress points, section volume,

• Locations of temperature measurements,

• Calculation of test pressure and test volume,

• The complete list of proposed equipment, material and installations, UNCONTROLLED UNLESS WITH ORIGINAL SIGNATURES

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Project number: F456 I ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS·A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

• Data sheets of the instruments (pressure, volume, temperature) with tolerances according

test requirements including the calibration certificates not older than 3 months satisfying

national standards,

• Material Safety and Data Sheets and trade names of any corrosion inhibitors which may

be used with the hydro test water,

• List of personnel responsible for carrying out testing operations, including names and

CV's of the responsible personnel,

• Safety precautions which identify the hazards and risks involved and what measures shall

be incorporated into the work procedure to mitigate these risks,

• List of authorities like police, fire brigade, ambulance services, crossing authorities, etc.

for notifying,

• List of involved landowners for notifying,

• Plan for supply and disposal of water,

• Procedure for filling and emptying the sections,

• Procedure for performing pressure test and data recording,

• Procedure for repair.

Safety aspects

The testing equipment shall be placed in a safe distance from the pipeline under test or be

protected by energy absorbing walls or sandbags.

Any pressure testing activity shall only be allowed after completed civil works, welding, coating,

backfilling along the pipeline section to be tested.

Free communication shall be ensured between pressure test engineer and his crew.

Caution signs and guards at areas with high risks for personal and environmental damages

Stand-by emergency crews shall be available to deal with washouts or other damages.

Qualification test crew

The test crew shall be directed by an experienced pressure test engineer with thorough

theoretical knowledge and practical experience in performance and calculation of pressure

tests.

Personnel for performance shall be adequately trained to the proper use of the equipment and

familiar with the safety precautions. For supervision of main crossings and other places with

high risks of damage to persons or environment, one person shall be present during

the pressure raise and the pressure test. During leak test the section needs only supervised by

mobile patrols.

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--······.

DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

3.1.6 HYDRO TEST PERFORMANCE

The hydro test work shall always comply with the agreed number and characteristics of equipment, materials and installation, the established safety precautions and the number and

qualification of people assigned to the hydro test procedure.

Special points such as major crossings are to be installed using pre-tested pipe, where shown in the crossing list. Those crossings installed with pre-tested pipe may also receive a final

hydrostatic test, along with the rest of the pipeline section.

All testing operations shall be directed from one end of the pipeline section where work is being performed.

Supervisory personnel of the test shall remain at this test point, where pressure and temperature measurement and recording instruments shall be installed in a mobile

measurement trailer.

At the other end of the section, a pressure gauge and thermometer recorder shall be installed

and shall be attended.

Additionally ground I pipe wall temperature probes shall be installed at selected locations along

the pipeline, normally 0.5 km from the ends and in distances of 2.5 km. These probes shall be installed at the same depth as the pipe itself to help substantiate any pressure losses due to

thermal variations.

Pressure test

The pressure test has to fulfill the requirements of ASME 831.8.

Before pressure test a drain test shall be made for calculation of the air content in the pipeline.

The water drained or injected into the pipeline shall be carefully measured and the quantity,

together with times, temperatures, pressures has to be properly recorded. The pressure rise

and reduction shall not be faster than 2 bar/min.

Leak test

The leak test has to fulfill the requirements of ASME 831.8. The duration of the tightness test is minimum 24 h.

Leakage and repair

If considerable pressure drops occur, that cannot be attributed to thermal changes during

testing, the Vendor shall determine at his own cost the cause. In the case of a pipeline leak,

the Vendor shall locate the defective location.

The Vendor shall safely vent the pressure to minimum 1 atmosphere before undertaking any

remedial repairs.

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Project number: __ F.456 l ACCUGAS No: 1204501 Doc No: 1204501-ILFL·PHS-A-0005 ,--·- Rev: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

The Vendor shall then conduct a complete repair in accordance with the approved instructions

and the specifications.

On completion of repair the Vendor shall repeat the entire hydrostatic test activities according to

the project requirements described previously.

3.1.7 AFTER TESTING

Dewatering

After hydrostatic testing the pipeline shall be completely dewatered by using sufficiently sized

air compressors to launch the dewatering pigs, previously installed in the section prior to filling

the line. These pigs shall be driven from the launcher end of the section towards the receiver

end. The pigs will drive the hydro test water, and where possible, the water shall be transferred

into the next adjacent test section. Any additional fill water volumes and water additives needed

for the adjacent test section shall be added as necessary.

Pressure test sections are often limited by compressor capacities needed to empty the pipe

section. Therefore the Vendor shall bear in mind that length and difference of geodetic elevation .

of the section is selected such as to allow proper emptying of the line.

Before starting dewatering the Vendor shall submit to Company a detailed procedure for

approval.

During any drainage operations, Vendor shall make the necessary arrangements for the drained

water to be suitably disposed of, in order to avoid pollution, damage to crops, to land, to existing

works, obstructions to traffic and to comply with planning approval agreements, The water may

be drained and disposed back to the waterbody from where it came or to another discharge system, which is defined in the planning approval notification. The Vendor shall comply with

the requirements of the water authorities. Vendor shall therefore bear in mind these provisions

during the scheduling stage of hydrostatic tests. ·

Swabbing Pig Runs

Once dewatering of the section is completed the pipeline section shall be dried to an acceptable

level by use of foam swabbing pigs to remove any free residual water. Once the foam pig runs

have been completed and the Company accepts the level of drying, the previously tested block

valve fabrications shall be installed in the line and the valve ball fully opened prior to the calliper

survey.

At the end of the testing and drying operations, the Vendor shall remove the provisional pig

traps as well as other temporary installations connected with the test. He shall also complete

the tie-in of the pipe sections to the previously tested section of pipeline and carry out all work

according to the project specifications and procedures described in this specification. These .

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PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

final tte-in welds shall be considered as Golden Welds and shall be 100% radio graphed and

100% ultrasonically inspected.

Drying

Drying operations shall commence immediately after completion of the dewatering operations of

the hydraulic test section.

Pipeline section drying shall be continued until a water dew point of -10° C is obtained.

Pressure, flow, temperature and dew point shall be monitored at the inlet and outlet ends.

Pipeline drying shall be carried out by introducing a large quantity of dry air into the pipeline

section at a low pressure (1 to 2,5 bar at inlet) so as to maximise water absorption. The air

before being introduced into the pipeline shall be dried to a dew point not less than 20°C below

the dew point value specified for the pipeline.

The dry air shall be used to drive high sealing pigs in a pig train. Each pig shall be separated

from the other by at least 250 meters of pipeline.

Pigging of the pipeline section shall continue until the water dew point of the air measured at

the pipeline end remains below the specified dew point and does not fluctuate more than 4°C

whilst a new pig is sent in the line. When the specified dew point is maintained, drying is

completed and the pipeline shall be blocked in at a pressure of 1 bar.

Contractor shall prepare a procedure defining pipeline drying including, but not limited to:

• Drying method procedure description, to be defined of the basis of environmental local

information and prescribed water dew point, complete of acceptance criteria,

• Calculations of the pressure/time curves for the evacuation of water, saturated air and

water vapour for all phases of drying,

• Sizing and rating of the drying equipment,

• Details of all equipment, materials and spares needed, indicating the type and rating of all

equipment,

• Procedure for monitoring pipeline pressure and dew point at both ends of the pipeline

section,

• Power supplies and/or fuel for air compressor drivers,

• Procedure for controlling the compressor mass flow capacity and suction pressures,

• List of nominated personnel supervising the activities with dates and time of duty, location

and duration of activities of all personnel required,

• Procedure for locating and tracking pigs,

• Contingency/recovery procedure to dislodge a stuck pig,

• Pig type and design details of temporary pig launchers/receivers,

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Project number: F4sa I Doc No: 1204501·1LFL-PHS·A-0005 [ Rev: B ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY _______ ___,

• Safety precautions including fire fighting facilities,

• piping and fittings to handle the test water and the drying medium.

For mechanical completion the Vendor is responsible to test /certify the overall water dew point

in the pipeline at -1 o·c.

3.2 PIPING TESTING - ASME 831.3

3.2.1 GENERAL

Prior to initial operation and after completion of the applicable examinations, each piping

system, except for the instrument air tubing, shall be tested to ensure mechanical strength and

tightness. The test shall be executed in accordance with ASME 831.3 and. Company standard

practice.

A written procedure outlining the scope and boundaries of each test shall be done, to assure

that it is performed in a safe manner.

Test pressure will be indicated on drawing approved for construction.

Prior to the test, a detailed review of the section of the line to be tested shall be made and

assure that the following requirements are fulfilled:

• Temporary supports for those sections where the permanent supports were not designed

to take the additional weight of the test fluid,

• Isolation or restraints on expansion joints,

• Isolation of equipment or valves which may be overstressed at test pressure,

• Need for additional test pressure gauges if there is a significant head variation due to elevation differential,

• Sufficient vents and drains,

• Relief valve to preclude excessive overpressure due to possible thermal expansion of

the test fluid,

• Accessibility to the weld joints for inspection. The welds must be left exposed until after

the test,

• Assurance that no part of the system will exceed 90% of its yield strength.

Relief and check valves shall be removed.

For carbon steel pipe, the testing medium shall be potable water.

Instrument air piping shall be tested by dry air or nitrogen.

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DETAIL DESIGN OF ORON GAS PIPELINE ·:;:--:----:--=-:--::----r------------------,----------··-Project number: F456

ACCUGAS No: 1204501 Doc No: 1204501·1LFL·PHS-A-0005 Rev:B

L_ PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

3.2.2 TESTING

Before pressure testing piping system shall be thoroughly flushed. For flushing fresh water shall

be used. Instrument air system shall be blown. After flushing/blowing system shall be clean.

System shall be filled with the medium selected for testing. The medium shall have ample time

for setting and, in case of water, to allow the entrapped air to be vented.

Records and gauges shall be calibrated and certified in accordance with Inspection Authority

requirements and accepted by Company. Certificates shall be kept on site for inspection.

The minimum test pressure shall be measured at the highest point of the system.

Testing period shall commence after approval of Inspection Authority or Company.

The pressure shall be maintained for the period mentioned in the pressure test procedure or as

long is required by Inspection Authority or Company.

During test period each welds (welds can not be painted before test), flange connections and

piece of equipment shall be carefully checked for leakage. Any leaks found shall be corrected

after de-pressuring the system. After correction of leaks or defects the system shall be retested.

If, during the test period, the pressure changes due to temperature variation of the test medium,

a correction calculation shall be part of the test report.

All tests shall be witnessed and approved by Company and if required by Inspection Authority.

3.2.3 AFTER TESTING

After successful completion of the test, the system shall be drained promptly and be drained

according to a Company approved procedure.

After completion of piping system water pressure testing, all piping shall be dried using hot air to

achieve a dew point -1 0°C.

For Company request system can be filled with nitrogen.

3.3 HYDRO/AIR TEST DOCUMENTATION

The hydro/air test results indicating both successful and failed hydro/air tests shall be

documented and made available to the Company.

Thedocumentation shall be issued according to the hydro/air test procedure with a general part

and an individual part per test section.

Vendor shall furnish the test documentation for approval by the Company.

The paperwork to support and document these activities shall be structured as follows:

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS·A-0005 Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

• General part with final hydrostatic/air procedure, overall plan, time schedule, HSSE plan, personal data sheets, equipment list, calibration certificates, instrument data sheets, typical, etc.

• Individual part with:

• Reports for water filling, equalization, drain test, pressure test, tightness test and

faults together with relevant pipe book, permits, diagrams, calculations and drawings,

• Company acceptance certificates for cleaning, gauging, drain test, pressure test, leakage test,

• Inspection Authority acceptance certificate for the successful performance of the hydrostatic/air test according the national Standards.

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DETAIL DESIGN OF ORON GAS PIPELINE -.::P-:-ro-:j:-e-ct=-n-u-m-:b:-e-r-: =F4-:-c5::-::6:--.-l-o_o_c_N_o·-. 1_2_0_4-50_1_·-IL_F_L--P-H-S---A--0-0_0_5--,.--~----~~~: 8-----­ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

4 INSPECTION

The Vendor shall provide Inspection Test Plan (I&TP) and Quality Assurance Plan (QAP) for

review and acceptance.

All items and equipment referenced within this specification shall be subject to inspection by

the Company or by nominated Inspection Authority.

All inspections activities to be performed, including any special requirements, shall be agreed

with the Company and shall be incorporated within the agreed Quality Control Plan provided by

the Vendor.

Any approvals given by the Company's Inspector or the Inspection Authority do not relieve

the Vendor of any responsibility regarding compliance with applicable standards and regulations

and this specification (unless a specification deviation is explicitly agreed}.

All certifications of instrumentation, quality-control tests and inspections records shall be kept

for 15 years and be available for the Company on request.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

5 ENGINEERING

Vendor is responsible for providing reports, documents and services during test pressure as

specified below:

• All detail pressure testing works executed by the Vendor;

• Documentation listed in Paragraph 8;

• Company approval of pressure testing works.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL·PHS-A-0005 -~ Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

6 TIME SCHEDULES

6.1 TIME SCHEDULE

On the basis of the delivery dates defined in the Contract, Vendor shall supply a time schedule for approval by the Company which shall be based on the schedule given in Paragraph 9.

