HSE Approach

A Project-specific HSE Management Plan will be developed, which describes how the project will achieve compliance with the corporate HSE policies, standards as detailed in the HSE MS and with Libya’s legislative requirements, also will support the project & execution planning and its key objectives.

The principal Contractors involved with the Project are required to develop their own Project HSE Plans and to ensure that they are aligned with the requirements of the NOO HSE MS. The Contractor HSE systems and performance will be evaluated during the tendering process prior to contract award and their project specific HSE plans will be subject to review and approval by NOO. Effective implementation of the HSE Plans and performance against defined HSE targets will be monitored during the execution of the project.

The Project Manager is responsible for ensuring that the Project HSE requirements, plans and systems are implemented and that performance against these is continually monitored. NOO’s HSE Manager will be appointed to assist the Project Manager in achieving this. The NOO HSE Manager will oversee project performance in achieving NOO HSE expectations and will provide advice to the project on HSE matters. The project will be supported by specialist safety and environmental consultants who will provide expert advice and assistance where required. HSE roles and responsibilities for all project personnel will be defined in the Project HSE Plan.

As part of the HSE plan, an HSE Bridging Document will be developed. The aim of this document is to facilitate co-ordination and communication between NOO and the principal contractors focusing on the major themes associated with Operational Safety, and will have to jointly reviewed their relevant documentation and Safety Management Systems.

The documentation has the following main objectives:

•  to highlight interface issues.
• to provide a common approach to interface issues.
• to provide personnel involved in the project with a clear understanding of the means by which operational interfaces will be controlled.
•  to define the security collaborations and responsibilities and to define a unified approach in dealing with security breaches.
•  to define plan on what to do in case of serious industrial incidents and benefit from lessons learned

The document will reveal operation guidance and details key aspects of Management Responsibilities, Communications, Work Programming, Equipment Fitness, Monitoring and Auditing.

As principle; contractors who do not meet NOO’s standard, must upgrade their systems to an acceptable level before proceeding with any works on the ground.

Some HSE programs will be conducted during construction and operation but not limited to:

• Risk Evaluation

  Risk Evaluation is a process to identify and control Occupational health, safety and environment risks of any activity through:

  • Risk and Hazard Identification.
  • Assessment and prioritization of risks as well as the impact of these risks.
  • Development and implementation of risk control as mitigation efforts and reduce the risk to ALARP level.
  • Implementation of risk mitigation plan.
  • Communicate all risk information to all operational level.
  • Nafusah Oil Operations has established the mechanisms and procedures to identify activities, products, and/or services that may affect to Occupational Health, Safety and have an impact to Environment.

• Permit to Work System (PTW)

  Project team will implement work permit systems during construction. There must be one permit system to be implemented onsite.
  The work permit system shall include the following requirements:

  • Reviews of risk assessments and method statements.
  • Inspection of the work site.
  • Isolation and de-isolation of assets.
  • Formal arrangements for issuing, extending, suspending, and cancelling permits.
  • Special forms for all types of permits, training for permit issuers, training for permit users.
  • Retention of permit records for a specified period.

• Simultaneous Operation

  Nafusah Oil Operations will implement the operations / activities simultaneously associated with the drilling, wells completion, production, and construction at the Central Processing Facilities. To reduce risk during simultaneous operation, will be prepared SIMOP Manual (Simultaneous Operations) to show:

  • Management of safe operation has been planned and coordinated.
  • Any hazards and risks arising from changes or new activities shall be identified and assessed. Physical or procedural action shall be established to reduce those risks.

• Critical Lifting

  • All lifting equipment subjected to inspection during audits. This is where most deficiencies are found.
  • All deficiencies are the result of a lack of effective control systems.
  • All lifting equipment must have checked by a competent inspector.

  Only experienced and certified persons from the rig crews should be authorized to operate hoisting equipment. Crane Operator must hold valid certificate from Libya Authorities and local regulations.

