Environmental and Social Assessment and Management System. As the operator of the OCTP block and on behalf of the partner group, Eni Ghana has developed two Environmental, Social and Health Impact Assessment (ESHIA) studies, the findings of which constitute the two Environmental Impact Statements (EIS) required by Ghana EPA for Phase-1 and Phase-2 developments. OCTP Phase-1 and Phase-2 developments were submitted for registration with the EPA in September 2013 and December 2014, respectively. Scoping Reports, included Terms of Reference (ToR), were compiled as part of the ESHIA process in accordance with the regulatory requirements stipulated in Regulation 11 of the Environmental Assessment Regulations (1999). 

The OCTP Block Phase-1 ESHIA was submitted to the EPA on 26th January 2015 and approved on 9th July 2015. The scoping report for OCTP Block Phase-2 ESHIA was submitted to EPA on 30th December 2014 while the OCTP Block Phase-2 ESHIA was issued on 19th March 2015 and approved on 24th July 2015. Both ESHIAs were disclosed by IFC on 23rd March 2015 under the early disclosure procedures outlined in IFC’s and MIGA’s Access to Information Policy, and can be found at ifcextapps.ifc.org/IFCExt/spiwebsite1.nsf/0/60279DBD070E6EB685257E110060FFEE?opendocument. The ESHIAs have been developed consistent with Eni S.p.A’s, Eni Ghana’s parent company, corporate standard which is aligned with international best practice, based on a set of environmental, fisheries, socio-economic and health baselines and on the outcomes of stakeholder consultation. The ESHIAs meet the requirements of the Performance Standards. Quantitative studies were carried out involving numerical modelling of project emissions to atmosphere and noise at the ORF during operations, underwater noise levels, quantification of project discharges, including cutting discharge and deposition modelling, and modelling of oil spill scenarios.  

The public review and public hearing, part of the ESHIA process, took place from March to May 2015.  In accordance with Ghanaian regulations, a series of Public Hearings were conducted integrating ESHIAs of both phases in the capital city of the Western Region Sekondi-Takoradi and in the community of Sanzule, where the ORF will be constructed.  The final Phase-2 ESHIA was issued in July 2015.  The EPA issued environmental permits for the drilling and development of wells; installation and commissioning of infrastructure of Phase 1, and construction, installation and commissioning of Phase 2 on June 8, July 9 and July 24 2015 respectively.  ESHIAs are available in relevant government offices and public places in the project region (such as the Western Regional library) and non-technical summaries were distributed in the Area of Direct Influence of the project.  The final OCTP Block Phase-2 ESHIA is disclosed as part of the documentation attached to this ESRS.

Drilling operations, laying of the subsea pipeline, installing the beach crossing of the pipeline at the landfall, installing the pipeline from the beach to the ORF, and clearing the locations for the ORF, base camp and helipad (to be used only in case of medical evacuation) are the main sources of potential environmental impact during construction. 

During operation, the most significant event that could affect the marine and coastal environments is a crude oil spill from the FPSO, which handles oil and associated gas from the oil field development as well as non-associated gas from the gas field development, or from the rupture of a flow line from an oil well to the FPSO. Accidental events assessed involve a blowout from an oil well or a gas well, gas leaks, fire or explosion at the FPSO or the ORF or its pipelines. Management of drilling wastes and cuttings, solid waste and hazardous waste, air emissions and noise are measures addressed in the ESHIAs. Risks and impacts identified and relevant mitigation and management measures are described in the relevant sections that follow.

At the corporate level, Eni S.p.A has well-established HSE, Sustainability and Human Resources Policies approved by its Board of Directors and applicable to all operations of the group, its subsidiaries and to its contractors and subcontractors. The Eni HSE IMS is based on a comprehensive set of MSG which cover, among others, HSE management and risk management, energy efficiency, greenhouse gas (GHG) accounting and reporting, environmental monitoring, soil remediation and recovery, water resources management, biodiversity and ecosystems, waste management, health surveillance, stakeholders engagement and community relations, third party monitoring, and crisis and emergency plans. The IMS has been developed and is implemented in accordance with ISO 14001 Environmental Management System and OHSAS 18001 Occupational Health and Safety Management.  

Eni Ghana’s management system mirrors the corporate IMS and the company has obtained the relevant ISO and OHSAS certifications. The IMS applies to all activities performed by or on behalf of Eni Ghana, including those undertaken in Ghana and contractors’ work locations overseas. As described below, consistent with the ESHIA commitment, a number of project-specific detailed management plans and programs will be developed. 

Vitol E&P’s HSE Policy includes commitment to achieve the highest standards in health, safety, environmental and community performance, as well as community relations commitments.  The HSE Policy has been adopted by Vitol Ghana, committing to respect culture, traditions and livelihoods.  At the corporate level, Vitol Group, the ultimate parent company of Vitol E&P, is currently in the process of developing a Code of Conduct and Corporate Social Responsibility (CSR) policy which will be rolled out. The director of Compliance and CSR oversees social management at the corporate level and in all its operations.  

Eni Ghana, with the support of Vitol Ghana, will develop environmental and social management plans and procedures as needed (among others Stakeholder Engagement Plan including Grievance Mechanism, Local Hiring and Training Plan, Security Management Plan, Community Health Management Plan, Influx Management Plan, Marine Traffic Management Plan, Traffic Management Plan, Livelihood Restoration Plan, Land Acquisition and Compensation Framework, Fisheries Management Plan, Cultural Heritage Management Plan, in addition to the Biodiversity Management Plan) to meet the objectives of the Performance Standards as indicated in the following sections, and incorporate those plans and procedures into an integrated Environmental and Social Management System.

