Read BTC_English_General_OSRP_Content_Main_Document.pdf text version

BAKU ­ TBILISI ­ CEYHAN OIL PIPELINE PROJECT

GENERAL OIL SPILL RESPONSE PLAN

Document Number: AGT 000-0000-OP-PLN-00004

Rev No. Issue A3 Issue A2 Issue 2 Issue 1

Date 23-1-04 16-1-04 19-12-03 2-11-03

Status Final Final report to Lender Group Draft Final to Lender Group Final Draft Issue to Lender Group Prior to Financial Close

Authors HJR HJR HJR HJR

Approved AJ AJ AJ AJ

Authorised JD JD JD JD

General Oil Spill Response Plan

BTC Project

TABLE OF CONTENTS Page 6 6 6 7 8 9 11 11 11 12 13 14 14 15 15 16 16 20 20 20 21 22 23 23 24 24 25 27 28 28 29 29 29 34 34 34 34 35 35 36 36 37 38 38 39 39 41 41

1

2

3

4 5

6

Introduction 1.1 Project Overview 1.2 Background 1.3 Background of Oil Spill Planning Process 1.4 Scope of the General OSRP 1.5 Document Layout General procedures 2.1 Associated Operational Plans 2.2 Linkages between Procedures 2.3 Boundaries of BTC Co. Responsibility 2.4 Pipeline Operations Response organisation 3.1 Group Crisis Team (GCT) 3.2 Business Support Team (BST) 3.3 Incident Management Team (IMT) 3.4 In-Country IMT Support Unit 3.5 Site Response Team (SRT) 3.6 Oil Spill Response Contractor ­ Azerbaijan and Georgia 3.7 Oil Spill Response in Turkey 3.8 Training 3.9 Exercises Oil Properties And Behaviour In The Environment Response strategies 5.1 Facilities 5.2 GIS / GPS Support Services 5.3 Incident Management System Manual 5.4 OSRP Format 5.5 Setting Response Priorities 5.6 Containment Manuals 5.6.1 Containment Manual Structure 5.6.2 Containment Sites 5.6.3 Database 5.7 Protection of Sensitive Receptors Spill response equipment 6.1 International Legislation 6.2 Benchmarking 6.3 The Risk Assessment Process 6.4 Defining Tiers 6.5 Tier 1 (Minor Spills): 6.6 Tier 2 (Major Spills): 6.6.1 Defining Tier 2 Spill Volumes 6.6.2 Tier 2 Response Time Planning Guidelines 6.7 Tier 3 (Crisis Event): 6.7.1 Tier 3 Spill Volume Planning Guidelines 6.7.2 Tier 3 Response Time Planning Guidelines 6.8 Safety Standards 6.9 Locations for Storage of Equipment 6.10 Equipment

Page 2

AGT000-0000-OP-PLN-00004 ­Rev A2

General Oil Spill Response Plan

BTC Project

6.10.1 Equipment for Inland Response 6.10.2 Equipment Selection for Ceyhan 6.10.2.1 Dispersants 6.10.2.2 Equipment Lists 6.11 Equipment Maintenance 6.12 Sharing of Oil Spill Equipment 7 Waste Management 7.1 Solid Waste Management 7.2 Decanting 7.3 Draft Waste Management Plan 8 Communications 8.1 Communications in the Event of a spill 8.2 Communications Systems 8.2.1 Emergency Communications Network 8.2.2 Tactical / Logistical Communications 9 Consultation 9.1 Consultation with Communities 9.2 Establishing Links with Local Contractors 9.3 Consultation in developing Response Strategies 9.4 Involving the Community in Response Exercises 9.5 Consultation with Host Government Agencies 9.6 Consultation outside Azerbaijan, Georgia & Turkey 9.7 Consultation with Lender Groups 10 Strategic and Tactical Initiatives 10.1 Transboundary events 10.2 Cleanup levels 10.3 Importation of equipment 10.4 Disposal options 10.5 Drinking Water Supplies 10.6 Wildlife Care 11 Programme 11.1 Updating the OSRP Appendices A - ESPOO Consultation B ­ Table of Contents ­ Country Specific OSRP C ­ Draft Waste Management Plan D ­ Environmental and Social Sensitivities Example ­ Georgia E ­ Oil Properties Discussion F ­ Behaviour of Oil in various Onshore Environments G ­ Example output from the Containment manual Database H ­ Spill Volume Estimates I ­ Examples of Decision Guides

42 43 44 44 45 45 46 46 47 47 48 48 49 49 49 51 51 51 51 52 52 53 54 55 55 55 56 56 57 57 58 58

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 3

General Oil Spill Response Plan

BTC Project

Acronyms and Abbreviations ACG AGI AGT Azeri-Chirag-Gunashli Development Area in the Caspian Sea Above Ground Installation Azerbaijan ­ Georgia ­ Turkey Pipeline Project (includes BTC Oil Pipeline and SCP Gas Pipeline) BMES Briggs Marine Environmental Services BMT Business Management Team BIL BOTAS International Limited BOTAS Boru Hatlari ile Petrol Taima A.. (Petroleum Pipeline Corporation established by the Turkish Petroleum Corporation) BP British Petroleum BTC Baku-Tbilisi-Ceyhan Pipeline Project CEM Crisis and Emergency Management CONCAWE Conservation of Clean Air and Water in Europe C&H Corbett and Holt LLC CM Crisis Manager CS Containment Site EARL East Asian Response Ltd ERA Environmental Risk Assessment ESAP Environmental and Social Action Plan ESIA Environmental and Social Impact Assessment Espoo Convention on EIA in a Transboundary Context (Espoo, 1991) EU European Union GCT Group Crisis Team GIOC Georgian International Oil Corporation HGA Host Government Agreement IFI International Financial Institution IGA Inter Government Agreement IMO International Maritime Organisation IMS Incident Management System IMT Incident Management Team IPIECA The International Petroleum Industry Environmental Conservation Association LLC Limited Liability Company LSTKA Lump Sum Turn Key Agreement MAP Mediterranean Action Plan MEP Main Export Pipeline (old name for what is now BTC) MOIG Mediterranean Oil Industry Group NREP Northern Route Export Pipeline OSIS An oil spill modelling System OSR Oil Spill Response OSRO Oil Spill Response Organisation OSRP Oil Spill Response Plan OSRL Oil Spill Response Ltd RA Risk Assessment REMPEC Regional Marine Pollution Emergency Response Centre for the Mediterranean Sea SCP South Caucuses Gas Pipeline Project (formally Shah Deniz Gas Pipeline Project) SLIP Supplementary Lender Information Pack (of ESIAs)

AGT000-0000-OP-PLN-00004 ­Rev A2 Page 4

General Oil Spill Response Plan

BTC Project

SOCAR, SRT TPAO WREP

State Oil Company of the Azerbaijan Republic Site Response Team Turkiye Petrolleri Anonim Ortakligi (Turkish Petroleum Corporation) Western Route Export Pipeline

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 5

General Oil Spill Response Plan

BTC Project

1

INTRODUCTION

This document provides an update on the Oil Spill Response (OSR) planning process for the BTC pipeline project. This General Oil Spill Response Plan has been developed in response to a specific request of the ECA environmental representatives, OPIC and Mizuho Corporate Bank. The purpose of developing the GOSRP is to provide a guide to the production of the country specific OSRPs. 1.1 Project Overview

The BTC Pipeline System has been designed to transport crude oil from the AzeriChirag-Gunashli (ACG) oil field complex in the Caspian Sea to the Mediterranean Sea. It includes 1750 kilometres of buried pipeline extending from the Sangachal Terminal in Azerbaijan, across Azerbaijan, Georgia, and Turkey, to the Marine Terminal at Ceyhan, Turkey. The location of the BTC Pipeline System is shown in Figure 1.1. Figure 1.1 Project Overview

1.2

Background

The BTC pipeline and Ceyhan Terminal have been designed to meet or exceed the relevant international technical, environmental and social codes and standards. Specifically the pipeline has been designed in accordance with ASME B31.4 including: pipeline routing, hydraulic design, structural design, contract specifications and leak detection. Similarly the Ceyhan Terminal and loading facilities have been designed in accordance with international standards with experts employed to address specific issues such as geohazard design. The rigorous approach to the design effort

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 6

General Oil Spill Response Plan

BTC Project

will ensure that the pipeline is constructed and operated in a manner that minimises the likelihood of oil leaks from the pipeline system. Despite high levels of design and operational standards the project sponsors recognise that there is always a small residual risk of a leak occurring along the pipeline system or at the terminal and loading facility. As part of its commitment to the protection of the environment in which the BTC pipeline resides, the BTC owners are developing a world-class response system to deal with any scale of release and to minimise its impact. However unlikely an oil spill from the pipeline may be, BTC Co. remains committed to respond effectively through implementation of well planned operator response and the rapid deployment of field response, appropriate to the scale of the incident. 1.3 Background of Oil Spill Planning Process

Detailed planning for pipeline leaks is essential if an effective response is to be implemented. In undertaking this planning, a programme of consultation, development of procedures, employment and training of staff and purchase of response equipment has been developed. An overview of the Oil Spill strategy being adopted by BTC Co. is provided in the country specific E(S)IA's and specifically in the "Framework for Development of a Comprehensive Oil Spill Response Capability for the BTC Project" incorporated as an appendix in each E(S)IA. A strategy document was subsequently developed and issued as part of the Supplementary Lender Information Pack (SLIP). Variations of these Framework and Strategy documents have subsequently been developed to update key stakeholders. In particular a document titled Oil Spill Response Strategy - Update to GIOC has been produced and issued to relevant parties in Georgia. This current document (the General Oil Spill Response Plan) provides lenders and other interested parties with an update on the planning process and to describe the strategy being developed in addressing key aspects of Oil Spill Planning for BTC. Hand in hand with the development of the oil spill plans, operational management plans and procedures are needed to assist in the planned response. Development of a comprehensive set of procedures and implementation of appropriate training is therefore very important and is being implemented as described in Figure 1.2.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 7

General Oil Spill Response Plan

BTC Project

Figure 1.2 Overview of oil spill response plans and Operational Plan Development Oil Spill Response Plans, Procedures and Implementation Oil Spill Response Framework Document Operational Plans, Procedures and Implementation Develop concepts for operations (described in ESIA and OSRP Framework)

Oil Spill Strategy Document

This "General" Oil Spill Response Plan Country Specific Oil Spill Response Plans Containment Manuals and Coastal Sensitivity and Shore Protection Manual Purchase Oil Spill Response Equipment Employ and Train Response Staff Operations Procedures and Manuals Development Purchase Equipment and Vehicles for Operational Requirements Employ and Train Field Staff

1.4

Scope of the General OSRP

This General Oil Spill Response Plan has been developed in response to a specific request of the ECA environmental representatives, OPIC and Mizuho Corporate Bank. The "Environmental Sub-Group" request indicates the General Oil Spill Response Plan should describe: " the process for the overall coordination of a response to an oil spill. The General OSRP will not replace the need for AreaSpecific OSRPs to cover sensitive areas such as the Karayazi aquifer in Azerbaijan, the Borjomi and Tsalka regions in Georgia or the key Sensitive Environmental Areas identified in the Turkish ESIA, but will serve as a framework and reference document for the development of those Area-Specific OSRPs." Section 7.2 of the Environmental and Social Action Plan for Construction (ESAP) provides details of the legal and regulatory basis in which the Oil Spill Response planning, including this document is being undertaken. This General Oil Spill Plan seeks to:

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 8

General Oil Spill Response Plan

BTC Project

· · ·

· · 1.5

Update interested parties on the Oil Spill Planning process Provide an overview of information that is being gathered for the Country Specific OSRPs Provide the BP, BOTAS and BOTAS International Limited (BIL) teams with a status report on oil spill related issues that will be used as the basis for dialogue as BP seeks to get consistency of approach across all three Host Countries Provide examples of how gathered data is being used in refinement of country and area specific response strategies Provide examples of outcomes from the planning process Document Layout