• Journey Management

  To manage the risks associated with transportation of personnel, materials, public road user and equipment, Company has implemented the Journey Management Plan. The system ensures the safety of the journey and effective response is available and documented in the event of an accident occurs.
  At a minimum the system must cover:

  • Identification of hazards, assessment of the risks and implementation of appropriate control measures to reduce risks of the journey in public roads;
  • Identification of road density, public communities such as school, mosque, etc. including address of Emergency Medical when needed
  • Plan on numbers of convoys, traveling time, periodical rest or change of driver, and escort.
  • Reporting and recording vehicle movements and effective communications arrangements from driver to base office during the journey.
  • Actions to be taken in the event of an accident during the journey.
  • A site response plan provides:
    • incident’s reporting procedure.
    • actions when a traveller is recorded as overdue.
    •  responsibilities for monitoring vehicle journeys.

• Emergency Response Plan

  Emergency Response Plan is needed to handle all emergency, such as:

  • Medical Evacuation
  • Oil Spill and pipe leak.
  • Wells blowout
  • Fire and/or explosion
  • Natural disasters
  • War

  The main purpose of Emergency Response Plan is to:

  • Protect people’s safety (workers and local community).
  • Rescue and treat the victim effectively.
  • Minimize environmental impact.
  • Minimize property damage of Company asset, community and personal.
  • Facilitate and expedite the recovery and restoration process of emergency incident.

The design of facilities, construction and operation shall incorporate best environmental engineering practices such as Best Available Techniques (BAT) for preventing the escape of all harmful emissions and to meet the applicable environmental criteria.

Facilities and infrastructure will be designed to have minimum impact on the environment, and shall incorporate the following environmental principles:

• Full compliance with NOO policies relating to the environment.
• No continuous flaring or venting of gases for disposal.
• Disposal of associated water in designated disposal wells after proper treatment.
• Utilisation of environmental engineering practices such as BAT to minimise both point source and fugitive emissions (consider low NOx burners, de-NOx, high efficiency flare burners etc.)
• Incorporate industry proven and efficient design and operating practices to minimise the generation of greenhouse gases; Incorporate highly integrated waste recovery heat systems, high efficiency heaters and waste heat recovery in accordance with industry standards where applicable and appropriate.
• Incorporate industry proven design, conservation, construction and operating practices that minimise:
  • The generation of waste water and maximise its reuse.
  • The generation of solid wastes including non-hazardous and hazardous.
  • The potential for accidental spills or releases of hazardous materials to the environment.
  • The generation of noise and noise levels both within the units and at the perimeter fence line.
  • Adopt procedures that ensure the proper tracking, treatment and disposal of all wastes generated within the facility through its construction and operational phases.

• Environmental Impact Assessment

  Nafusah Oil Operations BV (NOO) is currently in the planning stage to develop and produce North Hamada Area – 47, Libya. The development includes construction of facilities, drilling, and production operation that can cause positive and negative impacts to the environment.
  The impacts to the environment will be generated from following activities:

  • Land acquisition and land clearance.
  • Site preparation.
  • Drilling and re-entry of the gas wells.
  • Construction of gathering line, Central Processing Facilities (CPF), oil and gas export pipeline.
  • Re-injection of Gas and produced water.

  All activities which may have impact to environment shall be identified, controlled and mitigated.

• Emission and Control

  One of the important issue regarding to the environment aspect is emission and its control. Company will comply fully with the Libyan Laws, regulation, and International Standards.

  All emissions which will be generated from drilling, construction and Operation activities shall not exceed the allowable threshold. Type of the emissions and controls are mentioned above as follows:

  • Emission to Air
  • Ambient air quality standards
  • Sulphur contents in diesel fuels
  • Occupational Exposure Limits
  • Fugitive emissions
  • Flare and vent emissions
  • Ozone depleting substances/Greenhouse gas emissions
  • Emission to Water
  • Produced water
  • Treated waste water
  • Sanitary waste water

• Solid Wastes

  During Construction and Operation phases, sources of waste shall be reviewed to identify and quantities likely to be generated and to establish the storage, treatment and disposal infrastructure required. This review will also highlight any risks, such as the sources of hazardous waste and identify opportunities for waste prevention, minimisation, recycling, re-use of materials.