6.2 WORK SCHEDULE

Supplier shall produce a detailed work schedule based on time schedule.

A erection schedule shall be submitted to the Company according to document exchange schedule in Paragraph 8. A revised form of this schedule should then be submitted at the beginning of each week listing the actual work progress and, if necessary, including any additional detailed time schedules. Construction site meetings, which the Vendor must attend, should take place on a weekly basis. The results of these meetings will be recorded by

the Company's construction supervisor.

6.3 WORK REPORTS

After the contract award, weekly reports on construction progress shall be submitted to

the Company.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

7 DOCUMENTATION

7.1 GENERAL

Documents which shall be submitted by the Vendor are given in a list- see Paragraph 8.

Clarification and exceptions shall be included in tender documents.

7.2 CONTRACT DOCUMENTATION REQUIREMENTS

7 .2.1 INTRODUCTION

Vendor is obliged to prepare contract documentation according to Company's requirements and

to submit it in accordance with schedule shown in Paragraph 8.

Minor adjustments may be done to the schedule (for bilateral agreement) after signing

the contract. Such adjustments shall, however, not justify the Vendor to revise the contract

price.

The Vendor shall prepare a model document (based on templates and instructions prepared by

Company) of each document type that is listed in Paragraph 8. The model document shall be

submitted to the Company for agreeing the typical format and contents of the document.

All calculation shall be carried out in a clear and logical manner. The source of formulas or

methods shall be clearly referenced. Computer calculations will only be accepted if all input is

shown, together with calculated values of intermediate terms and factors and the computer

program has been validated to the satisfaction of the Company.

Vendor is obliged to present necessary technical data on Company's demand.

The Company shall provide his comments on the model document within two (2) weeks after

receiving the document. The Vendor shall revise and re-issue the document in accordance with

agreed changes within two (2) weeks from receiving the comments.

7 .2.2 LANGUAGE

All correspondence and documents shall be delivered in English language.

Final documents shall be delivered in English language.

7.2.3 UNITS

The parameter values and measures within all the documents shall be given in St units.

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Project number: F456 ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS-A-0005 Rev: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

7.2.4 DOCUMENTATION DELIVERY

Schedule of the documents and drawings to be delivered by the Vendor and/or the Company are listed in Paragraph 8.

The Vendor's documentation shall be made available in electronic version. It is not going to be

accessible for any parties other than Company I Vendor, unless the parties agree on exceptions.

All submitted documents and drawings shall be revised to comply with the implementation

status, and status information shall be inserted (whenever applicable) in the documents and

drawings:

• Issued for Approval = IFA

• Issued for Construction = lFC

• Issued for Review= IFR

When amendments are made, each amendment shall be recorded and indicated clearly in

the new issue of the document.

The Vendor shall also submit to Company the necessary documents for authority applications.

including technical appendices.

7.3 FINAL DOCUMENTATION

The Vendor shall provide the final documentation as follows:

• Paper copies in clearly marked files 3 set(s);

• Electronic copies on clearly designated CD/DVD-ROM 2 set(s).

Final documents shall be delivered in English language.

The Company shall review the final documentation within four (4) weeks from the date of its delivery. The Vendor shall correct any defects, omissions or errors found in the final

documentation within two (2) weeks after receiving a Company's note including a complete list

of such items.

The Vendor shall deliver the paper copies of all revised final documents directly to the binders

submitted earlier to the Company or he shall provide a new, complete binder.

Completely new CD/DVD-Rom shall be delivered should any of it contents have been revised.

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DETAIL DESIGN OF ORON GAS PIPELINE Project number:"i='4s6--~

ACCUGAS No: 1204501 Doc No: 1204501·lLFL·PHS·A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

8 SCHEDULE FOR INFORMATION EXCHANGE

This schedule determines Contract requirements for the type of documents and drawings that

the Vendor shall submit with all the equipment in this specification.

Documents with delivery date during the same week shall be delivered in one single package.

The documentation delivery package shall be dispatched (i.e. uploaded to the documentation

centre server) on Friday of the week mentioned, followed by a separately mailed transmittal.

Individual documents shall be issued in case of special questions.

DOCUMENT REQUIREMENTS

WITH BID

REVIEW REQUIRED

QUANTITY REQUIRED

WEEKS AFTER AWARD

WEEKS AFTER EXECUTION

REMARKS

~ E

A CONTROL DOCUMENTS

A01 DRAWING/DOCUMENT SCHEDULE y 3 2 To be submitted every 4 weeks

A02 SERVICE SCHEDULE y 3 2 A03 SUB-ORDER SCHED/COPY SUB-ORDERS

A04 WEEKLY PROGRESS REPORT y 1 4 To be submitted every week

A05 CONTRACT SPECIFIC INSPECTION & TEST y 3 2 PLAN A06 CERTIFICATE OF APPROVAL

A07 QUALITY MANUAL

A08 TYPICAL QUALITY PLAN

A09 CONTRACT SPECIFIC QUALITY PLAN y 3 4

B ARRANGEMENTS

B01 KEY DESIGN SKETCH

B02 GENERAL ARRANGEMENT

B03 INTERFACE/CONNECTION SCHEDULE

804 UTILITY REQUIREMENT y 3 2 B05 FOUNDATION DRAWING

c SCHEMAnCS

C01 PFD AND HEAT AND MASS BALANCE

C02 P&ID

C03 CAUSE AND EFFECT CHART

C04 CONTROL PHILOSOPHY/BLOCK LOGIC

C05 OPERATING PHILOSOPHY

coo FUNCTIONAL DESIGN SPECIFICATION

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501

·--~··---

Doc No: 1204501-ILFL·PHS·A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

DOCUMENT REQUIREMENTS

WITH BID

REVIEW REQUIRED

QUANTITY REQUIRED

WEEKS AFTER AWARD

WEEKS AFTER EXECUTION

REMARKS

~ E

D DATA SHEETS

D01 UNIT DATA SHEET(S)

D02 ACTUATOR DATA SHEET(S)

003 INSTRUMENT DATA SHEET{S)

D04 WEIGHT DATA SHEET

005 NOISE DATA SHEET{S)

006 COUPLING DATA SHEET(S}

E CALCULATIONS & PERFORMANCE DATA

E01 DESIGN/CODE CALCULATION

E02 PROCESS/UTILITY CALCULATION

E03 STRUCTURAL, FOUNDATION & SUPPORT CALC

E04 ROTATING ELEMENT CALCULATION

E05 INSTRUMENT SIZING CALCULATION

E06 PIPING STRESS ANALYSIS

E07 PRIME MOVER PERFORMANCE CURVE

E08 DRIVEN EQUIP PERFORMANCE CURVE

E09 ELECTRICAL CURVES

E10 RELIABILITY/AVAILABILITY ANALYSIS

E11 PULSATION STUDIES

E12 HEAT DISSIPATION

F DETAIL MECHANICAL AND PIPING DRAWINGS

F01 EQUIPMENT DETAIL DRAWING

F02 ANCILLARY PIPING DRAWING

F03 CROSS SECTION

F04 PARTS LISTiBILL OF MATERIAL

F05 SEAL DETAIL

F06 INSULATIONiLINING DETAIL

F07 STRUCTURE AND PLATFORM DRAWINGS

G DETAIL INSTRUMENT DRAWINGS

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-----------------------------··-··-···--········· DETAIL DESIGN OF ORON GAS PIPELINE

:~~~~~~u~:e~~~;:g1 I Doc No: 1204501·1LFL-PHS-A-OO~-~-·--·--~- -----~~~: B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

DOCUMENT REQUIREMENTS

WITH BID

REVIEW REQUIRED

QUANTITY REQUIRED

WEEKS AFTER AWARD

WEEKS AFTER EXECUTION

r!:l REMARKS

E

G01 INSTRUMENT LOCATION DRAWING

G02 INSTRUMENT SCHEDULE

G03 WIRING SCHEMATIC DIAGRAM

G04 TERMINATION DETAILS (FIELD CONNECTION)

G05 PANEUCABINET LAYOUT

G06 LOGIC DIAGRAM

GO? HOOK- UP DIAGRAM

GOS LOOP DIAGRAM t= G09 CABLE BLOCK DIAGRAM

G10 INSTRUMENT OUTLINE DRAWING G11 SERIAL LINK G12 GRAPHICS

H DETAIL ELECTRICAL DRAWINGS

H01 ELECTRICAL SINGLE LINE DIAGRAM

H02 ELECTRICAL LAYOUT DRAWING

H03 SCHEDULE OF ELECTRICAL EQUIPMENT

H04 CABLE SCHEDULE

H05 INTERCONNECTION DIAGRAM

H06 TERMINAL BLOCK DIAGRAM

H07 DISTRIBUTION BOARD SCHEDULE

J MANUFACTURING PROCEDURES

J01 QUALIFIED WELD PROC. (WPS & PQR)

J02 NDE PROCEDURES

J03 HEAT TREATMENT PROCEDURES (if applicable)

J04 PAINTING/COATING PROCEDURE

J05 MATERIAL SPECIFICATION

J06 OPERATOR QUALIFICATIONS

K TEST PROCEDURES

K01 FUNCTIONAL & PERFORMANCE TEST

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DETAIL DESIGN OF ORON GAS PIPELINE Project number: F456 I

ACCUGAS No: 1204501 Doc No: 1204501-ILFL-PHS·A-0005 I Rev:B

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

DOCUMENT REQUIREMENTS

WITH BID

REVIEW REQUIRED

QUANTITY REQUIRED

WEEKS AFTER AWARD

WEEKS AFTER EXECUTION

REMARKS

~ E

K02 HYDROSTATIC/PNEUMATIC TEST y 2 4

K03 MATERIAL TEST

K04 WEIGHING PROCEDURE

K05 FACTORY ACCEPTANCE TEST

K06 SITE ACCEPTANCE TEST

K07 MPI TEST PROCEDURE

K99 LISTING OF PROCEDURES USED

L CERTIFICATION

L01 MANUFACTURING RECORD BOOK INDEX

L02 MANUFACTURING RECORD BOOK

L03 MATERIAL CERTIFICATES

L04 HAZARDOUS AREA CERTIFICATES

L05 CODES/STANDARD/COMPLIANCE CERT. y 3 2

L06 TEST RESULTS y 3 2

L07 SPECIFICATION WAIVERS

L08 TYPE TEST CERTIFICATES

L09 INSPECTION RELEASE NOTE y 3 2

M HANDLING & SITE INSTALLATION

M01 DOCUMENTS TRAVELLING WITH GOODS

M02 PACKING & SHIPPING INSTRUCTIONS

M03 PRESERVATION PROCEDURE

M04 INSTALLATION INSTRUCTIONS

M05 FIELD FABRICATION ITEM

M06 MATERIAL PASSPORTS

M07 TRANSPORTATION DWG

MOS ERECTION SCHEDULE

N OPERATING INSTRUCTIONS

N01 SPARE PARTS LISTS OR DATA PACKAGES

H N02 OPERATING & MAINTENANCE MANUAL

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DETAIL DESIGN OF ORON GAS PIPELINE

---;~~~t;;~:e~~~::g1 J Doc No: 1204501-ILFL-PHS-A-0005 . [ Rev: B PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

DOCUMENT REQUIREMENTS

WITH BID

REVIEW REQUIRED

QUANTITY REQUIRED

WEEKS AFTER AWARD

WEEKS AFTER EXECUTION

REMARKS

~ E

N03 SUPPLIER CATALOGUE y 2

N04 LUBRICATION SCHEDULE

p CIVIL/STRUCTURAL

P01 STATEMENT OF DESIGN CODES TO BE USED

P02 LIST OF COMPUTER SOFlWARE TO BE USED

P03 CONCEPTUAL CALCS FOR BUILDING STRUCTURE

P04 DETAILED STRUCTURAL CALCS

P05 PRELIMINARY GENERAL ARRANGEMENT DRGS

POS FINAL GENERAL ARRANGEMENT DRGS

P07 CONSTRUCTION METHOD STATEMENT El=l P08 LIST OF ITEMS TO BE PRE-CAST

P09 LIST OF ITEMS TO BE PRE-STRESSED

P10 LIST OF MAIN SURVEY EQUIP, TO BE USED

P11 DETAILS OF CONCRETE BATCHING PLANT

P12 DETAil FABRICATION DRAWINGS

P13 SURFACE PREP & PAINTING SPEC

P14 SPECIFICATION OF BOLTING MATERIAL

P15 PAINTING/COATING PROCEDURE

P16 BOLT SCHEDULE

P17 MATERIAL SPECIFICATIONS & CATALOGUES

P18 BILLS OF MATERIALS

P19 GIDELINES FOR FOUNDATION DESIGN

Notes:

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r-~~~-~-~~-.-----------------------.-----------1 Project number: F456 I Doc No: 1204501·1LFL·PHS·A·0005 I Rev: B

ACCUGAS No: 1204501

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

9 PROJECT SCHEDULE

Task name

Commence of pressure test works - UGPF

Pressure test works completed - UGPF

Commence of pressure test works - OGRF

Pressure test works completed - OGRF

Commence of pressure test works - pipeline

Pressure test works completed - pipeline

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Date

xx.xx.xxxx

xx.xx.xxxx

xx.xx.xxxx

xx.xx.xxxx

xx.xx.xxxx

xx.xx.xxxx

Page 30 of 31

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DETAIL DESIGN OF ORON GAS PIPELINE

-Jcr~{t~~~u~:ef~!;::~---r··---~oc No: 1204501-ILFL-PHS-A-ooo5 I Rev: s

PIPELINE AND PIPING PRESSURE TEST PHILOSOPHY

10 REFERENCED DOCUMENTS

120450HLFL-GDE-A-0001 -Project Introduction

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., QHSSE Level: 2 j Originated by:

SEPTA ENERGY RULES, PROCEDURES, AND PRACTICES Originated: Sept2011 !Revised by: -·-

' ' '-.A "

Community: Grievance Mechanism (SOP X/XXX) Revised: j Authorised by:

Community Grievance Mechanism (SOP X/XXX)

A. Purpose

The purpose of this procedure is to outline Septa Energy's approach to accepting, assessing, resolving and monitoring grievances from those affected by Septa Energy's activities including its contractors' activities.