Each of the specific issues as specified in the ESAP section 7.2 are addressed in this report as follows: General Procedures A list of general procedures to be followed in the event of an oil spill, including, for example: action to be taken by any employee observing a spill; action to be taken by an emergency response team leader following a spill; emergency checklists for each piece of equipment (storage tanks, pipeline, etc); emergency actions for Tier 1 ­ Tier 3 spills; incident notification and reporting requirements; Response Organisations A section describing the tiered response system and the organisational structures to be implemented for Tier 1, Tier 2 and Tier 3 spills; Oil Properties A section describing the properties and behavior of spilled oil and the potential effects that spilled oil may have in various environments encountered in the Project area, including the "fate" of the oil (that is, how the oil's chemical composition changes due to "weathering" caused by evaporation and other photochemical reactions); Response Strategies for Specific Environments Environmental response strategies for specific environments (offshore response, river and wetlands response, land response and shoreline protection and clean-up); Spill Response Equipment An indicative list of spill response equipment for Tier 1, Tier 2 and Tier 3 spills; Waste Management A section containing guidelines for minimising the waste resulting from oil spill response operations (considering the types, characteristics and quantities of waste); procedures for inventory and tracking of waste; characterisation, segregation and disposal of different types of waste and procedures for waste collection, packaging and storage; Communications & Logistics Details of spill communications capabilities and logistical support and services; Wildlife Protection Details of wildlife response resources, and safety guidelines for minimising risks associated with wildlife rescue; People Safety A guide for all Project personnel for the protection and safety of personnel working on spill responses, including provision for training; recommended work practices;

AGT000-0000-OP-PLN-00004 ­Rev A2 Page 9

Section 2

Section 3

Section 4

Section 5

Section 6 Section 7

Section 8 Section 10.6

Section 6.8

General Oil Spill Response Plan

BTC Project

decontamination procedures and general hygiene, sanitation and housekeeping guidelines; Environmental Sensitivities An overview of environmentally Section 5.6 sensitive areas that may be affected by the Project (detailed diagrams and maps of sensitive areas will be developed and included in the Country-Specific OSRPs). In addition a section describing the Consultation process being undertaken is included. Section 9 In addition a section on Strategic & Tactical initiatives is Section 10 included An Updated programme for going forward is also included Section 11

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 10

General Oil Spill Response Plan

BTC Project

2

GENERAL PROCEDURES

The aims and objectives of the proposed BTC Oil Spill Response Planning process is to provide the means to: · · · · · · · · 2.1 Control a release, which may arise from a fault in the operation of the pipeline and associated facilities. Minimise the volume of any release, if they do occur, by securing the source in the most appropriate way. Minimise the extent of movement of the released oil from the source, by timely containment. Understand the environmental and social receptors that could potentially be effected in the unlikely event of a spill Document key organisations and individuals that should be contacted in the event of a spill Minimise the environmental impact of primary releases by timely containment and recovery response. Maximise the effectiveness of the recovery response through the selection of the appropriate response personnel, equipment and technique to be employed. Maximise the effectiveness of the response through use of trained and competent, operational and response teams. Associated Operational Plans

In order to minimise the environmental damage of a leak event, it is important that the pipeline operations staff take appropriate actions. The presence of a leak is likely to be identified by the systems operators via the leak detection system. Pipeline patrols will identify evidence of potential or actual interference from third parties or erosion. The operators will assess information from the systems, patrol personnel and other sources and the implications of undertaking specific actions assessed. Having taken action (which may involve shutting down the pipeline) the operations team will implement procedures for: · Ascertaining more information about the spill · Minimising the potential spill size · Initiation of procedures for fault correction and/or pipeline repair Development of a comprehensive set of procedures and implementation of appropriate training is therefore very important and is being implemented as described in Figure 1.2. 2.2 Linkages between Procedures

BTC Co. and BIL Operations and Oil Spill teams are working to develop a comprehensive set of plans that provide all personal involved in operations with the appropriate level of documentation. Table 2.1 summarises the procedures that will describe the responses that need to be undertaken in the event of a suspected or actual oil spill.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 11

General Oil Spill Response Plan

BTC Project

Table 2.1 Hierarchy of Oil Spill Procedures Response Response to indication of release arising from operations patrols, control room indications or third party alert. Initial evaluation of scale of release. Deployment to location of spill and initial setup of response teams under an On-Scene Commander, including personal safety risk assessments. Coordination of oil spill response within overall incident management system Guidance on pre-planned containment and coastal sensitivity mapping and deployment of relevant equipment Strategy and organization for tiered response according to incident scale and local sensitivities To be Described in BTC Co. Operations incident notification procedure

BTC/Contractor Action Plans

Oil

Spill

Response

BTC Co. Operations interface with BP's Incident Management System Manual Country-Specific Pipeline (and Terminal) Oil Spill Response Manuals. Country Specific Pipeline ( and Terminal) OSRPs. A detailed table of contents for the Georgian Country Specific OSRP is provided in Appendix B as an example.

Plans for minimizing , separation, treatment Waste management guidance included in and disposal of resulting contaminated the Country Specific OSRPs materials." 2.3 Boundaries of BTC Co. Responsibility

BTC Co. is accountable for oil spills arising from where the pipeline passes the fence line at the Sangachal Terminal (Azerbaijan) to the end of the loading arms at Ceyhan Terminal in Turkey, including the BTC Ceyhan Terminal storage and loading facilities. In addition to spills inland, the following list indicates the types of marine spill events that are within BTC's responsibility: 1. 2. 3. 4. 5. Spills emanating from the BTC Ceyhan tank farm that reach marine waters. Spills from any BTC pipeline rupture that reach marine waters, such as those emanating from a jetty line leak. Spills during vessel loading, including overflows, hose leaks, etc. Spills relating to a collision between the vessel and the loading facility. Spills resulting from accidents with BTC tugboats, including tug spills, or spills resulting from tug collision with the tanker, or spills from the tanker during movement controlled by BTC tugboats.

Spills, for example, caused by a vessel outside of BTC Co. control (e.g. grounding, collision, structural failure, etc.) are not the responsibility of BTC. Spills from a tanker, are assumed to be the responsibility of the ship operator and the host government. Not-withstanding the foregoing, BTC Co. will be prepared to cooperate with others in accordance with internal corporate policy should an oil spill occur outside the BTC Co. accountabilities.

AGT000-0000-OP-PLN-00004 ­Rev A2 Page 12

General Oil Spill Response Plan

BTC Project

2.4

Pipeline Operations

BP will operate the Azerbaijan and Georgian sections of the BTC pipeline on behalf of BTC Co. For the Turkish section of the pipeline BTC Co has entered into an operating agreement with BOTAS International Limited (BIL). This operating agreement sets out the contractual obligations of BIL including requirements to establish: · · · · · an HSE Management System a Crisis Management System aligned with the BP IMS oil spill response procedures oil spill response equipment a Geographical Information System (GIS)

BIL is responsible for the procurement, commissioning, maintenance of oil spill response equipment and training of the necessary personal. BP is working closely with BOTAS and BIL to ensure operating procedures and associated documentation is developed in a manner consistent with those being developed for the Azerbaijan and Georgian section of the pipeline.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 13

General Oil Spill Response Plan

BTC Project

3

RESPONSE ORGANISATION

BTC Co. is in the process of establishing an oil spill response organization with the capability to manage the response to an oil spill of any size. This organization will be based on principles of the Incident Command System ("ICS"). BP Explorations (Caspian Sea) Limited is the assigned operator of the BTC System, and has other operations in the Host Countries. BP has established oil spill and emergency response capabilities for its operations that fall under the umbrella of its Azerbaijan Business Unit's Incident Management System ("IMS"). This IMS is operational in Azerbaijan and Georgia and is currently being expanded into Turkey in association with BOTAS and BIL. BTC Co. plans to integrate the expanded IMS and its Incident Management Team ("IMT") into its response management organization, while retaining essential command and decision-making responsibilities. This integration will allow BTC Co. access to BP's corporate spill management experience, capability, and resources. The Azerbaijan Business Units approach to managing all incidents is described in the Incident management System Manual (document no UNIF-HSE-MA-400). In line with BP guidelines to ensure a coordinated response as outlined below:

Team Responsibility in an Incident Group Strategic Management

Group Crisis Team (GCT)

Business Management Team (BMT)

Business Strategic Management, Continued Business Operations, Support to IMT Overall Incident Response Management, Support to SRT

Incident Management Team (IMT)

Facility On-site Response Operation Site Response Team (SRT)

3.1

Group Crisis Team (GCT)

The Group Crisis Team in London forms a Group response strategy and pro-actively manages such issues as BP image, license to operate, and liabilities/loss potential, which could threaten the BP Group as a whole. The GCT's prime responsibilities are to: 1. Determine the principal impact of the crisis. 2. Ensure that information associated with the incident is promptly considered by the Group Crisis Team if it is formed and decisions of escalation and deescalation are addressed.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 14

General Oil Spill Response Plan

BTC Project

3. Review the business response to the incident and be assured that Group concerns (e.g. external media, government and shareholder issues) are considered and appropriately managed. 4. Review adequacy of information received, and respond to the BMT accordingly. 3.2 Business Support Team (BST)

Composed of senior management personnel who provide support to the IMT and analyze the implications of an incident and response operations on the company's viability, operability, and credibility. The BMT will be led by the Crisis Manager, or his nominee. The BMT's responsibilities are to: 1. Develop and co-ordinate an overall business response. 2. Provide and deploy additional resources as needed by the Incident Management Team. 3. Ensure good communications with the Incident Management Team, BP corporate head office, and the BP Group Crisis Team (if formed). 4. Implement any strategic decisions taken by the Group Crisis Team. 3.3 Incident Management Team (IMT)

Composed of specially trained management personnel who provide support to the SRT and interface with company management, government agencies, media, and the public. The primary role of the Incident Management Team is to support the Site Response Team with: mobilizing required internal and external resources, develop response strategy, notification of government organization and media, Next of Kin (NOK) and other issues related to the emergency. Members of the Incident Management Team are responsible for: 1. Responding to emergencies and functioning in a predetermined position on the IMT. 2. Maintaining qualifications and completing training as indicated by the IMT position assignment. 3. Maintaining a current copy of the Incident Management System (IMS) for use during IMT activation. 4. Participating within the assigned IMT section and contributing to the development of specific response procedures for the IMT.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 15

General Oil Spill Response Plan

BTC Project

3.4

In-Country IMT Support Unit

As the BTC pipeline system traverses three countries BP is looking to complement the roles and responsibilities to ensure the involvement of operational people in the country in which the incident occurs. This is of particular relevance for exercises or incidents in Georgia and particularly in Turkey where BOTAS International Ltd (BIL) will be operating the pipeline. BTC Co is actively working with BOTAS and BIL in establishing appropriate reporting structures and roles and responsibilities. BTC Co is working closely with BIL to ensure that, in accordance with the Operating Agreement, BIL develops a "Crisis management system procedures that fully integrate with the crisis management systems and procedures developed by the MEP (read BTC) Participant for the MEP System ("Crisis Management System Procedures")". The existing IMS manual describes the roles and responsibilities of the In-Country IMT Support Units. The roles and responsibilities of these In-Country IMT Support Unit correspond with the relevant ICS positions in the Baku IMT general and command staffs. Specifically the support units include: Liaison Officer; Security Officer; Logistics Officer; Public Information Officer; and Environmental Officer. 3.5 Site Response Team (SRT)

Composed of specially trained and equipped personnel who can respond safely and rapidly to an incident scene and mount and sustain tactical response operations. Every manager of BP operation facility or project is responsible for: 1. Developing, reviewing and revising facility/operation specific response plans, utilizing a comprehensive planning process, which address the response procedures and resources needed to effectively mitigate all reasonable anticipated emergencies. 2. Developing and maintaining emergency response capability that properly reflects the facility/operations' risks for all reasonably anticipated emergencies. This capability includes equipment and personnel with skills consistent with BP standards. 3. Conducting and participating in emergency response training and exercises to assure the readiness of plans, personnel and resources. 4. Responding to and managing emergencies affecting their facilities/operation utilizing the facility/operation specific Emergency Response Plan and the BP Incident Management System for operations in Azerbaijan, Georgia and Turkey. 5. Reporting all events, major emergencies and crisis, as required by this program. The following diagrams describe the response management structure at three levels:

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 16

General Oil Spill Response Plan

BTC Project

Figure 3.1 Incident Management - Organisational Structure ­ BP Company Level

On- scene team

MANAGE THE INCIDENT INCIDENT MANAGEMENT TEAM FACILITY RESPONSE PLANS

In-Country IMT Support Unit

NATIONAL ASSOCIATE PLAN

MANAGE BUSINESS IMPACT

BUSINESS SUPPORT/CRISIS TEAM

BUSINESS SUPPORT PLAN

REGIONAL SUPPORT PLAN

ADVICE EXPERTISE FACILITIES MUTUAL AID

EMERGENCY SUPPORT CENTRES

MANAGE GROUP IMPACT

GROUP CRISIS TEAM

GROUP CRISIS PLAN

Responder Teams

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 17

General Oil Spill Response Plan

BTC Project

Figure 3.2 Incident Management - Organisational Structure ­ BP Azerbaijan Business Unit Level

BST

Emergency Co-ordinator

Business Support Manager External Affairs Section

Operations Section

·Implications on future operations ·Implications on other operations ·Partner liaison ·Business continuity

Planning Section

·Situation Unit ·HSE ·Security

Logistics Section

·Human Resources ·Administration ·Communications/IT ·Procurement/Transportation

Finance Section

·Legal and Claims ·Accounting ·Documentation

IMT

Emergency Co-ordinator

Incident Manager External Affairs Section

In-Country IMT Support team

Operations Section

On-Scene Commander

Planning Section

·Situation Unit ·Health ·Safety ·Environment ·Security

Logistics Section

·Human Resources ·Administration ·Procurement ·Transportation ·Communications

Finance Section

·Legal ·Claims ·Accounting ·Documentation

Incident Scene

·Operation A ·Operation B ·Operation C ·Operation D

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 18

General Oil Spill Response Plan

BTC Project

Figure 3.3 Oil Spill Response Management - Organisational Structure ­ Country Level

Tier 3 Response Capability provided by International Response Organisation

Incident Manager (located in Baku)

In Country IMT Support Unit Located in: - Tbilisi (in event of incident in Georgia) -Ceyhan (in the event of an incident in Turkey)

On Scene Commander

Notes

Source Control

(Pipeline Repair Coordinator

Oil Spill Response Coordinator

HSE

Security

Fire

Green depicts role of Country support Unit which is managed by BP in Az and Geo and by BOTASIL in Turkey

Site Manager CS 1

Site Manager CS 2

Site Manager CS 3

Special Team Manager

Yellow depicts roles of dedicated oil spill response personal CS = containment Site

Oil Spill Responder(s)

AGT000-0000-OP-PLN-00004 ­Rev A2

Oil Spill Responder(s)

Oil Spill Responder(s)

Page 19

General Oil Spill Response Plan

BTC Project

3.6

Oil Spill Response Contractor ­ Azerbaijan and Georgia

BTC Co is in the process of establishing a contract with an international oil spill response contractor. This contractor will be required to provide sufficient staff and equipment in Azerbaijan and Georgia to ensure compliance with the BTC planning standards. The Oil Spill Response Contract for the Azerbaijan and Georgian sections of BTC will specify requirements for the following: · · · · · · 3.7 Locating equipment and staff to ensure rapid deployment in remote areas; Ensuring vehicles (All Terrain Vehicles) available to respond off road - in adverse weather conditions ­ snow and rain; Organising back up support from helicopter (taking account of the significant safety and logistical issues and the Business Units Aviation Policy); Working with operations team to develop a common approach to containerisation/ storage of equipment to enable rapid response; Maintaining correct balance between vehicles, river deployment, land response equipment and labour; Focusing on employment and training of local personal. Oil Spill Response in Turkey

BTC Co is working with BOTAS and BOTAS International (BIL) to ensure an effective response capability is established in Turkey. BOTAS is responsible for development of the Oil Spill Response Plans and associated coastal sensitivity and containment manual. BIL will operate the Turkish section of the pipeline in accordance with the Operating agreement and will be responsible for provision of oil spill response resources. BOTAS and BIL are currently assessing options for establishment of the necessary resources to ensure appropriate oil spill response standby capability. This evaluation includes considering various contracting mechanisms for procurement of the necessary equipment, hiring of personal and establishment of supply bases. 3.8 Training

Efficient and effective oil spill response requires trained spill response teams. BTC Co.'s response teams will include company personnel, and experienced spill response support contractors. These teams may include local personnel resident in key areas proximate to critical containment / response points along the pipelines and local emergency services personnel. BP IMT members and other operations personal will undertake training in OSR / IMT arrangements. BTC Co. will establish and implement a full oil spill response training program, for its personnel, that includes: · · · · · · · Oil spill awareness training, Environmental awareness training Health and Safety training, First Aid training, ICS and OSRP familiarization, Equipment operation training, and Table top and field deployment exercises.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 20

General Oil Spill Response Plan

BTC Project

Oil Spill response personnel will undertake specialised training in accordance with internationally recognised accreditation schemes / standards. Table 3.1 provides examples of the types of training being planned for the OSR personnel in Azerbaijan and Georgia. Similar training will be undertaken by BIL for OSR personnel on the Turkish section of BTC. Table 3.1 Example of Oil Spill Response Training Standards being Proposed Type of Training Sorbant Familiarisation Training Oil Spill Response Equipment Familiarisation Beachmaster Course On Scene Commander Course Executive Commander / Incident Controller Road Tanker Rollover Training Basic Damming Course and Exercise Emergency Management Command and Control Course Onshore Oil Spill Response Training Breathing Apparatus Training Hazardous Materials Response Training Hazardous Materials Response Training Decontamination Procedures Confined Space Entry & Working Pollution Incident Training and Exercises BA Instructors Training Accreditation / Standard MCA Level 1 (UK Standard) MCA LEVEL 2 (UK Standard) MCA LEVEL 3 (IMO Level 1) MCA LEVEL 4 (IMO LEVEL2) MCA LEVEL 5 (IMO LEVEL 2) Approved by PITAS In house Course OPITO Accredited BOSCA Approved OPITO Accredited HAZWOPER LEVEL 1 - 3 HAZWOPER LEVEL 5 In House Course OPITO Accredited In House Course UK - Fire Service College Approved

-

Training programs will be conducted at regular intervals to ensure that responders have current knowledge. BTC Co.'s Oil Spill Contractors and BIL will be expected to participate in BTC Co. training programs and/or provide equivalent training to their personnel. Training and drills will be scheduled on a regular basis. 3.9 Exercises

BTC and BIL are developing a programme of desktop exercises and drills for the pipeline in each country and for Ceyhan Terminal. These exercise programmes will include:: · · · · Notification exercises; Emergency procedures exercises; Spill management team tabletop exercises; and Equipment deployment exercises.

These exercises will be an ongoing activity through the operational life of the project and will be designed to hone the skills of operations and dedicated oil spill response staff.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 21

General Oil Spill Response Plan

BTC Project

4

OIL PROPERTIES AND BEHAVIOUR IN THE ENVIRONMENT

Three types of crude oil, Azeri, Chirag, and Guneshli will be transported through the BTC Pipeline System. The properties of these crude's influence not only their behaviour and impacts when spilled, but also the types of emergency response actions and equipment that are required for their control and cleanup. Extensive testing of these oils has been conducted, and Azeri crude used as representative of the total throughput. Azeri crude oil is relatively waxy and may exhibit a wide range of viscosities depending on environmental conditions and how the oil has been handled in its transport through the system. When fresh and contained in the pipeline system at approximately 30 to 40ºC, Azeri crude behaves as a light to medium crude oil. If exposed to the environment the volatile components of the oil evaporate rapidly. Once cooled to ambient temperatures, the oil may be fluid and mobile under warm temperatures; however, at cool to cold temperatures, its viscosity is expected to increase to the point where it will be effectively immobile and difficult or impossible to pump without specialized equipment. It may also emulsify or pick up water. Emulsification will increase its viscosity and handling challenges. Azeri crude has an observed pour point ranging from just above 0ºC to over 20ºC, varying again on how it has been handled. At temperatures below its pour point, it may gel or solidify and be immobile. Spilled oil may become solid at higher elevations and during the winter in most of Georgia and North East Turkey. High viscosity and the tendency to solidify also reduces the probability of spilled oil penetrating into sediments. Because the oil is waxy, it does not adhere to surfaces as strongly as other more asphaltic oils. Thus Azeri crude will likely be easier to cleanup, although specialized equipment and handling procedures may be necessary. The complex behaviour of ACG crudes has resulted in the selection of response methods and equipment capable of responding to virtually any form of petroleum hydrocarbon, including diesel fuel and lubricants also handled by BTC in lesser quantities. Procedures and appropriate types of response equipment and resources must be matched to the nature and behaviour of oil transported by the BTC Pipeline, particularly as it weathers after any spill. Key oil properties to be used in oil spill response planning will be based on typical analysis of ACG Crude (Crude Assay A04398), including: · · · · · Specific Gravity: 0.8515 kg/l @ 15C (API 34.5) Viscosity: 15.62 cSt @ 20C (will increase significantly as pour point is approached) Pour Point: 1 C to 19C H2S: <10 ppm wt Emulsification Potential: Stable emulsions containing 50% water may be expected

More detailed discussions of oil properties and behaviour of oil on different environmental receptors are included in Appendix E and F respectively.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 22

General Oil Spill Response Plan

BTC Project

5

RESPONSE STRATEGIES

The BTC Pipeline System spans over 1700 kilometres of pipeline in three countries. In addition, many square kilometres of downslope areas and waterways are subject to potential exposure in the event of a release. Protection of these areas will require rapid and well-planned tactical response actions. Considering the size and complexity of the area, BTC Co. has divided the pipeline corridor and surrounding areas into manageable geographic segments. Designation of these segments has been based on common drainage, with each segment typically representing a subdivision of a watershed which represents the area potentially impacted by a release of oil from the pipeline or associated operations. Individual or multiple segments may be grouped into functional response zones, based on logistical issues including accessibility and driving times from resource bases. Figure 5.1 Example of Geographically- based Response (Azerbaijan)

5.1

Facilities

Whilst the majority of the planning is being undertaken to address Tier 2 spills it is also recognised that small (Tier 1) spills may occur around mechanical plant at the above ground facilities (AGI's) and at Ceyhan. Site specific oil spill strategies will be described in the facilities operating documents. These documents will include the necessary links to the Country Specific OSRP and the IMS manual.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 23

General Oil Spill Response Plan

BTC Project

5.2

GIS / GPS Support Services

BTC Co. has developed and will maintain a Geographic Information System (the "BTC GIS") engineering and environmental database. The BTC GIS will be utilised in the BTC Oil Spill Response planning process in two capacities: · · Data Retrieval - The BTC GIS will contain a large environmental database that can be queried during an emergency response. Oil Spill Response Management - The BTC GIS can also be utilized to provide spill response management support in the form of production of maps for response crews and response data management, including tracking of spill movement, response activities, and personnel, and in the production of illustrations and presentations for command staff and public relations. Combined with Global Positioning Systems ("GPS"), the BTC GIS capability will also offer an excellent method for tracking personnel and equipment. Incident Management System Manual

5.3

All incident management documentation developed for the BTC project will form part of the incident management plan. The BP Azerbaijan Business Unit IMS Manual covers procedures to be followed in events such as: Fires / Explosions Spills (Oil) / Releases (Gas) Injury / Casualty / Medevac Transportation Accident Natural Disasters

The IMS Manual includes: · · · · · · · · Policy and Expectations Response and Organization Notification and Callout Incident Management System Roles and Responsibilities Response Action Plans Meeting Agendas and Protocols Standard Operating Procedures

Relevant information from the existing Azerbaijan Business Unit IMS Manual is included in this document but, to minimize duplication and to avoid potential confusion, such information will not generally be included in the country specific oil spill response plans. Figure 5.2 provides an overview of how the Oil Spill response plans will be linked to the IMS Manual.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 24