  • Non- hazardous Wastes
    Non-hazardous waste will be controlled and separated at source into those that can be recycled or re-used, and those which must be sent to disposal. They will then be stored in fit-for-purpose bags or tanks.Hazardous solid waste will be separated at source and separately stored according to regulations, and shall not be mixed with ordinary solid waste. Where hazardous and non-hazardous wastes have been mixed, these shall be disposed of as hazardous solid wasteHazardous Wastes
  • Hazardous Wastes
    Hazardous waste is defined as waste containing substances or compounds that are flammable, explosive, poisonous, corrosive, infectious, or which exhibit other hazardous properties or may interact with other substances to cause hazards to the environment and human health.
    Measure to ensure the safe handling storage of hazardous wastes will include:

• Minimising and classifying hazardous wastes generated from the drilling, construction and operation.
• Packaging hazardous wastes according to their categories in proper packing or containers, which satisfy the technical safety requirements, and the signs and marks there on must be clear as prescribed by the local regulatory agency.
• Storing hazardous wastes safely within the facility before transfer to the collectors, transporters, keepers, treaters and disposers.

The storage areas for hazardous waste must satisfy the requirements waste management requirements prescribed by the local regulatory agencies, e.g. fences, signboards and other guarantee measures.

• Noise

  The general work area noise limit for human health/worker exposure within the plant boundary shall be 85 dB (A) at one metre, unless otherwise specified.
  The provisions for equipment noise levels, sound power level and sound pressure level, shall comply fully with, but not be limited to the requirements referenced in Company Standards.

  Equipment shall be selected that will reduce noise levels to ALARP using the following hierarchy of controls:

  • Avoid the need for equipment that makes noise.
  • Substitute equipment with other equipment that makes less noise.
  • Isolate equipment that makes noise from recipients.
  • Apply engineering controls (if elimination or substitution not possible) to reduce noise levels to < 85dB (A).
  • Apply procedural controls to reduce duration or magnitude of exposure.
    Provide personal hearing protection.

• Resource Consumption

  In order to minimize the impact to the environment, Company will identify and monitor the consumption materials and energy, the objects are not limited to:

  • Chemical use and consumption
  • Energy
  • Water Resources

• Environmental Monitoring

  Monitoring programs will be conducted in accordance with international standards, techniques and methods for sample collection and analysis developed by the International Standards Organization and the European Committee for Standardization. Non-continuous sampling will be conducted by suitably trained and qualified personnel.

  Monitoring activities will include the monitoring of releases to air from stacks and vents, ambient air, surface and ground water, including biological parameters and sediments. In addition, the monitoring of soil and noise and vibration monitoring will be conducted as appropriate.

• Security

  Country security remains the biggest hindrance for the whole of oil business. Start of field development requires extraordinary security arrangements and involvement of NOC PFGs (Petroleum Facilities Guards). NOO gives security the most attention and precautions. Prior to any field activities, a suitable security screening shall be conducted to determine the appropriate controls that must be applied to ensure the safety security operations. A Security Plan will be part of the HSE management system and should stipulate the details of the requirements for secure mobilization to field, work on site, and security emergency plan. Contractors and subcontractors should develop their own security plans which controls security in their own sphere of the operations.

• Corporate Social Responsibilities (CSR)

  Good Community Relations will help to achieve the security and trouble-free operation of any development work being carried out. All companies/contractors involved in the operations have an obligation to act in a responsible manner and to avoid mishandling of community relations. Mishandling may include for example recruiting labour or hiring equipment from other towns, poor damage compensation, unfair treatment or insensitivity to cultural aspects. The following principles shall apply to establish good community relations for the field operations:

  • All persons involved in the operations are asked to treat the members of the community with respect and sensitivity to cultural aspects and are to consider any local customs.
  • Sound communication with the stakeholders in the operations area, including non-government organisations and population groups, is to be considered as necessary to help establishing and keeping good Community Relations.
  • Job creation and local contracting, even when limited, has a positive impact on the operations and the local community and tribes, however, it may also create expectations, which probably cannot always be met. To ensure that any jobs and local services will be properly distributed amongst interested parties, distribution shall be co-ordinated with the local government authorities. Hiring labour or equipment from other towns should be avoided as long as the locals can provide such labour and equipment according to NOO standard.
  • Community Relations concerns, or problems arising during the course of the operations, are to be reported to the NOO General Manager, or his Representative.
  • The NOO Management team has established and will continue to establish good relationships with the local people.