Grievances can encompass minor concerns as well as serious or long-term issues. It is essential to have a robust and credible mechanism to systematically handle and resolve any complaints that might arise in order that they do not escalate and present a risk to operations or the reputation of the company (nationally or internationally). If well-handled, an effective grievance mechanism can help foster positive relationships and build trust with stakeholders.

This SOP should be considered in parallel to the SOP related to Stakeholder Engagement due to the inter-relationship between these two activities. It has been designed to meet the requirements of the IFC in relation to Performance Standard 1.

The mechanism for addressing employee grievances is separate and is outlined in the Human Resources Policy.

B. Scope

This procedure will be applied to community complaints and grievances, perceived or actual, at all existing and new Septa Energy facilities, properties or assets owned (in full or part) and /or operated by the company in order to manage the company's risks and relations with stakeholders. The procedure applies for the entire operation lifecycle (including exploration and planning, evaluation, construction, operation and closure).

A complaint or grievance is an issue, concern, problem, or claim (perceived or actual) that an individual or community group has related to Septa Energy and its contractors' operations and activities.

The mechanism does not impede access to judicial or administrative remedies.

C. Application

This Grievance Mechanism provides guidance to all Septa Energy employees and contractors on receiving, registering, assessing and resolving community complaints or grievances emanating from Septa's operations. The fundamental objective of this mechanism is to:

• Provide a predictable, transparent, and credible process to all parties for resolving grievances, resulting in outcomes that are seen as fair, effective, and lasting.

• Build trust as an integral component of broader community relations activities.

• Enable more systematic identification of emerging issues and trends, facilitating corrective action and pre-emptive engagement.

~~-~£~En~!~.·-··-···-···-·· -·~········-- Volume 1, Page 1 o~Q_ QHSSE Manual

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l QHSSE Level: 2 Originated by: • SEPTA ENEf!GY il--' __ R_U_L_ES_,_P_R_e>_:.ED~~~!~~-D_P._R_A_C_TI_C_E_S __ l--0-ng_ln_ated--+: Se_pt-20_1_1 -t-R4ev_i_sed_by_: -+------1

! Community: Grievance Mechanism (SOP X/XXX) Revised: Authorised by: .......... ,., ____ _,_ __ ...__ __ ..J..-__ ___.,JL----.J

D. Resources, Roles and Responsibilities

The Grievance Mechanism will be the overall responsibility of the External Affairs Manager supported by the following:

Septa Wide Community Liaison Officer

Lead the Grievance Mechanism procedure and management system, providing guidance on solutions to complaints and grievances in consultation with the relevant department and Community Liaison Officer. Ensure consistency of compensation awarded and compensation rates across Septa Energy operations.

Promote the Grievance Mechanism to maintain momentum and ensure company wide and community commitment to and understanding of its implementation and operation.

Facility or Operation Community Liaison Officer (CLO):

Based locally at each asset, responsible for the day to day running of the grievance mechanism i.e. receiving, logging, investigating, addressing and tracking grievances.

All Septa Departments and Contractors:

Receive any issue, concern, complaint or grievance from.the community, verbally or in writing. They should record the issue and report it to the community relations team in compliance with the Grievance Mechanism procedure.

Involvement in the investigations of grievances as required depending on the nature and severity of the grievance.

Board of Directors/CEO:

Ensure that Grievance Mechanism procedure is applied through all Septa Energy and contractor departments and levels.

Apply necessary controls to minimize risks that could result in community grievances.

Contribute to resolution of and sign off of any grievances which have international repercussions.

The following resources will also need to be in place:

• Trained competent employees or external resources experienced in dealing with community concerns and complaints and grievance management.

• An auditable system for receipt, recording and tracking of the process (for example a grievance log. database etc} shall be in place.

• Dedicated budget for resourcing management of Grievance Mechanism and addressing grievances through financial or in-kind compensation as and when needed.

• Identify community representative to help build external support for the use of the system and address concerns

~~Pt.~ ... Energy QHSSE Manual

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QHSSE Level: 2 Originated by: • RULES, PROCEDURES, AND PRACTICES Originated: Sept2011 Revised by: SEPTA ENERGY --~····-···----··-~----------------------

Community: Grievance Mechanism (SOP X/XXX) Revised: Authorised by: , .. ~-................... ~ ... """' _"_...__ __

E. Definitions

Table 1. Definitions of key terms

Term

Affected Party (ies)

-------··--------------------Stakeholder

Stakeholder Engagement

Grievance

--··---~----·

Grievance Database

~""

Records of communication I consultation

Facilities I Operation(s)

Vulnerable Groups

Environmental and Social Impact Assessment (ESIA)

Environmental and Socia/ Management System (ESMS)

~~ EneriD:--------·-·-·--­QHSSE Manual

Definition

Stakeholders who are affected by Septa Energy or its contractors, both positively and negatively. Within this it is possible to distinguish between those that are directly affected and indirectly affected by the company or operation.

Persons or groups that are directly or indirectly affected by a Septa Energy project as well as those that ·may have Interests in a Septa Energy project and/or the ability to influence its outcome, either positively or negatively. This can refer to shareholders, lenders, employees, communities, industry, governments and international third parties.

An umbrella term encompassing a range of activities and interactions between Septa Energy and stakeholders (two way communication) over the life of a project that are designed to promote transparent, accountable, positive, and mutually beneficial working relationships.

An issue, concern, problem, or claim (perceived or actual) that an individual or community group wants Septa Energy or its contractor to address and resolve. "--_____ ,., ____ ._.__ ... , ......

System for logging and monitoring all grievances received, including any records of communication/consultation and details of grievance settl~-r:!l~'l~: -~ ~ ___ . _

Records of communication I consultation may include key e-mails, letters, newsletters. memorandums, complaints, opportunities for improvement, records of distribution/attendance, records of formal and informal meetings and records of commitments.

A location or activity that is operated by Septa Energy. Locations could include well heads, processing facilities, pipelines, construction camps, offices including corporate head offices etc

Individuals or groups within the project area of influence who could experience adverse impacts more severely than others based on their vulnerable or disadvantaged status. This vulnerability may be due to an individual's or group's ethnicity, gender, language, religion, political views, dependence on natural resources, sickness or disability or other factors.

Process of evaluating and addressing potential social and environmental impacts and risks of a Septa Energy project and identifying any mitigation or corrective measures that will enable the project to meet the requirements of the IFC Performance Standards, applicable Nigerian laws and regulations.

A system of management or action plans necessary for c:arrying out a suite of mitigation measures. These measures can be identified during the ESIA process to ensure compliance with IFC Performance Staf}dards, Nigerl~!!'!YS a~-<!~Jigns etc.

I i I

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' QHSSE I Level; 2 Originated by:

I • RULES, PROCEDURES, AND PRACTICES Originated; Sept 2011 Revised by; ~"!A~ I

Community: Grievance Mechanism (SOP X/XXX) I Revised: Authorised by:

F. Guiding Principles

To maximise the effectiveness of the Grievance Mechanism, Septa Energy shall uphold the following values during implementation and operation of the system 1:

• Commitment to fairness in both process and outcomes; • Freedom from reprisal for all involved parties- within Septa and in the

community; • Dedication to building broad internal support for the grievance mechanism across

project lines; • Mainstreaming responsibility for addressing grievances throughout the project.

rather than isolating it within a single department; and • Willingness by senior management to visibly and sincerely champion the

grievance system.

In addition, the following principles guide Septa's Grievance Mechanism procedure:

1) This grievance mechanism complements and reinforces Septa's wider stakeholder engagement activities. Proactive engagement is essential for good relations with communities and stakeholders. The Grievance Mechanism should not be implemented in isolation.

2) Septa Energy will proactively inform affected communities and wider stakeholders of the details of the Grievance Mechanism. This will include information about where people can go and who they can talk to if they have a grievance, who can register a grievance and process timelines. This information should be widely and regularly publicized, throughout the duration of any project, through posters at key locations , advertisements in local papers I radio and verbally by Septa employees. Septa will provide the information in a format and using languages (including local languages) that are readily understandable by the local population and/or orally in areas where literacy levels are low.

3) All complaints submitted or communicated to Septa employees or contractors should be addressed in a timely and appropriate manner. This includes factual, perceived or misrepresented grievances. Unreported grievances are a missed opportunity to build trust, improve community relations and identify emerging issues.

4) A grievance can be submitted by any affected party. This includes communities directly and indirectly affected by Septa Energy's projects, civil society, local and traditional authorities, local or national government, small business owners, associations, medical and educational practitioners, NGOs and international third parties.

5) The mechanism should be culturally appropriate, clear and easy to follow with defined timelines for key process milestones. The mechanism should be sensitive to local preferences towards conflict resolution, negotiation and

1 The Office of the Compliance Advisor/Ombudsman Advisory, 'A Guide to Designing and Implementing Grievance Mechanisms for Development Projects'.

Septa Ene~g.u<y ______ . QHSSE Manual

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Community: Grievance Mechanism (SOP X/XXX) Revised: AuthOrtsed by:

cooperation taking into account understandings of authority, social status and rank, community relationships and attitudes towards third parties.

6) The Grievance Mechanism should be easy to access for communities. Septa Energy will make available a range of measures for submitting complaints including face-to-face meetings, by post, email or left in suggestion boxes, on­line submissions and by telephone. A Grievance Form for external use is provided in Annex 3.

7) The Grievance Mechanism should be readily accessible to all stakeholders and communities including vulnerable groups such as women and youth at no cost to them. Assistance should be provided to those who face barriers to participation due to language, literacy, awareness, time, distance. finance or fear of reprisal.

8) The Grievance Mechanism should not impede access to judicial or administrative remedies or seek to replace these. The mechanism should never result in any kind of retribution.

9) Septa Energy will facilitate a variety of grievance resolution approaches according to individual and cultural preferences. This includes informal processes or more formal approaches involving a third party mediator or legal redress. Traditional or customary practices should be considered and incorporated. This may include inviting respected community members to act as observers, witnesses or testifiers to give legitimacy to the resolution process. Respected community members should also be solicited for advice on settling differences in a manner that complies with and respects community norms.

10) Septa Energy will provide regular feedback to relevant stakeholders to demonstrate how the Grievance Mechanism is working, clarify its purpose, manage expectations and encourage more people to use the system. Examples can be given of how cases were managed and resolved and how outcomes changed Septa policies or procedures to inspire trust and confidence that the system works.

11) Septa will maintain a record of all grievances in a central Grievance Database system. Grievance settlements will be monitored to ensure consistency. Analysis of this record might highlight grievance or conflict trends or emerging issues, allowing mitigation measures to be put in place to avoid risk to operations. If a common issue is identified, structural changes at company level might prevent the grievance from recurring rather than resolving each case on an individual basis. Such mitigation should be included in the Project Environmental and Social Management System.

12) The Grievance Mechanism will be regularly evaluated by Septa to improve its effectiveness. The evaluation will take into consideration general awareness of the Grievance Mechanism process, level of use, who uses it, type of issues addressed, ability of process to resolve issues promptly and constructively; outcomes (changes to company operations, management systems and community benefits) and overall ability to achieve stated goals and objectives. Stakeholder feedback should be gathered and incorporated into the evaluation process where appropriate.

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Community: Grievance Mechanism (SOP X/XXX) Revised: Authorised by:

The Grievance Process

The following steps outline the process that will be followed to resolve a grievance. This process is also presented in a diagram in Annex 1. A check list of documents and resources required to complete the Grievance Process is found in Annex 8.

1. Setting up channels and methods available for registering a complaint

a. Channels: Septa Energy will establish multiple channels to collect and forward grievances from the community. A network of community representatives (community leaders, government officials, community organisations, company environmental and operational employees, community liaison officers), including at least one member that is independent of Septa Energy, should be identified to receive community's concerns and deliver them to the CLO for further action.