General Oil Spill Response Plan

BTC Project

Figure 5.2 Document Hierarchy ­ Oil Spill Response Planning

Incident Management System Manual (Az, Geo, Tk)

OSRP - Pipeline

OSRP - Pipeline

OSRP - Pipeline

Containment Manual

Containment Manual

Containment Manual

OSRP ­ Ceyhan Marine Shoreline Protection Manual Turkey Georgia Azerbaijan

5.4

OSRP Format

BTC Co. has developed a standardized OSRP format that is supported by the overarching IMS, while meeting the specific needs of each Host Country. Each OSRP will be a country specific stand-alone document organized to facilitate emergency response use. This format has been developed after consideration of the existing Western Route Export Pipelines OSRP's and internationally recognised standards such as those set out in "A Guide to Contingency Planning for Oil Spills on Water" (IPIECA 2000). An important part of the process of determination of the layout has been engagement with the BTC operations management team in Azerbaijan, Georgia and Turkey. On this basis BTC, BOTAS and BIL have agreed on a structure as shown in Table 5.1.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 25

General Oil Spill Response Plan

BTC Project

Table 5.1 Summary of Contents of Country Specific Oil Spill Response Plan - Pipelines

Sections 1. Purpose And Scope 2. Environmental Risk and Response Strategy 3. Safety 4. Spill Response Organization 5. Notifications 5. Communications 6. Response Actions 7. Waste Management 8. Environmental Monitoring 9. Wildlife Care 10. Volunteers 11. Documentation 12. Public Relations 13. Response Resources 14. Training and Drills Appendices 1. Description of Facilities 2. Oil Properties 3. Environmental Data 4. Oil Spill Response Action Plan (OS RAP) 5. Site Safety 6. Transboundary Agreement 7. Waste Management 8. Documentation 9. Public Relations 10. Response Resources

A more detailed table of contents for the Georgian Country Specific OSRP is provided in Appendix B as an example. All oil spills involve unique combinations of conditions and circumstances, and any response action must be addressed at the time of the event, based on prevailing conditions. The Response Action Plans are being developed in recognition that it is not practical or appropriate to plan for all possible combinations of spill scenarios and weather conditions and that informed decisions will need to be taken to ensure an effective response to any spill. The Oil Spill Response Action Plan provides practical information and guidance for responding to releases and will be a useful reference document for the Incident Commander and On Scene commanders. The Response Action plan in each OSRP will include the following sections: · · · · · · · · · · Notifications Procedures; Safety Assessment Procedures; Spill Assessment Procedures; Setting Response Priorities; Preplanned Response Actions; Containment and Cleanup Options; Selection of Response Equipment; Bioremediation and Phytoremediation; Chemical Treating Agents; and Response Site Setup and Decontamination.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 26

General Oil Spill Response Plan

BTC Project

5.5

Setting Response Priorities

BTC and BIL have engaged industry experts and environmental specialists to assist in gathering the necessary environmental and socio-economic information required to make informed decisions in the event of an oil spill. Methodologies for ranking receptors in respect to relative sensitivity to oil spills are particularly well developed for Marine Environments and in this respect the methodology described in Gundlach and Hayes (1976) has been adopted. The validity and applicability of the information is being checked through the involvement of local specialists and institutions and will be further reviewed as part of the consultation process as described in Section 9.3. In the event of a spill those charged with co-coordinating the response will consider the data provided in the OSRP and Containment manuals and make informed decisions based on these documents, the conditions and the resources available at the time. The decisions guides contained in the OS RAP section of the OSRPs will be key to assisting the co-coordinators in developing appropriate strategies. Additionally "Net Environmental Benefit Analysis", such as those described in "Choosing Spill Response Options to Minimise Damage" (IPEICA 2000), will be described in the OSRPs for adoption by the Incident Commander if appropriate. Such analysis assists decision makers determine the likely impact of a particular strategy and assess the impacts against alternatives. Net environmental benefit analysis is based on the premise that each proposed technique must have a discernable environmental benefit, which means that in some cases the best option may be to leave the oil to weather and degrade naturally. A series of decision guides will be included in the Oil Spill Response Action Plan. An example of such decision guides is shown in Figure 5.3 with additional guides provided in Appendix I.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 27

General Oil Spill Response Plan

BTC Project

Figure 5.3 Example of Decision Guides

Small work boat: Net / manual recovery. Skimmer boat: belt or brush skimmer. Small work boat: boom placement / support. Skimmer boat: Weir / oleophyllic skimmer. Small work boat: for support and sorbent placement. Skimmer boat: Oleophyllic Skimmer. Tug / skimmer boat: Net / manual recovery, belt or brush skimmer, vacuum system. Tug / skimmer boat: Weir / oleophyllic skimmer, vacuum system.

Solid

Shallow Calm Water

Condition of Spilled Oil Amount of Oil

Medium to High

Fluid

Type of Water Body

Solid

Light

Deep Open Water

Condition of Spilled Oil Medium to High

Fluid

Amount of Oil

Light

Tug / skimmer boat: Oleophyllic skimmer, sorbent.

5.6

Containment Manuals

The Containment Manuals are currently under development in Azerbaijan, Georgia and Turkey. The manuals will be the primary document utilised by the OSR personal in the event of an oil or fuel spill. The manuals are being developed by specialists in oil spill response and in accordance with the specification set out in the Framework OSRP: " This volume will graphically pathways, specific immediate volumes will be supported by volumes and pathways for an terminals." display Maps and/or aerial photographs, oil drainage response and containment sites. The hard-copy an interactive GIS system, which will display spill event at any location along the BTC pipeline and

5.6.1 Containment Manual Structure A draft table of contents has been developed for the Georgian section of BTC and includes the following sections. (i) (ii) (iii) (iv) (v) Introduction Spill Risk Analysis First Response Pipeline Route Environmental Sensitivities Containment Sites

Page 28

AGT000-0000-OP-PLN-00004 ­Rev A2

General Oil Spill Response Plan

BTC Project

(vi) Rendezvous Points (RVP) (vii) Response Zone and RVP Maps (viii) Downstream Environmental Sensitivities (ix) Downstream Environmental Sensitivity Maps 5.6.2 Containment Sites

The information of most relevance to the Oil Spill Response teams is Containment Site (CS) Information. It is these sites to which the response crews will transport equipment for deployment and where any recovered oil will be temporarily stored. Containment sites are being selected by the oil spill teams preparing the containment manuals. Information considered in selected these sites includes: · · · · · · Possible flow paths from the pipeline Oil Properties and likely behavior in different environmental conditions River characteristics Vehicle access Area available for equipment laydown and establishment of oil storage facilities Environmental Sensitivities

An overview of the containment sites identified from the initial field surveys in Georgia are included as Attachment D. Similar maps will be developed for Azerbaijan and Turkey. The containment manuals are being structured in such a way that the oil spill responders are quickly able to determine what containment site they should respond to, the equipment that should be used. 5.6.3 Database The majority of information collected from the field and desk based studies undertaken in preparation of the containment manuals is being stored in a database developed specifically for the BTC project. The input data, database structure and output layout have been developed as a collective effort between BOTAS, BTC Co and the various consultants. Appendix G provides an example output from the database. 5.7 Protection of Sensitive Receptors

Containment sites are being selected with the primary purpose of protecting sensitive downstream receptors. Whilst it is not necessary for the response contractors to understand the nature of the receptors downstream of the containment sites this information will be included in the Containment Manuals to assist the relevant individuals in developing scenario specific responses. Examples of the response strategies that are being developed for each segment of the pipeline are included in Table 5.2

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 29

General Oil Spill Response Plan

BTC Project

Table 5.2 Examples of Spill Scenarios and Recovery Methods

Scenario: Valve flange leak at pump station PSG1 in summer, oil is sprayed into air and impacts 50m of soil (Tier 1 incident)

2

Response

Initiate valve repair; immobilize pooled material with berms and sorbent; remove and replace oil saturated gravel and soil mechanically or manually; dispose of contaminated materials at approved location.

Scenario: Equipment operator hits pipeline while excavating during summer and at low elevation, pipeline discharges into river; some oil has entered Kura River and is flowing toward Azeri border (Tier 2 incident)

Response

Initiate containment actions as identified in Containment Manual; recover contained oil with skimmer(s) and vacuum trucks; initiate trans-boundary response; initiate stream bank cleanup with low pressure flushing into booms and recover with skimmers; store recovered materials onsite temporarily in portable tanks or lined pits; excavate and replace contaminated soil at source; complete final cleaning of streambed using sorbent and manual recovery; restore damaged vegetation and initiate temporary erosion control measures as appropriate.

Scenario: Accidental release into Lake Tsalka; oil has flowed into lake and is blowing to east along shoreline (Tier 2 Incident)

Response (Summer)

Temperature is warm enough to allow oil to flow; initiate response actions as identified in Containment Manual; contain oil flow on land using berms and filter barriers; contain oil on water using booms; recover contained oil by skimming and sorbent recovery; cleanup shorelines using low pressure flushing and contain/recover material removed; cleanup residual pooled oil on shorelines and land using sorbent and remove saturated soil. Restore impacted areas as necessary and initiate erosion control measures as appropriate. Assess situation (oil is expected to be solid and concentrated near source); construct snow/ice berms as necessary to control and still-moving oil: oil reaching flowing streams may be carried downstream in the form of broken chunks of oil ; Attempt to contain moving oil using filter barriers or, in lake waters, boom, if practical and safe to do so; map/mark oil location; if practical (and safe), manually recover oil/ice/snow and remove. If oil has reached Lake waters, and no other actions are possible, monitor situation until weather improves; complete recovery of oil prior to spring melting (cleanup may include installation of filter barriers or weirs between immobilized oil and wetland and excavation and replacement of contaminated soil. Steam may be used to liquefy, remove and herd oil for recovery. Erosion control measures will be taken as appropriate.

Response (Winter)

Scenario: Pipeline release above Kysia wetland; oil threatens upper reaches of wetland (Tier 2 Incident)

Response (Summer)

Initiate containment and protection actions identified in Containment Manual; construct diversion

berms, dams and filter fences as necessary to prevent flow of oil into wetland; apply loose sorbent to immobilize free oil which has entered wetland; assess situation to determine whether further actions in wetland are appropriate; initiate cleanup actions as appropriate (cleanup can include flushing, further use of sorbent to immobilize and recover oil, and bioremediation); conduct wetland restoration, if appropriate. Assess situation (oil is expected to be solid and concentrated near source); construct snow/ice berms as necessary to control and still-moving oil; map/mark oil location; if practical (and safe), manually recover oil/ice/snow and remove; if necessary, monitor situation until weather improves; complete recovery of oil prior to spring melting (cleanup may include installation of filter barriers or weirs between immobilized oil and wetland and excavation and replacement of contaminated soil. Erosion control measures will be taken as appropriate.

Response (Winter)

Scenario: Pipeline release into the Borjomola River above Borjomi (Tier 2 Incident)

Response (Winter)

Possible leak is reported; first snow has fallen and streams are starting to freeze over; personnel stationed in Andesit inspect stream crossings and do not report any oil; oil response contractor is dispatched to first containment site to prepare for possible deployment of equipment; inspection teams reach pipeline and determine that a small leak has occurred, but oil has moved only 50 feet from the pipeline and is solid (not moving any further); a snow berm is placed below the oil mass, and the boundaries of the oil are located using a hand-held GPS; no snow is forecast for several days and repair and cleanup crews are dispatched; oil cleanup consists of mechanical / manual recovery of oil and snow; area is inspected in spring and minor restoration conducted. Possible leak is reported; personnel stationed in Andesit inspect stream crossing and report that some very viscous oil is moving downstream; oil response contractor is dispatched to first containment site and initiates deployment actions (oil has not reached site by arrival time); crew at Andesit constructs small filter barriers a natural collection points to contain some of the oil; inspection crew finds release point and crew is dispatched to construct containment berms; once flow of oil is controlled, cleanup consists of manual recovery and low pressure flushing, starting from upstream and working downstream to collection points; oil is recovered by skimming and vacuum trucks and portable tanks used to contain recovered oil; restoration of damaged areas and erosion control measures are implemented along stream bank and area between pipeline and first stream.