All Septa project and contractor staff should also be fully aware of the Grievance Mechanism process so that they know how to receive a complaint themselves and pass it on to the CLO, or else instruct community members about how they can access the Grievance Mechanism in another way.

b. Methods: Septa will set up multiple culturally appropriate methods for registering complaints including self-identified, confidential and anonymous procedures. This will include a postal, email and website address, a drop-box at all sites and in key community locations, a toll-free telephone line and hosting of face-to-face individual or group meetings. The Community Liaison Officer is responsible for receiving all complaints and logging them into the Septa Grievance Database.

The details of any Grievance Forms received (see Annex 3) should be transferred to the Grievance Log (see Annex 4) that will be used internally.

2. Logging Grievances

Septa Energy will log, document and track all grievances received within the secure Septa Grievance Database system. Grievances should be assigned a case number and records of communication/consultation should all be attached with the relevant entry. The database should be monitored regularly for recurring grievances so that appropriate mitigation can be developed.

As a minimum the following information shall be recorded:

Septa Energy QHSSE Manual

• Contact information- name, tel, address etc

• Date of complaint

• Details of complaint

• History of other complaints I queries I questions (if known);

• Prioritisation and categorisation based on Significance Criteria provided in Annex 2

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QHSSE Level: 2 Originated by:

Originated: Sept 2011 Revised by: SEPT~NERGY RULES, PROCEDURES, AND PRACTICES ' . r----···--·-······--·---·--·····-------------+----+----+----t-----1 ··· ·" ' Community: Grievance Mechanism (SOP X/XXX) Revised: Authorised by:

---·--··--------------·--- ----··- --·------··""''' "'"'--·------.J---'

• Resolutions discussed and agreed with the party(ies) in question

• Actions implemented and;

• Outcome of the actions implemented.

An example of a Grievance Log form is provided in Annex 4.

3. Acknowledging receipt of grievance

Septa Energy shall acknowledge receipt of any grievance within 7 days from the date it was submitted and shall inform the complainant about the timeframe in which a response can be expected. A grievance receipt form should be signed and a copy provided to the complainant. An example of a grievance receipt form is provided in Annex 5.

4. Investigating eligibility and severity of grievance:

Before selecting the correct procedure for resolving a grievance. the eligibility and severity of the grievance must be determimxJ. This will influence how the grievance wii! be handled, who wil//)e involved and how lonq the resolution process is likely to take.

Eligible griovances include ail those that are directly or indirectly related to Septa Enerqy's projects and that fa!! within the scope of the Grievance Mechanism as outlined above.

fneiigibie Complaints may include those that are clearly not related to any of .Seven Energy or its contractors· projects. whose issues fall outside the scope of the Grievance Mechanism procedure or where other Septa Energy or community procedures woul(} be n;or(ct appropriate lo Bddress the grievance.

The complainant should be engaged in conversation in an effort to truly understand the grievance fleforo it is cfismissed Even if a cornpfaint is invalid and unlinked to project operations, an investigation may uncover unck:rfying misperceptions and concerns w!tf1 the project. Taking seriously ali complaints submitted can increase trust in Septa ami tile project,

If the grievance is considtW:Jd e!igitJie, it musl be classified according to th('J severity anct urgency of the grievc.mce. This includes the risk it poses to both tile community a(l(1 to Septa Energy's operations and reputation Refer to the Grievance Ciassification Matrix provided in Annex 2.

Septa Energy will investigate fully all grievances submitted, involving other departments, contractors and senior management as required in this process to fully understand the circumstances that led to the Grievance. Septa Energy will aim to

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resolve any grievances within 30 days from the date that it was received. This timeframe can be extended to 60 for Level 4 and Level 5 Grievances (see below}, if required.

The following steps should be performed in a timely manner to avoid delaying resolution of a grievance:

1) Assign the grievance to a CLO to manage the grievance directly and conduct the investigation into the grievance.

2) Obtain as much information as possible from the person who received the complaint, as well as from the complainant to gain a first·hand understanding of the grievance.

3) Undertake a site visit to clarify the parties and issues involved. Gather the views of other stakeholders including Septa employees and identify initial options for settlement that parties have considered.

4) Determine whether the grievance is eligible (See box above).

5) If the grievance is deemed ineligible it can be rejected however a full explanation as to the reasons for this must be given to the complainant and recorded in the Grievance Log.

6) If the grievance is eligible, determine its severity level using the significance criteria in Annex 2. This will help to determine whether the grievance can be resolved immediately or requires further investigation and whether senior management will need to be informed of the grievance.

7) If the grievance concerns physical damage, (e.g. crop, house, community asset) take a photograph and GPS coordinate of the damage.

8) Inform the complainant of the expected timeframe for resolution of the grievance

9) Enter the findings of the investigation in the Grievance Log.

5. Grievance Settlement and Resolution Approach:

A guide to grievance settlement measures is provided in table 2 below. It is important to note, however, that most grievances should be dealt with on a case by case basis. Face-to-face discussions with complainants and community members, that seek to jointly identify and select measures for grievance settlement, will increase ownership of solutions and help to mitigate perceptions that resolutions unfairly benefit Septa Energy.

Compensation rates will be set by the Septa Wide Community Liaison Officer. These may change periodically depending on market prices thus should be regularly checked and updated by project CLOs. Compensation payments can often cause conflict or disputes thus it is important that compensation rates are applied consistently and fairly across Septa Energy operations.

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Table 2. Grievance Settlement Measures

_!Jature of grievance Settlement Measure ..... ~-----~····---~

Crop damage Cash compensation based on m2 , market price and

cost of tools/labour

Septa Energy to rehabilitate site if permanently destroyed and provide in-kind compensation (land-

- far-land) ·------

Damage to individual asset (e.g. house, • Replace asset destroyed (in-kind) fence)

• Fix asset destroyed

If complainant refuses in-kind compensation provide cash compensation at replacement value

-~--· ----··-···-·····················-··--·-----

Damage to community asset (e.g. road, • Replace asset destroyed (in kind) Infrastructure)

• Fix asset destroyed

• Provide material (in kind) and labour cost in-cash (if applicable).

'~""""""""'-A>ho>~~-·

No cash compensation, except for labour cost.

Damage to cultural heritage site (e.g. sacred • Replace cultural site . forest)

• Fix cultural site .

• Cost of traditional ceremony (if applicable)

• If community desires and location is at risk, Rio Tinto will also move the site. ---·-

Road kill Cash compensation based on the market price of the animal killed

Unfair or misapplication of recruitment Refer issue to HR and together provide explanation procedure to community via public forum -----------Lack of project information Address any specific questions and provide the

publicly available information to the complainant along with information about where to access project information in future (e.g. Septa website,

....... -~-community newsletters)

Complaints about dust Water road and discuss with operations team options to minimize dust

Complaints about quality of water Discuss alternatives with design/operations team including reinforcing erosion control or building a yvater well for the village if appropriate

Complaints about behaviour of Septa Energy Letter of apology and reprimand Septa Energy or and contractor staff contractor staff.

··~-

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• SEPTA ENERGY

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RULES, PROCEDURES, AND PRACTICES · Sept2011 Revised by: ·---

Community: Grievance Mechanism (SOP-xnooq -~;~~ised: --Authorised by:

Below are four basic resolution approaches that can be offered. Complainants should have influence over the approach selected:

• Septa Energy proposes a solution

This approach can be used for straightforward issues with obvious solutions, which Septa Energy can resolve alone to the satisfaction of the complainant. The decision to accept or reject it should be taken together thus sharing decision-making authority.

The resolution proposal should be respectful and considered, including rationale for the decision and any data used in reaching it. The case presented by the complainant during the decision making process should be acknowledged. The solution should be delivered in writing and where appropriate by the CLO to explain the response in person.

If the complainant is not happy with the proposed solution. a joint decision process (described below) should be offered. If this too is rejected, the grievance can be referred to a third party mediator or for legal arbitration.

• Septa Energy and the complainant decide together

Joint decision making approaches are the most likely to achieve a positive outcome and should be the core approach used in the grievance mechanism process.

This approach should be used for more complex cases involving a variety of stakeholders. It should also be used in situations where it is important to preserve an on-going relationship and where face-to-face engagement is valued.

Under this approach decision-making is shared and all parties engage in a join problem solving approach to resolve the grievance. The process can be informal, on4he-spot or can take a formal approach involving a mediator to help the parties reach an agreement. Good listening, information sharing, joint fact-finding, dialogue and negotiation are all essential features of this approach.

• Septa Energy and the complainant defer to a third party to decide such as village mediation committee

This approach should be used if a joint approach has been rejected or has failed to reach a voluntary settlement. It is also appropriate where there are disputes about facts or data. The third party may be a trusted individual or group In the community, an international or local NGO or a technical expert. They control the process and investigation of the grievance and make recommendations for settlement.

This approach involves joint submission of the grievance and both parties' views to the third party, who may also undertake a fact-finding process to allow an independent assessment of the grievance and the relevant Septa Energy practices. An agreement should be made with the complainant at the outset of this process about how to proceed once the results of the investigation are shared, and whether to treat recommendations as binding.

• Legal Recourse I Arbitration

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QHSSE Level: 2 Originated by:

RULES, PROCEDURES, AND PRACTICES Originated: Sept2011 I Revised by:

Community: Grievance Mechanism (SOP X/XXX) Revised: Au1hortsed by:

This is a more formal rights based approach that should only be taken if all other approaches have failed or when there are serious conflicts about facts and data. The final decision will be taken by the courts based on compliance with laws, policies, standards, rules, regulations, procedures, past agreements or common practice.

6. Communicating Response

If the grievance was not resolved immediately, once further investigation has taken place, a meeting should be held with the CLO, relevant Septa Energy manager and complainant or third party mediator. Next steps and any proposed solutions should be discussed during this meeting.

Once all parties are satisfied that the grievance has been resolved, a note of how and when it was resolved should be recorded in the Grievance Log and either a Grievance Closure Form or a Compensation Receipt Form should be signed by the complainant. Examples of a Grievance Closure Form and a Compensation Receipt Form are provided in Annex 6.

The following grievance responses might be discussed:

• No cash or in-kind compensation required

When responding to grievances relating to, for example, the unfair application of Septa Energy recruitment procedures or lack of project information, Septa will provide a verbal explanation or written documentation to the complainant. Once the complainant is satisfied that their grievance has been addressed, a Grievance Closure Form should be signed and filed with the relevant Grievance Log.

• Cash or in-kind compensation is required

If the response is a settlement offer and the offer is accepted then the case can be closed. Arrangements for payment or provision of compensation should be agreed and once they have been received by the complainant the case is closed and a Compensation Receipt Form should be signed and filed with the relevant Grievance Log.

• Complainant is not satisfied with proposed response

If the complainant is not satisfied with the proposed response to their grievance, a third party mediator can be brought into the discussion. If the resolution proposed by the external mediator is mutually acceptable the case should proceed to closure based on the agreed action.

• Complainant is not satisfied with the solution provided by third party mediator

If the complainant is not satisfied with the settlement proposed by the third party mediator they will have access to an arbitration process. The case should be forwarded by the CLO to Septa Energy's legal department and the CLO should remain in the process as mediator until the case is closed. A note of each step and the final settlement should be recorded in the Grievance Log. ·

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QHSSE level: 2 , Originated by: • RULES, PROCEDURES, AND PRACTICES Originated: Sept 2011 Revised by: SEPTA ENERGY r--·-·---·--· ,. ,; > .,.,, -·- ,_, _____ Community: Grievance Mechanism (SOP X/XXX} Revised: Authorised by:

7. Follow-up

Two or three weeks after the grievance has been resolved the CLO should visit the complainant to ensure they are satisfied that the matter has been resolved and should record this visit with any relevant comments in the Grievance Log.

G. Auditing

The grievance mechanism shall be subject to monitoring and evaluation internally every 6 months for the first two years and annually thereafter to ensure its effectiveness. The following Key Performance Indicators should be monitored:

Table 3. Key Performance Indicators

I Key Performance Indicator I Rationale

in th~ • Assess whether grievances are correctly I Number of grievances logged 1 proceedino period by level and type l classified

I Number of grievances unresolved after 60 I • Identify trends in grievances L~a~~l~X~Iand~pe Ensure grievances are being addressed I Number of grievances resolved in less than

• 30 days to satisfaction of all parties. by level • Identify individual or groups of

1 and type stakeholders with ongoing project concerns

i Number of grievances resolved between Assess compliance with the grievance ! Septa Energy and complainant, without •

i accessing legal or third party mediators, by management process

l_level and type • Identify improvements I

Number of grievances of the same or similar • Evaluate progress in achieving issue objectives

I Number of grievances from the same . stakeholder

·~>-•H>o•Ho'~"'-""'~-.-.-

These KPis should be recorded on an ongoing basis using a Grievance Monitoring chart, an example of which can be found in Annex 7.

An annual review of the Grievance Mechanism should also include qualitative assessments of awareness I knowledge of and trust in the Grievance Mechanism amongst community stakeholders and Septa employees. This should be done through stakeholder engagement.

H. References and Appendices

The following should be considered when implementing the Grievance Mechanism.