Response (Summer)

A key activity being undertaken as part of the Containment Manual development is the compilation of environmental sensitivity data contained in the E(S)IA's. To

AGT000-0000-OP-PLN-00004 ­Rev A2 Page 30

General Oil Spill Response Plan

BTC Project

augment this information additional environmental data is being collected on receptors downstream of the pipeline corridor. Containment site locations and response strategies are being reviewed to ensure key receptors will be protected in the event of a spill. The assessment of downstream receptors has yet to be completed however initial findings from the assessments conducted as part of the ESIA and Containment Manual development have identified the following key receptors: In Azerbaijan the most sensitive areas are along the Kura river system and include: Receptor from the Varvara reservoir dam to the Turianchay river mouth near the settlements Ali-Bairamly and Khilly the Kura delta Type of Receptor Spawning fish, Barda Forbidden Area, tugay forests Fish-rearing stations Migrating, nesting and over wintering birds, growth and development of young fishes, fish rearing stations Large water offtake facilities Migrating, nesting and over wintering birds Significant fish and bird populations Fish rearing station, significant bird populations Fish rearing station, significant numbers of waterfowl

near Talysh near Sarysu lake Mingeshevir Reservoir Shamkir Reservoir Varvara Reservoir

In Georgia the most sensitive areas include: Receptor Type of Receptor

Chitakhevi hydropower station Surface Extraction Zemo Avchala hydropower station Surface Extraction Ortachala hydropower station Surface Extraction Gardabani main channel Surface Extraction "Tbilisi Power Station" and "AES Mtkvari" Surface Extraction Akhaltsikhe "Water Pipeline" Surface Extraction Tsalka utilities Surface Extraction Tetri Tskaro utilities Surface Extraction Marneuli Water Pipeline Surface Extraction "Rustavi Water" Ltd. Surface Extraction "Gardabani Water" Ltd. Surface Extraction Borjomi District Hospital Surface Extraction Rustavi metallurgic plant Surface Extraction Akhaltsikhe Department of Village Water Pipelines Surface Extraction (springs) Sanatorium "Borjomi-Likani" Surface Extraction Sanatorium "Borjomi-Likani" Surface Extraction Sanatorium " Likani" Surface Extraction Bakuriani Water pipeline Surface Extraction

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 31

General Oil Spill Response Plan

BTC Project

Receptor Gardabani Managed Reserve Area between Zooveterinary institute and Kumisi la Narianis Veli and Tabatskuri Lake Tsalka reservoir and associated basins Lake Imera Lake Cherepanovskoe Lake Bedeni Lake Beretskoe Chil-Chil Lake Alig÷l Narianis Veli wetlands At Mt. Tavkvetili Northern part of lake Tabatskuri Tskhratskaro Pass to Sakire Akhaltsikhe (Meskheti) Depression Gardabani Managed Reserve Borjomi State Nature Reserve Borjomi-Kharagauli National Park Borjomi-Kharagauli National Park, Expansion Zone Nedzvi Managed Reserve Ktsia upper reaches

Type of Receptor Faunal Areas Faunal Areas Faunal Areas Faunal Areas Faunal Areas Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity Floral Sensitivity

In Turkey the main potential receptors are associated with the large river systems and include: River Basin Key Receptor

Posof GE Border Posof Sensitive Flora and Fauna (Wildlife Protection Area) Ardahan Forest Sensitive Flora and Fauna (Important Bird Area _IBA) Sarikamis Forest Natural Site Area Erzurum Plain IBA Erzurum Plain Groundwater Kelkit Wildlife Protection Area Sensitive Flora and Fauna Kuru Potential Ramsar Site Ulas and Alakorak Potential Ramsar Site Kura Turkish / Georgian Border Aras (north) Arapaçay Dam at Turkish / Armenian Border Aras (south) Turkish / Armenian Border Çoruh (3 dams in construction) Turkish / Georgian Border Firat (upper) Tercan Dam Firat (lower) Keban Dam Kelkit Kiliçkaya Dam Kizilirmak Hirfanli Dam Zamanti (Seyhan System) Yedigöze Dam Sariz (Seyhan System) Yedigöze Dam Göksun (Ceyhan System) Menzelet Dam Aslanta Reservoir (Ceyhan System) Sir Dam

Page 32

AGT000-0000-OP-PLN-00004 ­Rev A2

General Oil Spill Response Plan

BTC Project

River Basin

Key Receptor

Aslanta Reservoir (Ceyhan System) Aslanta Reservoir Ceyhan (Ceyhan System) Iskenderun Gulf Kizlarsuyu (by Terminal) Iskenderun Gulf These receptors will be described in the Containment Manuals and where appropriate additional information to assist response crews in protecting the particular receptors will be provided. In particular additional data is being collected to ensure an effective response is mounted should a spill occur at any point along the pipeline in which the following receptors could be impacted:

RECEPTOR

KP

Karyazi Tsalka Lake Lake Tabatskuri Borjomi Catchment Posof Forest Sarikami Forest Pasinler Aquifer Erzurum Aquifer Erzurum Marshes Kuru Lake Ula and Alacorah Lakes Göksun Aquifer Çokak and Kizilonluk Faults Aslanta Reservior Adana ­ Ceyhan Aquifer

Az ­ 420-440 Geo- 100-150 Geo 175-178 Geo 177-197 Tk 17 Tk 167 ­ 173.0 Tk 258 ­ 292 Tk 298 ­ 318 Tk 301 - 302, 306 - 312 Tk 666 ­ 667 Tk 720­ 724 Tk 915 - 930 Tk 960 , 965 Tk 964 - 1000 Tk 1026 - 1058

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 33

General Oil Spill Response Plan

BTC Project

6

SPILL RESPONSE EQUIPMENT

Spill Response Equipment requirements are being determined by BTC Co and BIL using a comprehensive and transparent process involving: · · · · Review of International Legislation Benchmarking Consideration of the Environmental Data and particularly information in the Environmental Risk Assessment process Consideration of access road, weather and additional environmental information gathered during the desk based and field assessments undertaken as part of the Containment Manual development

BTC Co. is using the internationally accepted Tiered Response concept to describe different categories of oil spill events, based on their severity and availability of response resources. 6.1 International Legislation

The Oil Spill Response Framework document describes the international legislation that is being considered in developing the various plans and establishing the appropriate resources. Of those listed in the Framework document the following Conventions are particularly relevant: · · 6.2 International Convention on Oil Pollution Preparedness Response and Cooperation (OPRC) International Convention for the Prevention of Pollution from Ships, 1973, as amended (MARPOL 73/78) Benchmarking

BTC has convened several meeting as part of the oil spill response planning process. These meetings have included Peer Assists to which Oil Spill Response specialists and managers from outside of the BTC team have been invited to critique the work being undertaken and to provide information on other facilities. Information gathered from these meetings has been evaluated as part of a benchmarking exercise. Additionally legislation such as the US Code Of Federal Regulations No 49 (49 CFR) has been considered as part of this benchmarking exercise. 6.3 The Risk Assessment Process

Figure 6.1 provides an overview of the Risk Assessment process adopted as part of the engineering, E(S)IA and OSRP process.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 34

General Oil Spill Response Plan

BTC Project

Figure 6.1: Risk Assessment Process

H aza rd Iden tification

Freq u en cy A na ly sis

C on sequ en ce A n aly sis

R isk S um m a tion

R isk A ssessm en t

R isk C riteria

D ecisio n M a king

The outcomes from the assessment are described in detail in the ESIA's and supplementary information. The outputs from the ERA process provide the OSR teams with a good understanding of the relative risks of oil spills and can be used to ensure the response capabilities are commensurate with the risks (see Georgian Case Study below). Of particular importance in defining Tiers 1,2, and 3 is to understand the potential spill sizes from the facilities and pipeline to ensure that appropriate resources can be mobilized. 6.4 Defining Tiers

Tier classifications are determined in consideration of spill volume data (discussed above), environmental and societal sensitivity and other factors that can only be determined at the time of the incident. Tier definitions used by BTC are similar to those adopted internationally and are set out below: 6.5 Tier 1 (Minor Spills):

Tier 1 events include small operational leaks, which can be dealt with on site by local staff and contractors. Along the pipeline Tier 1 spills have the potential to occur during operations such as refuelling, pig launching and receiving, valve and flange leaks, and routine operation and maintenance activities. In most cases, containment and cleanup will be effected using the Spill Response Kits at each facility. The nearest equipment base will provide any additional oil spill equipment required. Although notified, support from the IMT will not be required. To assist in determination of the appropriate response

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 35

General Oil Spill Response Plan

BTC Project

resources in Georgia spills associated with: a minor leak from pipeline valves, a spill during fuel transport or a spill during refuelling are being considered as "Tier 1" spills. At Ceyhan Tier 1 spills have the potential to occur due to mechanical defects, corrosion, wear or operational error. Such releases could occur from the loading arm, pipelines or from the ship. 6.6 Tier 2 (Major Spills):

Tier 2 incidents include larger spills that require additional local (in-country) resources and manpower. Along the pipeline Tier 2 spills may result from fuel tanker accidents or leaks from the pipeline. Cleanup will be effected by dedicated oil spill equipment from incountry BTC Co. equipment stockpiles, in-country oil spill response contractors, equipment shared with other operators, or other in-country sources. Support from the IMT will be required. To assist in determination of the appropriate response resources the most probable spill sizes described above are being considered in equipment selection and adoption of response strategies. At Ceyhan a Tier 2 releases may occur from vessel fuel tanks or from the loading arm in the event of a vessel drifting off during loading As the BTC pipeline covers large distances BTC and BIL have divided the concept of Tier 2 into the following: · Tier 2 First Response ­ this is the response that can be initiated from a single oil spill response base located along the pipeline route or at Ceyhan · Full Tier 2 Capability ­ this is the response that can be deployed using all in country resources 6.6.1 Defining Tier 2 Spill Volumes

For the pipeline potential spill sizes have been derived from data collated by CONCAWE (Report No. 98: Western European Cross-Country Oil Pipelines 25 Year Performance Statistics). This information was used in defining the underlying failure frequencies used in the ERA model and to give a guide for the establishment of Oil Spill response capabilities. BTC and BIL are using these spill volumes in determination of the "first response" resources. These resources will be located at the various bases located in two or more locations in each country. For the pipeline the data indicates a most likely spill volume of 520m3. A similar approach has been adopted for determination of spill scenarios at Ceyhan as described in the EIA and indicates a most likely spill size of 350m3. BTC and BIL have also considered the spill volumes calculated in the ERA and are determining the Tier 2 (ie total in country capability) resource requirements on the basis of the spill volumes for a medium sized leak. On this basis the following Tier 2 (ie in country) spill volume planning guidelines have been adopted: Azerbaijan 2268 m3

Page 36

AGT000-0000-OP-PLN-00004 ­Rev A2

General Oil Spill Response Plan

BTC Project

Georgia Turkey (pipeline) Ceyhan

2815 m3 2163 m3 2200 m3

These values compare well with those used by the U.S. Coast Guard (1,830 m3) and Canadian Coastguard (1,000 ­ 2,500 m3). Adoption and communicating these volumes in this GOSRP is seen as an important means of conveying the intent by BP, BOTAS and BIL to follow a transparent process in determination of equipment requirements in each country. In the event of a spill, it is often difficult to determine quickly the exact cause, hole size or spill volume. Information from the risk assessment (Appendix H), site observations, and from SCADA will however assist responders in estimation of potential spill volumes. In instances where spill volumes are estimated to potentially exceed the Tier 2 values noted above a Tier 3 response will be initiated. Additionally if a spill occurs along the pipeline or at the terminal in a location that could likely impact on a highly sensitive receptor then a Tier 3 response may be initiated. Such an approach is in accordance with IMS Manual that describes an overarching philosophy of "over reaction" in the event of a spill or other incident. 6.6.2 Tier 2 Response Time Planning Guidelines

BTC aims to be able to deal with a Tier 2 spill by the use of in-country resources within the overall coordination of the BP Incident Management System. BTC will have dedicated Oil Spill personnel and stockpiles of oil spill equipment at strategic locations in each country. Table 6.1 Draft Response Time Planning Guidelines (Hours)

Activity Response Time Planning Guideline 0 2 Cumulative Response Time Planning Guideline 0 2 4 8 12 24

Notification Mobilisation of staff to Response Base Departure from Response Base with appropriate initial response equipment Travel time to spill site Deployment of initial Response Resources at spill site Full Tier 2 Capability in place using equipment and resources from other response bases

2

4 4 12

BTC and BIL are in the process of selecting response base locations using these planning guidelines. Information being considered in selection of the base locations includes: · · The Tier 2 response time planning standards Minimisation of environmental impact (ie considering locating at pump stations when practical)

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 37

General Oil Spill Response Plan

BTC Project

· · · ·

Assessment of road conditions Expected weather conditions throughout the year Security issues Relative sensitivities and risks along the pipeline

An overview of the process is set out in the Case Study below. Work undertaken subsequent to the assessment described in the Case study confirms that BTC and its Oil Spill Response Contractor will, in most weather conditions, be able to respond to the more environmental sensitive / high risk areas well within the draft response time planning guidelines described above. These response time planning standards are comparable to other projects considered as part of the Benchmarking exercise and in comparison to 49 CFR. Specifically 49 CFR requires an operator to identify the necessary resources to be able to respond to a Tier 2 incident within 36 hours (or for a high (traffic) volume area within 30 hours). 6.7 Tier 3 (Crisis Event):

Tier 3 incidents include very large, possibly ongoing spills, which will require additional resources from outside the country of spill origin. Such spills could occur as a result of events such as full diameter pipe rupture or an uncontrolled tank failure. Response operation will utilise all of BTC Co.'s available in-country Tier 2 resources, augmented by additional assets from outside the country. Extensive support from the IMT will be needed. To assist in determination of the appropriate response resources in Georgia spills associated with a full bore rupture are being considered as a "Tier 3" spill. At Ceyhan a Tier 3 event may occur should a vessel impact with the Jetty or a major earthquake causes rupture or overtopping of an onshore storage tank. 6.7.1 Tier 3 Spill Volume Planning Guidelines

The ERA provides detailed information on the range of spills that could occur in excess of the Tier 2 spill sizes described above. Tier 3 spill volumes range from 2000 m3 up to a maximum spill size as follows: · · · In Azerbaijan (pipeline) - 25,000 m3 In Georgia (pipeline) - 18,000 m3 In Turkey (Ceyhan) - 100,000 m3

An example of the spill volumes derived from the ERA for Azerbaijan and Georgia are provided in Appendix H. It is recognised that there could be a large spill, up to 140,000 m3, from a ship operating outside of BTC area of responsibility. BTC Co and BIL will ensure the relevant authorities are aware of such eventualities and would be available to assist should such an event occur.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 38

General Oil Spill Response Plan

BTC Project

6.7.2

Tier 3 Response Time Planning Guidelines

An internationally recognised Tier 3 contractor will be contracted to provide a standby service prior to pipeline linefill. Response time planning guidelines will be developed with this contractor with due regard to international norms and in particular 49 CFR which requires a Tier 3 response time of 60 hours. Most of the Tier 3 response resources would likely originate from the OSRL base in Southhampton or alternatively from Singapore. OSRL publish 1 indicative Aviation Response times for a Hercules as: · · · Repositioning = 2 hours Loading approximately 1.5 hours Flight time from Southampton to Baku = 20.7 hours

BTC, BOTAS and BIL are also seeking to establish the necessary protocols with customs in each country to facilitate fast clearance of equipment arriving by plane. 6.8 Safety Standards

Public and employee safety must be balanced against potential reductions in environmental damage associated with spills. Issues to be considered in the development of tactical response plans include the following: Safety factors including speed limits, driving at night, fire and explosion hazard, toxicity issues (oil contact/inhalation/ingestion), and work in hazardous environments, such as fast flowing rivers and steep terrain. Environmental conditions which can influence logistics including inclement weather, hazardous (steep) terrain, and condition of roads and bridges. Security issues, including incidents, which may involve no-go zones or may have been caused intentionally. Particular attention will be paid to events resulting from potential sabotage, as residual and/or secondary hazards may be present. BTC Co. safety procedures will require completion of a Safety Risk Assessment as part of the mobilisation to a response.

1 (OSRL ­ EARL alliance yearbook 2002)1

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 39

General Oil Spill Response Plan

BTC Project

Case Study - Location of Oil Spill Response Equipment in Georgia

BTC Co. have employed international consultants to assist the OSR team in determining appropriate planning standards. Having determined the planning standards the locations and capacities of oil spill response equipment are being determined. On the basis of the estimated response times and spill volumes determined as part of the ERA process BTC Co. has ascertained that establishment of a single base in the vicinity of Tbilisi would be sufficient to enable the response contractor to meet the planning standards during "normal" weather conditions. The contractor's ability to meet these standards is considered realistic, as most containment sites are located in areas below the snow line or in areas where the roads are generally kept open by the local authorities even during winter. Data collected during development of the containment manuals confirms that, under daylight, clear weather and clear road conditions, travel times from Tbilisi to containment sites in Borjomi or Tsalka are typically 3 ½ hours. BTC has reviewed the environmental data and refined the risk assessment on this basis to assist in determination of locations for storage of oil spill equipment. Figure CS1 provides an overview of the relative risks to which important receptors are exposed. Figure CS1 Comparative Risks at Important Receptors

Average Borjomi Ktsia River - Upper Reaches including wetlands Tbatskuri Ktsia River - Lower Reaches Tsalka Lake Tetritskaro Forest Marnuli Rustavi Jandari

0 20,000 40,000 60,000 80,000 100,000

As described in the ERA and OSR framework documents, BTC Co seeks to ensure any response planning is undertaken with the intent of ensuring response times are reduced in areas having a comparatively higher risk. On this basis and in accordance with the requirements of the ESIA conditions it is proposed that equipment and staff be located in the following locations: Location Tbilisi Tsalka Borjomi Reason Oil Spill Response base to support BTC and WREP Established in recognition of the sensitivity of Tsalka Lake, Naris Veli Wetland, Lake Tabatskuri and Ktsia River Established in accordance with the ESIA consent conditions and in recognition of the sensitivity of the Borjomola Gorge and Kura River

A benchmarking exercise undertaken as part of the BP peer assist process suggests that establishment of 3 bases in Georgia goes well beyond normal operating practice. It is however understood that such a precedent is warranted given the particularly challenging topography and weather coupled with the highly sensitive nature of the environment.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 40

General Oil Spill Response Plan

BTC Project

6.9

Locations for Storage of Equipment

Equipment, resources and personnel will be stockpiled at locations along the pipeline as necessary to meet Response Time Planning Guidelines as previously described. Table 6.2 Preliminary Assessment of Locations for Tier 1 and 2 Response Equipment

Country Location OSR Equipment for Offshore and Coastal Clean-up OSR Equipment Onshore Facilities for Spills from

Azerbaijan

Baku Sangachal

BTC PS A2

Georgia

BTC PS G1 Tbilisi Base

BTC PS G2 Tsalka Base Borjomi Base Supsa

/ Offshore and Coastal clean-up WREP equipment augmented with equipment as part of the ACG equipment for BTC and SCP as response capabilities determined from assessment of response times and risks WREP equipment from PS 5 and PS 8 augmented with equipment for BTC and SCP as determined from assessment of response times and risks Tier 1 equipment Equipment for WREP, BTC and SCP as determined from assessment of response times and risks Tier 1 equipment Equipment for BTC and SCP as determined from assessment of response times and risks Offshore and Coastal clean-up WREP equipment equipment as part of the WREP response capabilities Equipment for BTC as determined from assessment of response times and risks

Turkey

BTC PS T1 BTC PS T2 BTC PS T3 BTC PS T4 Ceyhan

-BTC specific Offshore and Coastal clean-up equipment - Offshore equipment associated with existing facilities

The terrain and other environmental factors in the area of the pipeline will require that strategies for containing a spill take advantage of natural barriers and man-made structures constructed at the time of a spill. As such, construction equipment will form a large part of the response resources for the pipeline. Water bodies that may be affected by a spill will still rely on traditional oil spill response and containment equipment such as containment booms or barriers. 6.10 Equipment BTC and BOTAS have engaged a number of specialists to assist in development of the various documents and in determination of appropriate equipment requirements. The teams will establish an equipment selection methodology that is transparent and

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 41

General Oil Spill Response Plan

BTC Project

that draws on information collected as part of the ESIA, ERA and containment manual development process. In addition information from the Oil analysis has been considered with due regard for the variation in environmental conditions along the pipeline. A detailed discussion of the oil properties and implication in equipment selection is included in Appendix E. 6.10.1 Equipment for Inland Response An overland spill modeling study has been undertaken and this provides BTC and its contractors with background information on the likely fate of oil, and associated volumes that may reach a given containment site. Figure 6.2 provides an example of the outputs from this assessment. Figure 6.2 Example of Output from Overland Flow Modeling

KP191 - Volume Balance

100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Leakage From Pipe Leakage Retained Infiltration During in Pipeline Trench Overland Flow Vegetation Storage Overland Flow Evaporation Overland & River Stored On River Banks Infiltrated/ Retarded On River Banks Volume Outflow in River

Table 6.3 summarizes the basis of the equipment selection in Azerbaijan and Georgia. BTC Co is working with BOTAS and BIL to establish a similar basis for selection of equipment along the pipeline in Turkey.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 42

General Oil Spill Response Plan

BTC Project

Table 6.3 Example of Assumptions used in Determining Equipment Requirements at Containment Sites ­ Azerbaijan and Georgia

Factor Design Spill Volume Losses Prior to Entering Watercourse Losses Through Evaporation Losses in River to Banks etc Capacity at each containment site Number of containment sites downstream of any given point on the pipeline Skimmer Derating Unit `m3 % % % % No Basis "most likely" spill 25 8 8 50 2 Reference ERA as described above Overland Flow Modeling Overland Flow Modeling Overland Flow Modeling Design Assumption Design Assumption Corbett and Holt on basis of US coast guard and industry best practice

%

25

Equipment lists will be provided in the Final country specific OSRP's and will include but not be limited to: · · · · · · · · · · · · · · · · Personal Protective equipment Safety devices (gas detectors etc) Communications equipment Mapping (as included in Containment Manuals) Geographical Positioning systems (GPS) Booming Systems Barrier systems (such as fencing systems for containment on land) Oil Skimmer systems Pump Systems Temporary Storage systems Vehicles Boats All terrain vehicles (for Georgia and Turkey as required) Decontamination systems for people and clothing Solid waste management systems (skips, plastic bags etc) Shovels, gloves and other "consumables"

6.10.2 Equipment Selection for Ceyhan In determination of equipment requirements for the marine environment BOTAS is considering data from the risk assessments in the context of international best practice. A platform for deploying equipment and collecting oil in the offshore environment is necessary. Two possible configurations are being considered: (1) a sweeper arm system based on a tugboat, and (2) collection from a towed boom/skimmer system.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 43

General Oil Spill Response Plan

BTC Project

Collected oil will be stored temporarily at sea in floating bladders towed behind tugboats or alternatively in small barges. Oily water will be transported back to the BOTAS terminal for storage and treatment at the oily water treatment plant. There are a number of highly sensitive areas in the Iskenderun Gulf in which area specific protection methods are being developed as part of the coastal sensitivity and containment manual development. Areas in which site specific strategies and associated equipment requirements will be determined include: · · · · · · · · Yumurtalik Lagoon Yurmurtalik Port Tuzla Inlet Akyatan Inlet Karata Port Agyatan Inlet Arsuz Çiftlik Port

6.10.2.1 Dispersants Dispersants act to generate oil droplets that are incorporated into the water column and made more available for microbial degradation. Wave action is needed to generate sufficient mixing of the dispersed oil into the water column. Dispersant is more effective on non-weathered oil. Whilst mechanical methods are preferred over the use of dispersants BOTAS is considering the storage of dispersants as a back up method of environmental protection. BP, BIL and BOTAS are currently engaged with the regulators in each of the host countries to address the various environmental and technical and reputation aspects associated with dispersant use. The sponsors are seeking to develop protocols with the relevant regulators setting out the process for gaining approval to use dispersants in the event of a spill. 6.10.2.2 Equipment Lists Equipment lists will be provided in the Final Marine OSRP for Ceyhan Terminal. These equipment lists will include but not be limited to: · · Response Boats Booms o Ocean (reel pack) o Fast-current recov boom o Nearshore o Harbor/river o Fire boom Skimmers Storage o On-Water Bladder o Temp.On-Land