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I QHSSE Level: 2 Originated by: J1r rl ----------------------~~~--~---r~ SEPTA!~ ilt-. __ R_U_L_Es_,_P_R_o_c_e_o_u_R_Es_._A_N_.D_P_RA_C_T_IC_E_s __ +-o_rtg_,n_at_ed-1: _se_pt_20_1_1-+-R-ev_ised_bY_' -+-----1

Community: Grievance Mechanism {SOP X/XXX) Revised: Authorised by:

International Finance Corporation Performance Standards Guidance Notes 2012: The IFC has published Guidance Notes to guide the implementation of the full range of performance standards:

http://www.ifc.org/ifcext/sustainability.nsf/Content/PerformanceStandards

http://www.ifc.org/ifcext/sustainabilitv.nsf/AttachmentsByTitle/p GrievanceMecha nisms/$FILE/1 FC+Grievance+Mechanisms.pdf

International Finance Corporation Good Practice Note: The IFC has published a Good Practice Note on 'Addressing Grievances from Project-Affected Communities':

http://www.ifc.org/ifcext/sustainabilitv.nsf/AttachmentsByTitle/p GrievanceMecha . nisms/$FILE/I FC+Grievance+Mechanisms. pdf

A Guide to Designing and Implementing Grievance Mechanisms for Development Projects published by the The Office of the Compliance Advisor/Ombudsman for the International Finance Corporation (IFC), Multilateral Investment Guarantee Agency (MIGA) and Members of the World Bank Group:

http://www.cao­ombudsman.org/howwework/advisor/documentslimplemgrieveng.pdf

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.. -~-----QHSSE

RULES, PROCEDURES, AND PRACTICES

Community: Grievance Mechanism (SOP X/XXX}

Appendix 1 Grievance Mechanism process

l*rioritise J~el of grievance ;,md eonvard to C:R Manager iht,"Jtdtcd

' '~

t:\'

Stakeholder accept'S 1\!roposal

" Stilt<coolder

rejeds pmprl9at

<::om:trro:nitatc rcs~onse hl cumpl&Jmnt !ndudipg proprJSed mitigation mea@tttet>

" ' '

Level: 12 Originated by:

Originated: Jsept 2011 Revised by:

Revised: I Aullmrlsed by:

,~ A%-%M...t= ~»a'""

t~¥t~ifl ~s frttmitntt w~d(.T: Iftal'® ftta-udirtg eunstm£flmc'"' -~trmors if required to bel~

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~tdtiat<J alt<Jmatnm Ap~f , tJr jiid!Cial ptt»:~tS!!e!l aria

m aecutdingly ~ooing ootcume

Dissatisfied

Satisfied

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QHSSE Level: 2 Originated by: • RULES, PROCEDURES, AND PRACTICES Originated: Sept2011 Revised by: SEPTA ENERGY

',,,, I Community: Grievance Mechanism (SOP X/XXX) Revised: Authorised by:

Annex 2 Grievance Significance Criteria

Significance Level Type of grievance Who Is involved

Level1 A grievance that is i$.olated or 'on&-aff and CLO or relevant Septa essentially local. in .nature. and . restricted to d~rtment manager ·one complainant ·

Note: Some on&-O!f grJ(Ivances may be significant enough tq be assess ~ a UrtlaJ 4 ~rlctt . e.g. When . a natfonel or

. "tnternlitlonal taw is broktm. {$f:f8 Levet 4 be/Ow} ' ..

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• :4ENERGY ··"''"•·>lv~,.,

1l Reference No: _ (Official Use)

! FuHName

QHSSE

RULES, PROCEDURES, AND PRACTICES

Community: Grievance Mechanism (SOP X/XXX)

Annex 3 Public Grievance Form

iLe\lel: i

2 Originated by:

I Originated: Sept 2011 Revised by:

I Revised: Authorised by:

! r--------------------------------------------------------~ i Contact Infonnation Address:

! 1 Plt.'llse mark how you wish i to be contacted (mail, 1 telephone, e-mail).

Telephone:-------------------

E-mail -------------------f-::---:---:-::-----::---+---------------------------- ·······----------

Preferred Language for communication I

I Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to?

What do you think caused it to happen? What is the result of the Q!Q.blem?

t------------------,----------------- ---------- --------------------1 Date of lnddent/Grlevance

___ _:__;c__;;_;_.:___ ________ +------------------------1 One time Incident/grievance {date-------')

Happened more than once (how many times?__)

On·l!olno: (currentlv exverlendnl! problem)

What would you ~ike to see bap~e_n_to_r_e..:.sol'--ve'--th..:.e_,p_r_ob"-1-em_? ____________________ ---l

'----------------------------------------------------------'

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., ! QHSSE Level: 2 Originated by:

I RULES, PROCEDURES, AND PRACTICES Originated: Sept2011 RENised by: SEPTA ENERGY ~-·-····-···-···-·· -·---~

I Community: Grievance Mechanism {SOP XJXXX} Revised: Authorised by: --

Annex 4 Grievance Log Form

Response/Resolution:

Strategy

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QHSSE Levet 2 Originated by: • RULES, PROCEDURES, AND PRACTICES Onglnated: Sept2011 Revised by: SEPTA ENERGY

---¥ff--~-·~·- -·-·---·-·····-··- . ·~-·--

! Community: Grievance Mechanism (SOP XJXXX) Revised: AuthOriSed by:

Annex 5 Grievance Receipt Form

Coordinator

Email:

Address:

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• QHSSE level: 2 Originated by: -1------

SEPTA ENERGY RULES, PROCEDURES, AND PRACTICES Originated: Sept2011 Revised by: -··-.-... --~·- •... ........................ ~~~·

.... _ ,, Community: Grievance Mechanism (SOP X/XXX) Revised: AuthoriSed by:

Annex 6 Grievance Closure Form

Number:

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-----~1== QHSSE Level: 2 Originated by:

SEPTA ENBIGV 1 RULES, PROCEDURES, AND PRACTICES Originated: Sepl2011 Revised by: ,,_,,,,,,,,,~-

1 Community: Grievance Mechanism (SOP X/XXX) Revised: Authorised by:

Compensation Receipt Form

Address and Contact Details

Grievance Received By:

Name of Grievance

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• QHSSE

SEPTA ENERGY RULES, PROCEDURES, AND PRACTICES

-----Community: Grievance Mechanism (SOP X/XXX)

---····------~ -----

Annex 7 - Grievance Monitoring Chart.

I I --~t:i~vances received ' Level I Type

-:-r:-~----r

1 J2 1 314

! j

l I Month

! .Jan

Crop damage

Project I Propert/Asset Info Damage

Personal Injury

level: ., Originated by: -~---~-

Originated: Sept2011 Revised by:

ReviSed: Authorised by:

Grievance handling Past grievances

Outstanding I Recurring

l Road I Water I Dust Kill Quality

Septa i New I New I New staff ! grievances grievances grievances

addressed resolved unresolved (%1

I

f~b--+-1- ~ I ! I I I I I I ~tt~ I I +- • I I =t I I +------< -------+- --t---------

May I

June !

!~I I I I I ---r I I Tl I I I I I --r-- -------l---~

I Sent +--t -+-------·_-~--J--r-' Oct 'Nov

--·----+-------1------l------ll----J.---J.--+--t--+---+---i----j----t-----j

l:Jiillti_lllill I I I II Notes

Outstanding grievances refer to those remaining from previous months that have not yet been resolved. Recurring grievances refer to new grievances but concerning issues that have occurred previously.

S(.!pt~_g~~x:gy_ ______ _ ----~------------··-··---·····-

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QHSSE !Level: 2 ~-x= • -~··-· -------RULES, PROCEDURES, AND PRACTICES i Originated: Sept2011 Revised by:

SEPTA ENDGY ·~~~- ~~-~--·~•#"h~~·~·-·~ •• ••••·--N~•o ••- '

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Annex 8 - Check lists

1. Grievance Mechanism - resource checklist

• Who manages Grievance Mechanism database?

• Who conducts assessment?

• Who deals with specific concerns/complaints?

• Who needs to be involved when dealing with different levels of grievance significance?

• Decision making authority for selecting resolution approaches and settlements?

• Who communicates results of assessment/proposed settlement?

• Budget in place for handling and settling grievances?

• Compensation entitlement and rates set?

2. Grievance Tracking -checklist

• Grievance is logged in Grievance Mechanism database under assigned case number, with relevant Public Grievance Form if received.

• Grievance receipt form has been given to complainant and a copy retained for records within 7 days.

• Procedure for resolving grievance has been recorded and shared with complainant

• Grievance settlement has been recorded and shared with complainant within 30-60 days.

• Grievance Closure Form has been signed by Septa Energy and Complainant and filed.

OR

• Compensation Receipt Form has been signed by Septa Energy and Complainant and filed.

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Grievance Mechanism

This is a community relation grievance procedure and guideline that outlines the approach to accepting, accessing, resolving and monitoring grievances from those affected by Septa activities including the contactor's activities working for Septa.

A grievance or complaint is an issue, concern, problem or claim (perceived or actual) that an individual or community, group of persons has related to Septa Energy and its contractors' operations and activities. A more detailed document is contained in the SOP for grievance Mechanism.

Why handle Grievance

SENL recognize the fact that despite the best endeavours between parties;

• Disputes and conflicts may arise from time to time and need to be handled in a manner to bring prompt resolution.

• Minor concerns as well as serious or long -term issues may arise that needs to be systematically resolved to prevent them from escalating into major issues of risk to operations

• Reputation/image of company both Nationally and Internationally needs to be protected at all times

• Building cordial relationship and trust with stakeholders is of importance to our operation

SCOPE/COVERAGE

This procedure and guideline is to cover community complaints and grievances, perceived or actual at all existing and new SENL facilities, assets and properties owned in full or part and or operated by the company in order to manage the company's risk and relations with stakeholders throughout the project life cycle

APPLICATION:

The grievance mechanism is to provide guidance to employees of SENL and contractors on how to receive, register, assess and resolve community complaint or grievances from Septa operation.

OBJECTIVE

This process is aim at achieving the followings:

• Provide a predictable, transparent and credible process to all parties for resolving grievances to have outcomes that are seen as fair, effective and lasting

• Build trust and confidence as an integral part of the broader community relations activities and function

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• Provide enabling environment for a more pragmatic identification of emerging issues and their trend thus facilitating corrective action and pre-emptive engagement.

The schematic in Figure 1 below is a guide to achieving the set objectives of grievance identification, registration, assessing and resolving. It is important to state that keeping to the times specified for activities is quite important in achieving the goals and objectives.

Yes

Figure L Schematic for grieviance Mechanism.

I day

Acknowledgltlg ~eipt of · Gne.r~·

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ROLE, RESPONSIBILITIES AND RESOURCES

The grievance mechanism shall be the responsibility of the Community Relations Manager, while the Community Liaison Officers (CLOs), Community Relations Officers (CROs) and the RAP project Officer based locally at each facility, asset, project or area; play the active role in ensuring its companywide consistent application and community commitment to and understanding of its implementation and operation. For effective grievance Management, all departments in Septa and the Board of Directors shall play the roles identified for them below.

All SENL department and contractors have a role in the grievance mechanism management to receive and acknowledge any issue, concern, complain or grievance from the community verbally or in writing, which should be recorded and reported to community relations team in a recorded/written form in compliance with the grievance mechanism procedure within the time specified. Please note that, there shall be involvement of individuals from such departments originating the grievance in the investigation of the grievance as required depending on the nature and severity of the grievance.

The Board of Directors/CEO has the role of ensuring that the grievance management process/procedure is applicable all through Septa Energy and contractor departments and levels. The board has the role to accede to, and apply all necessary controls to minimize risk that could result in community grievance and also contribute to resolutions by signing off on any grievance which have international repercussions.

The board also has the role of providing a dedicated budget for management of grievances and addressing grievances through in -kind or financial compensation as and when due and found so to be.

As a requirement, there will be an auditable system for the receipt, recording and tracking of the process-a grievance log data base in place generated from the attached forms in appendix Al to Fl.

Core values and Guiding Principle

The following core values shall be upheld by SENL during implementation and operation of the system for effectiveness and good results.

• Commitment to fairness in both process and outcomes;

• Freedom from reprisal for all involved parties - within Septa and in the community;

• Dedication to building broad internal support for the grievance mechanism across project lines;

• Mainstreaming responsibility for addressing grievances throughout the project, rather than isolating it within a single department; and

• Willingness by senior management to visibly and sincerely champion the grievance system.

Principles: The following principles guide the SENL Grievance Mechanism procedure:

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1) This grievance mechanism complements and reinforces Septa's wider stakeholder engagement activities. Proactive engagement is essential for good relations with communities and stakeholders. The Grievance Mechanism should not be implemented in isolation of stakeholder engagement.

2) Septa Energy will proactively inform affected communities and wider stakeholders of the details of the Grievance Mechanism. This will include information about where people can go and who they can talk to if they have a grievance, who can register a grievance and process timelines. This information should be widely and regularly publicized, throughout the duration of any project, t hrough posters at key locations (e.g. outside a village town hall), advertisements in local papers I radio and verbally by Septa employees. Septa will provide the information in a format and using languages (including local languages) that are readily understandable by the local population and/or orally in areas where literacy levels are low during routine stakeholder engagement.

3) All complaints submitted or communicated to Septa employees or contractors should be addressed in a timely and appropriate manner. This includes factual, perceived or misrepresented grievances. Unreported grievances are a missed opportunity to build trust, improve community relations and identify emerging issues.

4) A grievance can be submitted by any affected party. This includes communities directly and indirectly affected by Septa Energy's projects, civil society, local and traditional authorities, local or national government, small business owners, associations, medical and educational practitioners, NGOs and international third parties.

5) The mechanism is expected to be culturally appropriate, clear and easy to follow with defined timelines for key process milestones. The mechanism should be sensitive to local preferences towards conflict resolution, negotiation and cooperation taking into account understandings of authority, social status and rank, community relationships and attitudes towards third parties.

6) The Grievance Mechanism should be easy to access for communities. Septa Energy will make available a range of measures for submitting complaints including face-to­face meetings, by post, email or left in suggestion boxes, on-line submissions and by telephone. A Grievance Form for external use is provided in appendix A 1.

7) The Grievance Mechanism is expected to be readily accessible to all stakeholders and communities including vulnerable groups such as women and youth at no cost to them.

8) The Grievance Mechanism is not expected to impede access to judicial or administrative remedies or seek to replace these. The mechanism should never result in any kind of retribution.

9) Septa Energy will facilitate a variety of grievance resolution approaches according to individual and cultural preferences. This includes informal processes or more formal

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approaches involving a third party mediator or legal redress. Traditional or customary practices which include inviting respected community members to act as observers, witnesses or testifiers to give legitimacy to the resolution process shall be used in most cases. Respected community members should also be solicited for advice on settling differences in a manner that complies with and respects community norms and company policy.

10) Septa Energy will provide regular feedback to relevant stakeholders to demonstrate how the Grievance Mechanism is working, clarify its purpose, manage expectations and encourage more people to use the system. Examples can be given of how cases were managed and resolved and how outcomes changed Septa policies or procedures to inspire trust and confidence that the system works.

11) Septa will maintain a record of all grievances in a central Grievance Database system. Grievance resolution settlements will be monitored to ensure consistency. Analysis of this record might highlight grievance or conflict trends or emerging issues, allowing mitigation measures to be put in place to avoid risk to operations. If a common issue is identified, structural changes at company level might prevent the grievance from recurring rather than resolving each case on an individual basis. Such mitigation should be included in the Project Environmental and Social Management System.

12) The Grievance Mechanism will be regularly evaluated by Septa to improve its effectiveness. The evaluation will take into consideration general awareness of the Grievance Mechanism process, level of use, who uses it, type of issues addressed, ability of process to resolve issues promptly and constructively; outcomes (changes to company operations, management systems and community benefits) and overall ability to achieve stated goals and objectives. Stakeholder feedback should be gathered and incorporated into the evaluation process where appropriate.

Channels: The channels to collect and forward grievances from the community shall be through a network of community representatives (community leaders, government officials, community Organizations, company environmental, Safety and operational employees, community liaison officers), including at least one member that is independent of Septa Energy such MOU implementation committee members, should be identified to receive community's concerns and deliver them to the CLO/CRO for further action.

All Septa project and contractor staff should also be fully aware of the Grievance Mechanism process so that they know how to receive a complaint themselves and pass it on to the CLO, and also instruct community members about how they can access and channel their Grievances following the procedure.

Methods: Several methods that are culturally appropriate will be used for registering complaints including self-identified, confidential and anonymous procedures. This will include a postal, email and website address, a drop-box at all sites and in key community locations, a toll-free telephone line and hosting of face-to-face individual or group meetings. The Community Liaison Officer is responsible for receiving all complaints and logging them into the Septa Grievance Database for transfer into the grievance log.

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Appendix Al Public Grievance form.

----------· ···--Reference No:

(Official Use)

··--Full Name

Contact Information Address:

Please mark how you wish

to be contacted {mail,

telephone, e-mail). Telephone:

E-mail

-·· Preferred Language for

communication

Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to?

What do you think caused it to happen? What is the result of the

problem?

Date of Incident/Grievance

One time incident/grievance (date )

Happened more than once (how many times?_)

On-going {currently experiencing problem)

What would you like to see happen to resolve the problem?

·--·¥~-'"'"""r•·~·•••••• .. ···"· .... ~.

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Appendix 1 B- Grievance Receipt form

Grievance Receipt Form

Grievance Number: Date Submitted: Target Date for initial meeting to address grievance

Name:

Grievance Received By:

Name of Grievance Coordinator:

Contact details of Grievance Tel: Coordinator

Email:

Address:

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Appendix lc: Grievance Log form

Grievance Record

Grievance Number: Date Submitted Target Date for Resolution:

Name:

Address and Contact Details

Grievance Received By:

Name of Grievance Coordinator:

Description of Grievance:

~EilQlbilltyof Grievance Grievance is Y/N eligible

If no please state reason

---··· Assessment of Grievance Notification to Head Y/N Level: of Community

Relations?

~

Actions to Resolve Grievance

Delegation to:

Action Who When Completed Y/N/Date

Response/Resolution:

Strategy to Communicate Response:

Sign-Off:

.__ Date:

Conclusion

I Is complainant satisfied? Y/N Comments from I Grievance Coordinator I

I L·-·--··----·-··----··---··-···- -

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Grievance Closed? YIN Grievance Resubmitted? Y/N

Signature of HCR: Date

Date New Grievance Number:

Appendix I D: Grievance Closure form

Grievance Record

Grievance Number: Date Submitted: Date resolved:

Name:

Address and Contact Details

Grievance Received By:

Name of Grievance Coordinator:

Description of Grievance:

Assessmeni'oT<3rievance-ceveE _____ --·•-••---·-··----.. M _____ ,_ _____ ~•••·o-.. M ---··-·······-··-·-----··········-

i Grievance Closure

Complainant

Are you satisfied that YIN Comments your grievance has been resolved

---·-·--·-·----1---------·-Signature Date:

Grievance Coordinator

Are you satisfied that this YIN Comments grievance has been resolved?

-··-·------··-~- ---·---· ... - ... - .. .. Signature Date

Appendix I F: Grievance Compensation Form

I Grievance Record

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Grievance Number. Date Submitted: Date resolved:

1--7;--------------·-··--·--·-· Name:

Addr€iss and Contact Details

Grievance Received By:

-----~-------~ '"""'""'""~

Name of Grievance Coordinator:

Description of Grievance:

Assessment of Grievance Level:

Details of compensation payment

Type of Compensation In kind I Financial

-Ticompensationin-i<ina: description of compensation received

i ..... _ i If financial compensation, I

I amount of compensation received (Naira)

-Date compensation received: (If multiple, please state)

-Grievance Closure

Complainant

Are you satisfied that this YIN Comments grievance has been resolved?

--- ----- ·--·--··-··-···- --····~····· --··---····------- -·-------· .. ••m••-,__.. ________

Signature Date

····---· Grievance Coordinator

Are you satisfied that this YIN Comments grievance has been resolved?

Signature Date

l i ....... ------·-

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1. Grievance Mechanism - resource checklist

• Who manages Grievance Mechanism database?

• Who conducts assessment?

• Who deals with specific concerns/complaints?

• Who needs to be involved when dealing with different levels of grievance significance?

• Decision making authority for selecting resolution approaches and settlements?

• Who communicates results of assessment/proposed settlement?

• Budget in place for handling and settling grievances?

• Compensation entitlement and rates set?

2. Grievance Tracking - checklist

• Grievance is logged in Grievance Mechanism database under assigned case number, with relevant Public Grievance Form if received.

• Grievance receipt form has been given to complainant and a copy retained for records within 7 days.

• Procedure for resolving grievance has been recorded and shared with complainant.

• Grievance settlement has been recorded and shared with complainant within 30-60 days.

• Grievance Closure Form has been signed by Septa Energy and Complainant and filed; where applicable,

• Compensation Receipt Form has been signed by Septa Energy and Complainant and filed.

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Annex 4A : Environmental Sensitivity Mapping Description

The current study is based on a gas pipeline to be constructed from Uquo to Usung near Oron. The pipeline will pass through three vegetation zones mainly of lowland areas which are made up of fresh water swamp forest, farmlands /fallow areas as well as fresh water swamps mixed with patches of mangrove especially close to Calabar River. The swamp forests along the pipeline route are of little agricultural importance because the soils are saturated with water, making only water loving plants to survive/thrive.

Indeed this is the most sensitive part of the pipeline route and was encountered at the beginning of the pipeline ROW. The area is only partially degraded and serves as habitat which harbours various terrestrial and swamp organisms etc. As one moves along the pipeline route the land becomes drier and hence is cultivated for various tree crops. Within this zone are the oil palm and other plantation crops such as plantain/ citrus etc. This zone is dominated by bush fallows, farmlands, plantations and secondary lowland forest. The area is of medium agricultural activities with mainly tree crops in plantation.

This is followed by a mangrove zone interspersed by scanty freshwater plants which occur at the end of the pipeline ROW. The area is designated as mangrove forest in the E5I report. Mangrove forest is dense along the Calabar River; and on the banks of the streams flowing into the Calabar River. A number of mangrove species where encountered in the mangrove habitat and these are documented in the E5I and EIA reports. The mangrove soil fauna was made up mainly of decapod crustaceans and gastropod molluscs. These include the fiddler crab, marsh crab (Seserma huzardi), purple mangrove crab (Goniopsis pelii) and the lagoon land crab (Cardiosoma armatum). Others include the periwinkles, whelk and oyster (Crassostrea gazar).

As recorded in the EIA report, the chloride content of the soils, ranged from 17.67 to 353.23mg/kg and these levels were higher than the control samples (7.09-79.98 mg/kg) indicating estuarine conditions. Thus the presence of plant species such as Rhizophora, and mangrove associates such as Acrostichum aureum (mangrove fern), Paspalum vaginatum (mangrove grass), Machaerium lunatus and Dalbergia ecastaphyllum gives credence to the observed mangrove habitat among the major vegetation types reported in the E5I report.

The presence of mangrove swamp at the water -side at Usung close to the pipeline proposed tie - in - point was recorded along the pipeline ROW (5530/VEG 30); Therefore the end of the pipeline and the tie-in­point lie within the mangrove habitat.

Revision 1 Page 1

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The swamp forest at the beginning of the pipeline and mangrove forest recorded at the end of pipeline ROW have similar soil texture in terms of their wetness and the mechanism of crossing these swamps shall be similar.

Revision 1 Page 2

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Annex SAl

Wildlife Report on Uquo-Oron gas pipeline project for SEPTA.

Methodology

The Uquo-Oron gas pipeline EIA studies were carried out during two seasons of

sampling, rainy and dry season. The dry season sampling was carried out from

March 7 - 12, 2011 while the rainy season sampling took place between 12 and 17

July 2011. Sampling took place along the pipeline route from Oron to Uquo CPF in

Akwa Ibom State, Nigeria. Assessment of the biodiversity of the area was carried

out through field observation, interviews with local hunters, and reference to

specialist institutions and experts. The studies centered on a number of intensive

study locations along the pipeline route in which the biological diversity, soils,

topography, major vegetation communities and climatic conditions of the proposed

project area was studied. At each study location, the invertebrates and vertebrates

population (including arthropods, birds and mammals) were observed in their

habitat. This was corroborated with data collected from interviews with hunters and

trappers from the area. The communities studied include Oron, Esit Eket, Akwata,

Urua Okot, Akpautong, amongst others.

Specimens sighted in the field were identified using taxonomic guides and voucher

specimens in the Zoology Museum, University of Benin. Identification and

nomenclature are based on the field guide of Birds of Nigeria and West Africa

(Eigood, eta/. 1994; Serle et al., 1977), Mammals of Nigeria (Happold, 1987).

Results

The terrestrial invertebrates were dominated by arthropods, including insects and

spiders and molluscs. The terrestrial invertebrates were mainly dominated by

arthropods including insects and spiders, and land molluscs. The mangrove soil

fauna at Oron, Uqua CPF, and part of Esit Eket were made up of mainly decapod

crustaceans and gastropod molluscs. These include the fiddler crab, marsh crab

(Seserma huzardi), purple mangrove crab (Goniopsis pelii) and the lagoon land

crab (Cardiosoma armatum). The mangrove molluscs were mainly periwinkles,

whelk and oyster (Crassostrea gazar).

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Most of the species recorded during the survey were common and may not be

threatened by the proposed project activity, although some species are of unclear

conservation status or have not been categorized by IUCN. Other species fall under

the category of "Least Concern" in the IUCN category.