· ·

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 44

General Oil Spill Response Plan

BTC Project

·

· · ·

Sorbents o Sausage boom o Pads o Sheets Tug Crane / modification o Skimmer Arm o Pumps Mapping (as included in Containment Manuals) Geographical Positioning systems (GPS)

6.11 Equipment Maintenance BTC Co. will establish a program of inspection, testing and maintenance for its oil spill response resources to ensure that all such resources are operational. This program will be applied to all oil spill response equipment owned and operated by BTC Co. and its oil spill response contractors. 6.12 Sharing of Oil Spill Equipment BTC Co. will also explore establishing Mutual Aid Agreements for sharing of spill response resources and perhaps training with other BP operations including WREP, NREP, and SCP. Resource sharing allows each participant access to a greater resource pool. It can also allow for a more efficient and cost-effective response, and in many cases, response actions are similar for adjacent pipeline operations. Under any Mutual Aid concept adopted, BTC Co. would maintain a complete initial tactical response capability (on scene management and resources) and gain access to additional resources from adjacent operators.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 45

General Oil Spill Response Plan

BTC Project

7

WASTE MANAGEMENT

BTC will build and operate the project, complying with the intent of EU legislation, to ensure wastes are managed according to five key principles: · · · · · Waste Management Hierarchy. ­ reduce, reuse, recycle or render harmless Self-Sufficiency at Community and, if possible, at Member State level . Use Best Available Technique Not Entailing Excessive Cost (BATNEEC). Proximity. (Wastes should be disposed of as close to the source as possible). Producer Responsibility

A particular focus is being given to minimization of hazardous wastes generated as part of normal and abnormal operations with wastes being categorized as follows: "Inert" Waste: as defined in Article 2 of EC Directive 1999/31/EEC which, in summary, is waste that does not undergo any significant physical or chemical or biological transformations. Inert waste will not dissolve, burn or otherwise physically or chemically react, biodegrade or adversely affect other matter with which it comes into contact in a way likely to give rise to environmental pollution or harm human health. The total leachability and pollutant content of the waste and the ecotoxicity of the leachate must be insignificant and, in particular, not endanger the quality of surface water and/or groundwater. "Hazardous" Waste: means any solid or liquid waste covered by Article 1 (4) of EC Directive 91/689, which has the following potential properties: "explosive", oxidizing, highly flammable or flammable, irritant, toxic, carcinogenic, corrosive, infectious, teratogenic, mutagenic; substances which release toxic or very toxic gases in contact with air, water or acid; substances which are capable after disposal of producing another substance, and ecotoxic substances. "Non-hazardous" Waste: Waste that is neither inert, not hazardous, nor wastewater. It includes municipal waste as defined in the Landfill Directive 1999/31/EEC. "Waste water": Freshwater that is contaminated as a result of project activities. 7.1 Solid Waste Management

BTC and BIL are currently developing solid waste management plans and the associated infrastructure to ensure wastes can be managed in accordance with European Legislation. Facilities that will be available will include incinerators and landfill sites. BTC is currently reviewing the options for bio remediation as this is considered preferable to landfill disposal for some wastes including contaminated soils. Additionally BTC is working to establish environmental management systems which will address waste management issues for normal and abnormal events including oil spills.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 46

General Oil Spill Response Plan

BTC Project

7.2

Decanting

The process of recovering oil from water will generate significant quantities of water. Temporary storage of recovered oil / water mixtures presents one of the major challenges to an effective spill response. BTC Co. has undertaken to consult with the relevant Environmental Ministries in each Country with the intent of developing protocols setting out the conditions under which decanting of recovered mixtures will be acceptable. Wastewater will be treated in accordance with best international practice. To achieve this, it is necessary to ensure appropriate equipment including decanting devices are deployed as part of the first response. BTC Co will use the Net Environmental Benefit Approach, described elsewhere in this document, in defining first response equipment lists. 7.3 Draft Waste Management Plan

A waste management plan specific to Oil Spill response has been prepared as part of the oil spill response planning process and this is included as Appendix C.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 47

General Oil Spill Response Plan

BTC Project

8

COMMUNICATIONS

This section describes the communication that will be undertaken in the event of a spill and the systems that will be established to facilitate such communications. 8.1 Communications in the Event of a spill

Each country specific OSRP will include contact details for key individuals, organisation and government agencies that may need to be informed in the event of a spill. Communications will be managed by the incident commander in accordance with the IMS Manual which sets out: the organisations, titles of the individuals, contact details and the types of incidents in which they would normally be notified. Prioritisation for calling individuals has been established using R-1, R-2 and I nomenclature as follows: · · · R-1 requires immediate notification following confirmation of incident along with continuous updating. R-2 Requires notification on next working day along with updating as appropriate. Information only within 24hrs or next working day.

BTC and BIL will work with relevant authorities to ensure an appropriate and integrated response to an event. As BP and BIL will be managing a significant amount of the oil spill response capability in host countries, BP will in most instances retain control of managing the response activities. In the event of a spill that could potentially affect neighbouring countries, BP and BIL will work with host Governments to ensure effective communication with appropriate organisations and individuals in potential affected neighbouring countries. BP has established relationships with many oil spill practitioners and policy makers in the region through its involvement in regional forums and working groups. If deemed appropriate BP and BIL will, in the event of a spill, notify individuals and organisations in neighbouring countries or riparian states directly. Regional initiatives and conventions that assist BP make informed decisions regarding communications with potentially effected countries include: · · Convention on the Protection of the Black Sea against Pollution (Bucharest, 1994); Convention for the Protection of the Mediterranean Sea against Pollution, 1976 (the Barcelona Convention). The Barcelona Convention and Protocol have been developed as mechanisms through which the members undertake to use their best endeavors to provide each other with assistance in the event of a oil spill incident in the geographic areas covered by the agreement. Protocol Concerning Cooperation in Combating Pollution of the Mediterranean Sea by Oil and Other Harmful Substances in Cases of Emergencies Mediterranean Oil Industry Group (MOIG). The International Petroleum Industry Environmental Conservation Association (IPIECA), comprising petroleum companies and associations around the world, established the Mediterranean Oil Industry Group (MOIG) as the means for providing a regional

· ·

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 48

General Oil Spill Response Plan

BTC Project

·

oil industry forum on oil spill preparedness and response for the Mediterranean Region. It provides a regional industry interface with Regional Marine Pollution Emergency Response Centre for the Mediterranean Sea (REMPEC). BP and other BTC partners are key members of both IPIECA and MOIG. Oil Spill Preparedness Regional Initiative (Caspian Sea ­ Black Sea ­ Central Eurasia) (OSPRI). BP is a member of an industry lead initiative on oil spill response related issues for the Caspian and Black Sea "region". Communications Systems

8.2

BTC has developed a reliable emergency response communications system to link its command centers with all field operations. This system utilizes mobile telephones and VHF radio with satellite telephones as a backup. 8.2.1 Emergency Communications Network Tactical communications are the responsibility of the Incident Commander and the Communications Unit Leader, set up on a case­by-case basis. This communications center will provide communications links necessary to support the BTC response to any spill incident and will be located either in the country that the incident has occurred or at the pre-designated IMT Incident Management Center (IMC), Room 187, Villa Petrolea, Baku Office, depending on the size and severity of the incident. In the event of a large incident, a local (in-country) satellite communications center may be established. Features of the BTC Communications Network include: · Command Center Communications Room. The location and telephone number(s) of the Communications Room will be assigned at the time of the incident. While the Communications Center's primary function will be operational communications, it can be set-up to accept and refer incoming media and public relations calls to the appropriate section for processing. Mobile Telephones and/or Paging Equipment. BTC personnel and contractors assigned to media / public relations duties during an incident will be issued mobile telephones and / or pagers. Tactical / Logistical Communications

·

8.2.2

In developing equipment schedules the following communications systems are being considered: · Terrestrial Telephones. Staff working from offices will utilize the terrestrial telephone networks currently in place. Those working in offices within or adjacent to the pump stations and other above ground facilities may be able to communicate by telephone linked into the fibre optic system that runs along the length of the pipeline. · GSM. The main form of communication from vehicles and staff in the field will be in from GSM mobile phones. In those areas where GSM coverage is not available, VHF or satellite phones will be used. · There are several service providers and associated networks in the host countries. To ensure effective communications even when across borders, several sets of telephones with international roaming and pre-entered international codes will be available. · VHF. Every emergency response vehicle will be equipped with a handheld VHF radio (5 watt).

AGT000-0000-OP-PLN-00004 ­Rev A2 Page 49

General Oil Spill Response Plan

BTC Project

· Satellite Phone. For team stationed or likely to operate in remote locations satellite phones will be provided for use in the event that GSM coverage is not available in the area of operation. Key numbers will be entered into the phones by the Communications Unit.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 50

General Oil Spill Response Plan

BTC Project

9

CONSULTATION

A considerable amount of consultation has been undertaken across the BTC host countries as part of the E(S)IA process. Consultation is continuing as part of the land acquisition and construction process. Oil Spill issues have been discussed at length during this consultation and therefore most potentially effected parties have a reasonable understanding of the BTC project and the risks inherent in operating an oil transportation system. Further consultation specific to oil spill response planning is now being undertaken as set out below. 9.1 Consultation with Communities

As described above a considerable amount of consultation has been undertaken during the ESIA process and this is ongoing during construction. In development of a consultation programme with potentially effected villages due regard will be made to the comparative risks to villages along the pipeline and in the Iskenderun Gulf. Appendix A provides some insights as to how the risk data can be used to assist in determining who should be consulted on oil spill issues. BTC Co proposes to undertake additional consultation in areas of particularly high sensitivity or where the communities have shown considerable interest or concerns regarding oil spill related issues, notably communities in the Iskenderun Gulf and in the Borjomi region. In addition BTC Co plans to undertake consultation in villages where oil spill response bases are to be built. Such stand-alone facilities are only envisaged in Georgia and will be constructed in Borjomi and Tsalka. Consultation in these towns will be undertaken in association with the ESIA and Government and Public affairs (GPA) departments within BTC Co. 9.2 Establishing Links with Local Contractors

An important part of the oil spill response planning process is the formation of linkages with locally based contractors. These organisations will be needed to support the Oil Spill Response contract during exercises or in the (unlikely) event of a spill. Briggs Marine, who have been awarded the contract to provide oil spill response standby for BTC in Azerbaijan and Georgia, will be commencing discussions with local contractors as the facilities and resources are established in Azerbaijan and Georgia. A significant number of potential contractors were identified during the ESIA process in Turkey and additional dialogue will be undertaken as BOTASIL establishes its Oil Spill Resources in Turkey. 9.3 Consultation in developing Response Strategies

BTC CO.and BIL have engaged industry experts to assist in development of appropriate response strategies. In developing such strategies for the marine environmental the methodologies developed by Gundlack and Hayes are being used. These methods provide responders with an internationally recognised method for prioritisation of response activities. Additionally the Country Specific OSRP will include decision guides that assist responders in making informed decisions. Notwithstanding this approach BTC CO.and BIL are seeking to engage relevant

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 51

General Oil Spill Response Plan

BTC Project

individuals and organisations in understanding how best to ensure specific receptors could be protected in the event of a spill. In refining the OSRP for the marine environment BP and BIL will engage with potentially affected parties in "identifying priorities in response with input from potentially affected or concerned parties" (International Finance Corporation Oil and Gas Development (Offshore)). 9.4 Involving the Community in Response Exercises

BTC Co is seeking to establish a mechanism of dialogue with communities that does not invoke undue concern about the risk of an oil spill. Involvement of the communities in response exercises is seen as a good mechanism for establishing a dialogue with community leaders and individuals that may be able to assist during an actual event. A program of exercises in each country is being developed as part of the country specific oil spill planning process. 9.5 Consultation with Host Government Agencies

The HGA for each country is a key document setting out the obligations of the BTC CO.partners and the Government within each respective country. Whilst the HGA for each country differs slightly, each contains words relating to the OSRP similar to the following: "Prior to the completion of the Facilities and in relation to Pipeline Activities, a plan for Petroleum spill response capability ("Spill Response Plan") as to spills within or that could affect the Territory will be created and implemented by the MEP (Main Export Pipeline) Participants. The Spill Response Plan will include: (i) (ii) (iii) (iv) Environmental mapping of habitats vulnerable to potential petroleum spills in the entire MEP system; Situational scenarios of potential spillages and responses, taking into consideration local circumstances; Plans for the provision of relevant Petroleum spill clean-up equipment, materials and services; Plans for the deployment of relevant equipment and emergency response notification details of the organisation required to handle Petroleum spill response; and Plans for the treatment and disposal of resulting contaminated materials."