Tables 1-3 show a checklist of some vertebrate species observed or reported from

the area of study with their conservation status. The amphibians, mainly frogs and

toads were all common and abundant during the rainy season. The reptiles (Table

1) recorded include lizards, snakes, and tortoises. Crocodiles reported include the

short snouted crocodile, and the long snouted crocodile. The Nile crocodile was not

recorded in the region and maybe locally extinct. Lizards were common but the

population of the monitor lizard, Varanus niloticus, is gradually declining because of

hunting pressure. More individuals of the monitor lizard were recorded during the

rainy season than the dry season. Skinks were abundant in the region, but more

individuals were recorded in the dry season than in the rainy season. The crocodiles

and the Royal Python were the vulnerable reptilian species found in the area. Other

reptilian species are either not threatened or vulnerable depending on the rate of

hunting or destruction of their habitat.

The birds' species found include those characteristic of disturbed habitats,

farmlands and gardens along the Oron Uquo CPF, Esit Eket, and other communities

along the pipeline route. Table 2 gives a list of avifauna found in the area of study.

They include finches, bulbuls, Crows, Sunbirds, Hornbills, Senegal Coucal, Hooded

Vulture, Black Kite and Tambourine Dove. Birds of prey including hawks, kites,

harriers, and crows dominated the fauna in Oron especially along the pipeline route

near the Uquo central processing facility (CPF). The birds were more abundant in

the dry season than in the rainy season. We recorded over 60 individuals of hawks

and crows at a particular site near the Uquo CPF during the dry season sampling.

The mammals were dominated by rodents mainly rats, grasscutter, squirrels, and

porcupines. These species are neither threatened nor endangered. Other

mammalian species reported include primates (monkeys), carnivores (cats),

artiodactyla (antelopes) and pangolins. Apart from the primates which are

vulnerable, non of the mammalian species recorded in the region was threatened

by the project development. This was confirmed using the IUCN Redlist of

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endangered species' list (2012). Even though we observed a large population of

Mona Monkeys at Esit Eket and Urua Orok during the rainy season, these species

were not threatened. However, continued destruction of the forest may lead to

their extirpation and result in local extinction.

Table 1: Checklist of amphibians and reptiles reported from the project area

~-----···········~·-·· .... ····~-----·-~--~-

Class Order Family common name scientific name status -----· ''""'"---·-··-···· ..... -... -.. .-........ ~.-----·

Hinged-back Reptilia Chelonia Testitudinidae tortoise Kinixys erosa Vulnerable

Slender- I snouted Crocodylus

Crocodilia Crocodylidae Crocodile, cataphractus Vulnerable Dwarf Osteolaemus Crocodile tetraspis vulnerable

Squamata Agamidae Agama lizard Agama agama Least concern Hem/dactylus Least concern

Gekkonidae Wall Gecko brooki Scincidae Skinks Mabuya sp Least concern

Least concern

I Nile Monitor Varanus Least concern

Varanidae niloticus I

Colubridae I Common Least concern Common I Nigerian File Snakes j Snake Mehe!ya crossi

I

I

/ Royal Phython Phyton regius vulnerable i Naja Least concern I

Elapidae I Black Cobra melanoleuca i

Viperidae 1 common vipers Vipera sp. Least concern

I Least concern

Amphibia Bufonidae I Toads Bufo regularis Least concern

I Bufo maculatus Least concern Hylarana Least concern

Ranidae I True frogs a/bolabris

I Dicroglossus Least concern

I

occipitalis Anthroleptis sp. Afrixalus Least concern

Rhychophoridae [ Treefrogs dorsalis ' Hyperiolius sp. ' Least concern l_ ______

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Table 2: List of Birds recorded in the pro]ect area. Common Names African Harrier Hawk Black & white Hornbill Black & white Mannikin Black Flycatcher Black Kite Bronze Mannikin Bush Shrike Bush Sparrow Cassin's Grey Flycatcher Cattle egret Chattering Cisticola Collard Sunbird common Bulbul Copper Sunbird European swift Fire-spotted Woodpecker Forest Robbin Forest Scrub-robbin Grey Heron Grey-headed Sparrow . Ham merkop Lily trotter Hooded Vulture Little African Swift Little Bee-eater Little Egret Little Greenbul Lizard buzzard Malachite kingfisher Pied Crow Pigmy Woodpecker Pin-tailed Whydah Plain-backed Pipit Plamnut Vulture Red-billed Dove Red-eyed Dove Senegal Coucal Senegal Fire-finch Senegal kingfisher Superb Sunbird Swamp Palm Bulbul Tambourine Dove Ussher's Flycatcher Village Weaver West African Thrush White-throated Blue

Scientific Names Polyboroides typus Tockus fasciatus Lonchura poensls Melaenormis edoliodes Milvus migrans Lonchura cucullatus Melaconotus cruentus Petronia dentate Muscicapa casini Ardeola ibis Clsticola erythrops Anthreptes collaris Pycnonotus barbatus Nectarinia cuprea Apus apus Aropethera puncu/igera Stiphrornis erythrothorax Cercotrichas leucosticta Ardea cinerea Passer griseus Scopus umbretta Actophilornls africana Nephron monachus Apus affinis Merops pusillus Egretta garzetta Andropadus virens Kaupifalco monogrammicus Alcedo cristata Corvus a/bus Verreauxia Africana Vidua macroura Anthus leucophyrs Gypoierax angolensis Tuturafer Stneptopelia vinacea Centropus senegalensis Lagonosticta senega/a Halcyon senegalensis Nectarinia superba Thescelocichla leucopleurus Tutur tympanistra Artomyias ussheri Ploceus cucullatus Turdus pelios

Swallow Hirundo nigrita Yellow Wagtail Motacilla flava

Yellow-throated l,QD.9::f_l_i'I_"Y__ .J::t:.:::a~c,_,ro:::.:.n'-Lw-.::;xc..:c~n.:::o:::-ce::::.:u,_,s"-------'------------....-..J

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Table 3: Checklist of mammals reported in the proposed project area

Mammals Abundance

Class Order Family Common names Scientific names status Conservation status

Mammalia Primates Least concern

Galagidae Gafagoides (bushbabies) Dwarf Galago demidovii Rare

Cercopithecidae Cercopithecus {monkeys) Mona monkey mona Rare Vulnerable

Selecel monkey Sefecef gueone Rare Vulnerable Least concern

Pholidota (Pangolins) Manldae Tree Pangolin Manis trtcuspis Rare

Erinaceus Insectivora Erinaceidae Hedgehog albiventris Common Vulnerable

Least concern

Soricidae (Shrews) Forest Shrew Croddura odorata Common

Rodentia I Beecrof's Flying- Anomalurus Least concern

(rodents) Anomaluridae squirrel beecrofti Rare

Brushtailed Least concern

Hystricidae Porcupine Atherurus africanus Abundant

Cricetidae Emin's Giant-rat Cricetomys emini Abundant Least concern

Cricetomys Least concern Gambian Giant Rat gambia nus Abundant

Thryonomys Least concern Thryonomidae Greater Cane Rat swinderianus Abundant

Giant Forest Tree- Protexerus Least concern Sciuridae squirrel strangeri Rare

Red-legged Sun- Heliosciurus Least concern squirrel rufobrachium Rare

Least concern

....__ --~~--

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l '

Muridae Rattus rattus Abundant I Black Rat Multimammate Mastomys Least concern Mouse natalensis Common

Pygmy Mouse Mus minutoides Common Least concern

Hbyomys Least concern Three-striped Mouse trivirgatus Common

Lophuromys Least concern

I Rusty-bellied Rat sikapusi Common

Least concern

Carnivora Viverridae (civet, (Carnivores} genets & mongoose) African Civet Viverra civetta Rare

Two-spot Palm Civet Nandinia binotata Rare

Forest Genet Genetta poensis Rare Threatened

least concern Herpestldae Marsh Mongoose Atilax pa/idinosus Rare

Artiodactyla Tragelaphus Least concern

Bovidae (Antelopes) Bush buck scirptus Common

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References

1. Boorman, J. (1970) West African Butterflies and Moths. Longman Group, 79pp.

2. Brown, D.S. (1980). Freshwater snails of Africa and their medical importance. Taylor & Francis Ltd, London. 487pp.

3. Elgood, J.H., Heigham, J.B., Moore, A.M., Nason, A.M., Sharland, R.E. & Skinner, N.J. (1994) The birds of Nigeria. An annotated checklist. British Ornithologists' Union. 305pp.

4. FAO (1981) FAO species identification sheets for fishery purposes, Eastern

Central Atlantic. Vol VI. Fisher, W., Bianchi, G. & Scott, W.B. eds.

5. Haltenorth, T. & Diller, H. (1977) A field guide to the mammals of Africa including Madagascar. Collins, London, 400pp.

6. Happold, D.C.D (1987). The mammals of Nigeria. Oxford University Press, Oxford. 402pp

7, Serle, W., Morel, G.J. & Hartwig (1977) A field guide to the Birds of West Africa. Collins, London, 351pp.

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--QHSSEC Level: 2 Originated by: PH .,

CORPORATE QHSSEC ST ANOARO OPERATING SEPTA ENERGY PROCEDURES

Originated: Feb2010 Revised by: PH

SOP 916- Hydro-testing Revised: Apr 2010 Authorised by: SA '" ---

SOP 916 Hydro-testing

A. Purpose

The purpose of this procedure is to prove station piping, related facilities, and installed pipeline integrity by hydrostatic pressure testing.

B. Scope

Hydrostatic testing of station piping, related facilities, and installed pipelines.

C. References

• Project Drawings.

D. Definitions and Abbreviations

• ASME -American Society of Mechanical Engineers;

• API -American Petroleum Institute;

• STP- Specific Test Pressure; and

• PTW- Permit to Work.

E. Responsibilities and Authorities

• General Superintendent

Implements operating procedures on project sites.

• Quality Manager

Reviews, approves. and maintains the operating procedures.

• Foreman

Responsible for assuring that the work activities are performed within the specified requirements.

• QC Representative

Responsible for performing the required inspections and complete the associated inspection documentation.

F. Procedure

1. Preparation

Septa Energy QHSSEC Manual

The General Superintendent shall designate qualified personnel to be responsible for all hydrostatic testing activities. Prior to commencement of hydro-testing activities, the NOT subcontractor shall comply and work in accordance with the Septa Energy Permit to Work System (PTW) (SOP 613}.

Volume 6, Page 1 of 4 Version 3.1

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II SEPTA ENERGY

QHSSEC Level: 2 Originated by: PH

CORPORATE QHSSEC STANDARD OPERATING Originated: Feb 2010 R&vioed by: PH

PROCEDURES

SOP 916- Hydro-testing Revised: Apr 2010 Authorised by: SA

All testing equipment shall be supplied by Septa Energy. The Foreman shall be responsible for all test preparations, including fabrication of test ends, test manifolds, piping, pipe filling, and draining. The location for filling, testing, and draining the pipeline shall be mutually agreed between the Project Engineer and Septa Energy.

As required by Septa Energy, a water sample shall be tested by an approved laboratory and presented to the Construction Superintendent for approval prior to filling. Based upon the water sample and project specifications, corrosion inhibitors and biocides and any other specified inhibitors shall be added to the water, as required, during filling.

Under normal circumstances, the Company shall be responsible for providing permits for obtaining, using, and disposing of water for cleaning and testing purposes. Septa Energy shall submit details of the equipment and instruments to be used and certification to be provided. Instrumentation and pressure testing equipment shall be calibrated prior to the hydrostatic test by a qualified technician or an approved, independent company.

The appropriate pressure and temperature gauges, recorders, dead weight tester, and valves specified shall be connected to the installed pipeline in preparation for the hydrostatic test. Test measuring equipment shall be calibrated. The connections and the test assembly shall be checked by the Foreman for conformity to this procedure and to ensure that all safety precautions have been taken.

All valves, if installed, shall be in the open position during the hydro-test. Check valves shall be either removed or blocked in the open position during test.

The installed pipeline shall be hydrostatically tested to the specific test pressure (STP), as either one unit or a series of sections, unless specified otherwise by the engineer. When specified, each test procedure shall contain test plans or sketches identifying the piping sections to be tested, the pipe test legend indicating the test pressure, the test medium, and any other pertinent information. In the event of a conflict between this procedure and the detailed specific procedures, the test procedure shall prevail.

2. Testing

Septa Energy QHSSEC Manual

Flushing and cleaning is achieved by flushing until debris is removed or by running pigs through the pipeline, as specified in SOP 915. If pigs are used, water is continuously pumped into the pipeline at the launch area until the pigs are received at the catch area. As the water is pumped into the pipeline, air is bled off at the catching area.

Testing of the installed piperine shall be tested and pressurised to the STP.

After filling, the pipeline shall be stabilised. The stabilization period shall be as specified in the project specification. After the stabilization period, the test is started. During the testing of the pipeline, QC will check for pressure drops. Should a leak occur, the test pressure is reduced to 0 psig, repairs other than welding are completed, and the pipeline is subsequently re-pressurised and re-tested.

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~~---------

• SEPTA ENERGY

QHSSEC Level: 2 Originated by: PH

-coRPORATE QHSSEC STANDARD OPERATING Originated: Fab 2010 Revised by: PH

PROCEDURES

SOP 916- Hydro-testing Revised: Apr 2010 Authorised by: SA -- ·-----------· _____ ,,_..,_, __

Test pressures and temperatures shall be recorded on the chart throughout the testing period. Upon satisfactory completion of the test, the results shall be recorded on Form QR-022.

3. Hydrostatic Test Acceptance Criteria

To satisfy the testing requirements, the pressure in the line must be maintained without pressure variations that cannot be accounted for by changes in temperature. Since precise verification is difficult, a tolerance of ± 0.2% of the specific test pressure, after temperature corrections, is accepted. The test shall be accepted if all pressure containing components In the test section maintain their integrity and no leaks are found.

Any reduction in pressure outside the limits specified or variation in temperature that cannot be accounted for shall result in a test failure. Possible causes for failure, such as loose bolts and/or fittings, leaking gaskets, test pump failure, air entrapment, or weld failure, shall be located and rectified. After rectification work is complete, the pipeline section shall be refilled with water and the procedure in clause 6.2 repeated until such time as the STP can be satisfactorily maintained.

After acceptance of the test, the line Is gradually de-pressurised. Further de­watering is stopped and the line is left filled with the water used for testing until such time as the Company is ready to put the line into service.

4. Pipeline Commissioning

Following acceptance or approval of the hydro-test, the test liquid shall be displaced from the pipeline with a multiple cup or bi-directional disc pig propelled by compressed air. Free draining of the line during de-watering may be allowed.

When required, drying runs are made to remove all remaining water from the line. After the line is free of water, abrasive or brush pigs are run with dry compressed air to remove any rust or mill scale from the pipe wall prior to commissioning, in accordance with Clean and Gauge {SOP 915).

Following satisfactory testing, temporary test heads, blind flanges, instruments, and other test equipment are removed and returned to the Septa Energy yard. All test records and record charts shall be signed by Septa Energy and included in the as-built documentation package.

On completion of the above, the pipeline is released for final installation and tie-in.

5. Safety and Environmental Protection

All employees and contractors engaged in hydro-testing operations must comply with the Septa Energy SOPs regarding health, safety, and protection of the environment. Where appropriate, risk assessments should be carried out to ensure that all the hazards associated with the activities:

• Are identified and assessed, and

• Have controls put in place to reduce risk to people (including local communities), environment, assets, and reputation to a level that is as low as is reasonably practicable.

Septa Energy Volume 6, Page 3 of 4 QHSSEC Manual Version 3.1

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------------~ .. ··---·------., SEPTA ENERGY

""•<"' ... ,.

QHSSEC Level: 2 Originated by: PH

CORPORATE QHSSEC STANDARD OPERATiNG-----·- -···-------~-- -----------

PROCEDURES Originated: Feb2010 Revised by: PH

SOP 916- Hydro-testing Revised: Apr 2010 Authorised by: SA

Prior to any hydrostatic testing activities, the Foreman shall familiarise all personnel with the safety requirements associated with the test.

All personnel shall be equipped with safety clothing, particularly for handling of chemical additives, which require rubber gloves and safety goggles as a minimum. A Septa Energy Safety Representative shall instruct personnel in safe working practices and ensure that they are enforced. All test crew personnel shall be trained and/or experienced in the testing activities performed.

A communication link system shall be finalised, prior to the start of any hydrostatic testing activities. All static machinery, including pumps and compressors, shall be equipped with fire extinguishers. All above ground sections shall be secured and entry restricted to exclude personnel, other than the test crews, during the hydrostatic testing. Work permits shall be endorsed by security personnel made aware of the nature of the test and access limitations.

Other than specified above, no work of any kind, either permanent or temporary, shall be performed on any part of the system while testing is in progress.

G. Records/Objective Evidence

• Hydrostatic Test and Temperature Record QR-015, and

• JHAs.

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QHSSEC level: 2 by: PH

Ill I - ---

CORPORATE QHSSEC STANDARD OPERATING SD'TA ENERGY PROCEDURES

Originated: Feb 2010 I Revised by: PH

SOP 919- River Creek Crossing ReviSed: Apr2010 Authofised by· SA

SOP 919 River Creek Crossing

A. Purpose

The purpose of this procedure is to document a safe and effective operational procedure for installation of pipelines in river and/or creek crossings.

B. Scope

The installation of pipelines in the bed of major rivers and creeks by the bottom tow method.

C. References

• Pipeline Survey Procedure (SOP 901 );

• Backfilling Procedure (SOP 906);

• Clean and Gauge Procedure (SOP 915);

• Hydro-testing Procedure (SOP 916);

• 800 Series Septa Energy Environmental Procedures; and

• Welding and cutting procedures.

D. Definitions and Abbreviations

• HSE- Health, Safety, and Environment.

E. Responsibilities

• Project Engineer

Responsible for preparing all installation/pulling calculations.

• Construction Superintendent

Responsible for all installation/pulling operations.

• HSE Representative

Responsible for implementing safety procedures/requirements.

Septa Energy QHSSEC Manual

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QHSSEC level: 2 Originotad by: PH

II CORPORATE QHSSEC STANDARD OPERATING Originated: Feb 2010 ReviS<Id by: PH

SEPTA ENERGY PROCEDURES ''

SOP 919- River Creek Crossing ReviS<Id: Apr2010 AuthoriS<Id by: SA

F. Procedure

1. Safety

Prior to commencing the operation, a detailed Job Safety Analysis (JHA) will be prepared. After all known, suspected, or potential hazards and risks have been identified, the workforce shall be informed of the hazards and control measures that must be in place to eliminate or control the hazards and potential risks surrounding the thrust bore activity.

All personnel involved in river/creek operations will have received safety induction training and the job-specific training required for the particular operation in which they will participate. All workers shall wear appropriate PPE (reference the job-specific JSA). All workers shall comply with HSE requirements as per the HSE Plan.

Only authorised personnel shall be allowed in the work area. All necessary measures and requirements or manufacturer's recommendations or specifications shall be followed.

The HSE Manager shall ensure that all the relevant safety procedures and requirements are enforced prior to and during the thrust bore operations. All mechanical operations shall be monitored by an HSE Officer in accordance with the HSE Plan.

Safety equipment used in waterborne operations, e.g., life floats, life buoys, fire extinguishers, etc., are supplied by the HSE Department and checked for adequacy/conformance by the HSE Representative on a routine basis throughout the project duration. Workers will have to pass a swimming test.

During the dredging operations, all marine craft will ensure that they do not block the river or cause obstruction to the river traffic. Warning signs/lights for the movement of floating equipment and the anchor lines shall be displayed at all times.

2. Survey

Prior to any construction activity, the location of any adjacent existing facilities will be established. In addition, a bathymetric survey will be carried out in accordance with the Pipeline Survey Procedure (SOP 901) to plot the existing profile of the riverbed along the pipeline route in order to establish a final pipe profile.

3. Dredging

Septa Energy QHSSEC Manual

A bucket dredge will be utilised for dredging smaller and shallower creek crossings. The bucket dredge will also be used to excavate the slot in the banks of the river/creek. All dredging will be carried out in accordance with procedure.

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··-·--- --· QHSSEC level: 2 Originated by: PH

II CORPORATE QHSSEC STANDARD OPERATING Originated: Feb2010 Revised by: PH

SEPTA ENERGY PROCEDURES

SOP 919- River Creek Crossing Revised: Apr 2010 Authorised by: SA

4. Welding

The welding of the pipe strings will be done on the bank of the river. On completion, they will be pushed into a floatation ditch of sufficient length to cover the complete width of the river crossing pipe string. As the pipeline is pushed into the ditch utilising rollers, floaters will be fixed on the top of the pipe at determined intervals to enable the river crossing section to float in the ditch. Welding and radiography will be carried out in accordance with the welding and NDT procedures. Welding and cutting field joint coating will be carried out in accordance with the appropriate procedures.

5. River/Creek Crossing Installation

Septa Energy QHSSEC Manual

Prior to pulling operations, the following preparations shall be performed:

• Calculations to determine the level of buoyancy to be applied to the pipe string in order to limit the maximum pulling load and determine winch selection;

• Functional testing of winch;

• Final survey of bottom profile to be performed after completion of dredging. Client to review and, if satisfactory, approve the final survey within 24 hours of receipt;

• Lay pull cable across the river;

• Positioning of winches;

• Bury pull anchors; and

• Hydro-testing of the river crossing section, see Hydro-testing {SOP 916).

To commence the pulling operations, the pull winches will be positioned at the bank and adjacent to the pipe-pulling head. The wire rope will be connected to the pipeline through the pulling head. The pulling wire rope will be laid in the excavated trench in the river bottom. When the winches start pulling the river crossing section, the river crossing supervisor will control the speed at which the section is pulled

When the pipe reaches the opposite bank, it will be located in the pulling slot on the pipe centreline. The anchors will then be placed and buried on the bank of the river. Anchor winches will be used to tension the anchor lines and to set the anchors.

The pipe will be pulled along the river bottom by the winches located on the pulling barge. The pipe will be pulled continuously until the pulling head reaches the pulling end.

During pulling operations, the required amount of floaters will be removed from the pipe sections at the edge of the bank of the river, which will enable the pipeline to sink to the bottom of the trench with the designed buoyancy, due to the presence of the remaining floaters, for the pipe string to be installed without excessive pull loads.

After the completion of pulling operations, a bathymetric survey is carried out to confirm the proper positioning of the pipeline within the trench.

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Ill SEPTA ENERGY

QHSSEC Love!: 2 Originated by: PH

CORPORATE QHSSEC STANDARD OPERATING Originated: Feb 2010 Revised by: PH

PROCEDURES

SOP 919- River Creek Crossing Revised: Apr 2010" Authorised by: SA

The installed pipeline will be cleaned and gauged in accordance with SOP 915 and hydrostatically tested in accordance with SOP 916. Prior to backfilling and acceptance of the hydro-test, the floaters will be removed using a rip cable. On successful completion of the test and acceptance of the gauging plate, backfilling will commence in accordance with SOP 906.

Final survey of the backfilled river/creek crossing will be carried out in accordance with Pipeline Survey {SOP 901) to confirm restoration of original profile.

G. Records and Objective Evidence

• SGS Radiographic Report;

• QR-022 Hydrostatic Test Reports;

• QR-024 Welding Inspection Reports;

• QR-002 Survey Reports;

• QR-000 Dredging Reports;

• QR-000 Pipe Pulling Record; and

• JHAs.

Septa Energy QHSSEC Manual

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PROCEDURE FOR CHANCE FIND FOR

UQUO- ORON GAS PIPELINE PROJECT.

DOCUMENT NUMBER: 1204501-SENL-PLN-S-0003 Project Code Organisational Doc Type Discipline Code Numeric Sequence

Code Code Number 1204501 SENL PLN s 003

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AUTHORISATION PAGE.

Name Date Signature · Remark

Prepared by Siakpebru S --- ·-Reviewed by Ekpelegho, J Salau, B Approved by Horrocks P

----~

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REVISION MODIFICATION LOG

--,----- . ---I Revision Section Description

01 All sections I I

---------

---l

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1.0 Introduction.

Section 15(1) of the Oil Pipelines Ordinance (CAP) 145 prohibits the holder of an

Oil Pipeline License {OPL) to enter upon, take possession of or use any of the

following lands unless the occupiers or persons in charge thereof have given their

assent:

(a) Any land occupied by a burial ground or cemetery,

(b) Any land containing any grave, grotto, and trees or things held to be sacred or the object of veneration/

(c) Any cultivated land.

Septa Energy as part of site/route selection avoids cultural heritage sites/routes

which may contain archaeological structures. This is with a view to minimizing

adverse impacts to cultural heritage. This procedure outlines the process steps to

be followed when a tangible cultural heritage is encountered unexpectedly during

project construction and operation.

1.1 Objectives.

The main objective of this document is to ensure that there is a procedure in place

which will be applied in the event that a cultural heritage/ archeological structure

are discovered during construction or operation of any Septa Energy facility.

1.2 Chance Find Procedu're

The following procedure will be is executed in the event that Archaeological

material 1 graves or other artifacts are discovered in the course of right-of-way

clearing, ditching or borrow pit operation.

i. All construction activity in the vicinity of the find/feature/site will cease

immediately, and the Site Health Safety and Environmental (HSE) Officer

and the Project Manager will be informed of the find.

ii. The HSE officer or Project Manager will delineate the discovered find/

feature/ site with tape or other marking material to prevent unauthorized

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persons from entering, record the find location and ensure that all

materials are left in place.

iii. Site Security personnel will secure the area to prevent any damage or loss

of removable objects.

iv. The Project Manager will inform the Septa Energy, which will in turn inform

the Chief Artefacts Officer in the Ministry of Culture/ Museum and

Tourism. He/she will in turn report find to the Curator of the National

Museum and request a site visit by a qualified archaeologist.

v. Work at the location will not resume until the Archaeologist has

determined what course of action to take:

- continue work because the find has no cultural or archaeological value 1

- continue work after the find has been relocated or removed to safe

storage under the guidance of the Archaeologist,

-or divert the works around the site if the find needs to be preserved in

situ.

The contractor's equipment operators and supervisory personnel will be trained in

recognizing items that could be of cultural significance. The chance finds procedure

will be explained to operators, supervisors, HSE Officer, project engineer and other

relevant staff and will be posted at appropriate locations.

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