(v)

BTC Co is developing the OSRP in accordance with BP policies and generally in accordance with the ICS system. In this context the information stipulated in the HGA's will be provided in different documents as described in Table 9.1.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 52

General Oil Spill Response Plan

BTC Project

Table 9.1 Mapping HGA Requirements to the Oil Spill Planning Documents HGA Requirement Environmental mapping of habitats vulnerable to potential petroleum spills in the entire MEP system; Situational scenarios of potential spillages and responses, taking into consideration local circumstances; Plans for the provision of relevant Petroleum spill clean-up equipment, materials and services; To be Described in Coastal sensitivity and Containment Manuals with overview in the OSRP These will be included in the OSRP

The approach to be adopted in selection of oil spill response equipment will be discussed in the strategy documents developed for each country.

Plans for equipment notification required to and Plans for the treatment and disposal of Waste management plans will be included resulting contaminated materials." in the OSRP In addition to the HGA requirements a number of conditions have been imposed on BTC Co as part of the ESIA consenting process. These ESIA conditions are being addressed at a country level and will be described in the country specific OSRP's and associated documents. BTC Co plans to issue the country specific OSR documents well before commencement of pipeline operations. BTC Co is adopting a pro-active approach to consultation with the regulatory bodies in each country in advance of issuing any documents and plans to continue with this dialogue up to and beyond commencement of pipeline operations. 9.6 Consultation outside Azerbaijan, Georgia & Turkey

The final list of equipment will be included in the final Country Specific OSRP's. the deployment of relevant Coastal sensitivity and Containment and emergency response Manuals describe the plans for details of the organisation deployment of equipment. handle Petroleum spill response;

The UNECE Convention on Environmental Impact Assessment in a Transboundary Context (ESPOO Convention) was signed in Sept 1991. The convention places a general obligation on signatory states to notify and consult each other on all major projects under consideration that are likely to have a significant adverse environmental impact across boundaries. Whilst the onus to undertake consultation within the context of ESPOO fall on those host governments that have ratified the convention BTC Co is working with the EBRD and the government agencies to assist all parties in meeting obligations under the convention.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 53

General Oil Spill Response Plan

BTC Project

A more detailed discussion of BTC in the context of ESPOO is provided in Attachment A. 9.7 Consultation with Lender Groups

Progress on development of the various plans has been communicated to the various lender groups on a regular basis and this dialogue is ongoing. BTC Co has agreed to have the OSRP's ready for review by the lender group 150 days prior to linefill. BTC Co is also seeking to engage the Lender's consultants in earlier dialogue.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 54

General Oil Spill Response Plan

BTC Project

10 STRATEGIC AND TACTICAL INITIATIVES BTC Co. will adopt a proactive approach to Oil Spill Response Planning with Host Governments and other operators. Many issues that arise during the response to a significant oil spill can be anticipated, planned for and described in documents. BTC Co. will work with appropriate agencies and other operators toward development of formal and/or informal agreements and understandings regarding spill response issues including: 10.1 Transboundary events Situations exist in which spills originating in one country may migrate into adjacent countries. Expedited notification procedures will be included in each OSRP. In addition, expediency may dictate sharing of resources across boundaries. BP has established protocols to expedite movement of equipment across the Azeri / Georgian border in the event of an incident. These protocols will be reviewed and updated to ensure any BTC specific aspects are incorporated into the protocols. BTC CO.is seeking the Georgian Governments support in establishment of similar protocols for transfer of equipment across the Georgian / Turkish border. 10.2 Cleanup levels Criteria for determining acceptable levels of cleanup will be developed prior to emergency need. BTC Co. has undertaken to consult with relevant ministries from the host countries to develop pre-spill criteria and /or target cleanup levels in the unlikely event of releases into areas of varying environmental / social sensitivity. The agreed methodology, criteria and, where appropriate, cleanup levels will be included in the final Country Specific OSRPs. As a precursor to these discussions BTC Co has agreed on the following wording in the Construction ESAP: "BTC Co.'s OSRPs will ensure oil spill containment and protection of key receptors in accordance with the international standards (which are listed in the ESAP) following the principles of risk based corrective action. BTC Co. will remediate any oil spill as required under applicable law and in accordance with good international practice in order, so far as is practicable, to restore the Environment affected by the oil spill to its baseline condition." A number of risk based corrective action methodologies have been developed in different countries and these will be considered as part of the assessment and consultation process. Examples of risk based methodologies include those described in ASTM standards and in the UK Environmental Agencies (EA) "Methodology for the Derivation of Remedial Targets for Soil and Groundwater to Protect Water Resources" (publication Number 20 October 1999). The UK EA approach has been adopted for the construction phase of BTC in Turkey and will be described as the "base case" methodology in discussions with the regulators in each country. This methodology uses a Tiered approach as follows: · · Tier 1 assessment sets out a remediation target concentration equal to the receptor target concentration Tier 2 multiplies the receptor target concentration by a dilution factor

Page 55

AGT000-0000-OP-PLN-00004 ­Rev A2

General Oil Spill Response Plan

BTC Project

· ·

Tier 3 multiplies the receptor target concentration by a dilution factor and an attenuation factor (derived by analytical means) Tier 4 multiplies the receptor target concentration by a dilution factor and an attenuation factor, derived by more complex numerical modeling techniques

Having an understanding of the environmental conditions, and particularly the groundwater quality, prior to a spill can be very beneficial in undertaken such risk assessments. Groundwater quality data has been gathered as part of the ESIA process and further monitoring will be undertaken during construction and operations. This data will be captured in a manner to be described in the Operations ESMS currently being developed by BTC CO.and will be available to those undertaking any risk assessments such as those described above. This data will also assist in determination of the target water quality that should be achieved through remediation of the soil and / or groundwater. In the particular case of drinking water being sourced from an potentially affected aquifer, and the ERA process suggests a cleanup is necessary, consideration of the baseline water quality data and international standards such as those developed by the EU and WHO will considered in designing the cleanup effort. Such risk based approaches have primarily been developed to assist in determining in contaminated land cleanup strategies. The approach is not however as relevant when considering cleanup levels in streams and other surface water features and for sensitive flora and fauna. For surface water intakes and other sensitive downstream receptors a simpler methodology will be considered. In such instances BTC CO.will seek to develop water quality limits that will be used to assist in determination of the cleanup strategy and against which the efficacy of any cleanup will be measured. Such predetermined water quality levels would be defined at the receptor. Risk base methodologies that consider impacts to Flora and Fauna are in their infancy however the UK EA has developed an approach and issued a draft on the internet for comment. BTC CO.will consider such methods and will also discus the possible application of these methods with the relevant regulators. 10.3 Importation of equipment In the unlikely event of a Tier 3 oil spill, it will be necessary to import additional response resources. These resources must be delivered to the spill scene as expeditiously as possible. Predetermining clearances and customs procedures and identifying ports of entry and holding/staging areas can expedite import of emergency resources. BTC Co. has undertaken to consult with the relevant ministries in the Host countries with the intent of establishing expedited procedures for importation of spill response resources. 10.4 Disposal options BTC Co. will assign highest priority to recycling of recovered materials. Typical forms of recycling of recovered oil spill materials include direct recovery, use as power plant fuel and use as road base. BTC Co. will work with regulatory agencies in development, pre operations, of acceptability criteria for various forms of recycling. In the event recovered materials cannot be recycled, BTC Co. will seek to

Page 56

AGT000-0000-OP-PLN-00004 ­Rev A2

General Oil Spill Response Plan

BTC Project

treat contaminated soil and plant matter using natural processes such as bio remediation. Any wastes unable to be recycled or bio remediated will be disposed of in accordance with the Host Government Agreement and BTC Co. environmental standards. 10.5 Drinking Water Supplies As part of the containment manual development process BTC Co and BOTAS are collecting information on surface water extraction facilities on rivers and streams potentially affected by an oil spill. As part of the ongoing discussions with the ECA Environmental Sub Group BTC Co has agreed the following wording for inclusion in the final Environmental and Social Action Plan for construction (ESAP): "The Country-Specific OSRPs will also include identification of significant drinking water sources that could potentially be impacted by an oil spill and establish procedures for provision of alternative emergency water supplies where significant drinking water sources are affected within 4 days of the relevant oil spill." 10.6 Wildlife Care BTC Co. will develop procedures for capture, treatment and care of wildlife exposed to oiling. In addition, BTC Co. is working with the Azerbaijan Business Unit to determine an appropriate wildlife care facility to service the business units area of operations. It is envisaged that a facility will be established in Azerbaijan in collaboration with Azeri scientists. In addition equipment will be provided in each country and may include: · · · · · · · · · · · · Long-handled nets Wildlife boxes (RSPCA design) Cotton wool swabs Plastic syringes Thermometers Ophthalmic ointment Barrier cream Detergent Disinfectant Milton solution Scales Poultry rings

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 57

General Oil Spill Response Plan

BTC Project

11 PROGRAMME A preliminary schedule for establishment of oil spill response capabilities for the BTC Project was set out in the Framework OSRP. Ongoing liaison between BTC Co., the lender group, and regulatory authorities and between BTC Co, BOTAS and BIL has resulted in some changes to the programme. A summary of the planned delivery dates is outlined in Table 11.1. Table 11.1 Programme of Key Activities for Oil Spill Response Planning Element General OSRP Draft Country ­Specific Oil Spill Response Plans: Azerbaijan Georgia Ceyhan Terminal Turkey Containment Manuals Procure Equipment Training Government Approval Expert Review Date Prior Close

to

Financial

Oil Spill Response Exercises Full Oil Spill Response Capability in Place 11.1 Updating the OSRP

1Q 2004 1Q 2004 1Q 2004 1Q 2004 1 Q 2004 Commences 1 Q 2004 Commences 3 Q 2004 3 Q 2004 Commences at least 120 Days Prior to Linefill Prior to Linefill and ongoing therafter Prior to Linefill

BP updates the Incident Management System Manual on an annual basis. BTC CO.and BIL are planning to update the country specific OSRPs on an annual basis also. Any significant changes to the system operation or the environmental or social environment in which BTC CO.operates would also trigger an update of the IMS and OSRPs. The Containment Manuals are being developed in a manner that facilitates a simple updating of sections of the manuals and the revision of the manuals will be ongoing and undertaken by the OSR contractor. The Containment Manuals will be reviewed by BTC CO.on an annual basis. This GOSRP will be updated should the asset base, to which it applies, change significantly.

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 58

General Oil Spill Response Plan

BTC Project

Appendices

A ­ ESPOO Consultation B ­ Table of Contents ­ Country Specific OSRP C ­ Draft Waste Management Plan D ­ Environmental and Social Sensitivities Example ­ Georgia E ­ Oil Properties Discussion F ­ Behaviour of Oil in various Onshore Environments G ­ Example Output from the containment Manual Database H ­ Spill Volume Estimates I ­ Examples of Decision Guides

AGT000-0000-OP-PLN-00004 ­Rev A2

Page 59

Information

59 pages

Report File (DMCA)

Our content is added by our users. We aim to remove reported files within 1 working day. Please use this link to notify us:

Report this file as copyright or inappropriate

30187