Management Programs.  A framework Environmental, Social and Health Management Plan (ESHMP) for the project is described in the Phase-2 ESHIA. On behalf of the OCTP partners, Eni Ghana has been appointed as the OCTP project operator and is ultimately responsible for the management and supervision of all project activities. The framework ESHMP describes the structure and processes that will be applied to development and production activities to assess and monitor compliance and effectiveness of the mitigation measures. The elements of the framework plan will be taken forward and incorporated into an integrated ESHMP that will be implemented in order to deliver the project environmental, social/health regulatory compliance objectives and other related commitments. The integrated ESHMP will be a component of Eni Ghana’s overall HSE IMS. A construction/development phase ESHMP and the relevant management plans and programs will be in place in advance of development drilling and construction, followed by a production operations ESHMP which will be developed before first oil, with gas-related elements integrated as needed before first gas. As indicated, the ESHMP will include a Cultural Heritage Management Plan with a chance-finds procedure and measures to ensure the cultural heritage site identified and excluded from the project area is not damaged or compromised during construction and production operations.

The integrated ESHMP will be maintained and developed as the project advances, and will be subject to annual review. The ESHMP will also be updated as required, such as in the event of any significant changes to the project and its environmental and social risks and impacts occur, following a Management of Change process.  In addition, Ghana EPA’s regulations call for formal submission of an up-to-date operations ESHMP within 18 months after commencement of operations, and updates every three years thereafter.

Eni Ghana will require that contractors adopt measures and bridging documents to ensure that their management systems are compatible with Eni HSE Policy, Eni Ghana guidelines and procedures within the HSE IMS and the project ESHMP. Each contractor will develop its own specific implementation plans demonstrating how the contractor intends to comply with the stipulated project requirements. All contractors’ plans will be reviewed and approved by Eni Ghana. Contracting parties to Eni Ghana will be monitored on implementation of relevant project’s environmental, social and health requirements.

Organizational Capacity and Competency.  Eni S.p.A. is a recognized and experienced operator with a strong track record in similar offshore environments. Eni Ghana is committed to provide resources essential to the implementation and control of the ESHMP. Eni Ghana’s Health, Safety, Environment, Quality and Community Investment (HSEQ & CI) department is headquartered in Accra, where staff overseeing commissioning and operations will be located. Currently, the company has a HSEQ Manager directly managing a team of five specialists in Accra and four HSE Supervisors in Takoradi. The team will be further expanded as necessary for the development phase and will maintain adequate resources and structure throughout the production and decommissioning phases. Plans have been presented that include reinforcing project staff in Takoradi and project sites to facilitate HSE and social performance oversight of site activities as well as to allow direct interface and access for stakeholders in the Western Region for the continuation of the stakeholder consultation process. During development, commissioning and production, HSE staff will also be stationed offshore.

The project will ensure that all staff, as appropriate with their job profile, understand the environmental and social policies, procedures and mitigations. The identification of training and awareness needs and implementation of the training plan will be the responsibility of Eni Ghana Human Resources & Training Manager with inputs from relevant departments. Contractors will be required to provide sufficient resources to manage the E&S aspects of their work. They will be required and responsible for the training and awareness of their staff on the project environmental and social setting, potential environmental and social impacts of their work activities, management and mitigation measures, and the existence of, and importance of complying with, the OCTP project ESHMP, including relevant interfacing with contractor’s management systems.

Vitol E&P will assign an E&S assurance manager to the project to oversee environmental, health, safety and social aspects, ensuring compliance with Performance Standards and with project E&S commitments. Vitol E&P, through the E&S assurance manager and other resources to be engaged as needed, will partner with Eni Ghana for the integration of existing plans and procedures into the Eni IMS for the project. 

Emergency Preparedness and Response.  The corporate MSG on crisis and emergency plans establishes reference principles for managing HSE emergencies and related crises, and informs the development of emergency response plans. The MSG requires that accidents are reported immediately to Eni S.p.A’s major emergencies unit. Consistent with these corporate requirements, Eni Ghana has developed plans and procedures for preparedness and response to environmental accidents and health and safety emergency situations, and for mitigating potentially adverse environmental, health, safety and social impacts that may be associated with them.  

The Eni Ghana Emergency Response Plan describes the process, actions and responsibilities by which the company deals with emergencies both onshore and offshore. Other relevant plans and procedures are the Emergency Evacuation and Medevac Procedures and the Oil Spill Contingency Plan (see the section on PS3). Before development drilling commences, a Drilling Emergency Response Plan (Drilling ERP) will be developed. The ERP will include response procedures to emergencies potentially associated to drilling activities, including fire prevention and protection, environmental emergencies, and other incidents. Before first oil / first gas, Eni Ghana will develop a Production Operations ERP. Emergency preparedness and response procedures will be reviewed by Eni Ghana at least annually and after any accidents or emergencies to ensure that lessons learnt inform continuous improvement. Emergency drills will be undertaken regularly to confirm the adequacy of response strategies and equipment, and investigations of accidents or incidents will follow formal documented procedures, according to industry good practice.

The double-hulled FPSO design will satisfy requirements set out in the International Marine Organization (IMO) Conventions and by a ship classification society. The ship classification society will evaluate the FPSO against the structural and mechanical standards and will independently review FPSO construction activities and perform regular surveys for maintaining classification status. Also other vessels involved in the project will be classified and regularly inspected by an established certification body. The FPSO will be designed for the most harsh environmental operating conditions at the OCTP Block, without the need to access dry docking facilities for the 20 years of the project expected life. 

The project will incorporate an Integrated Control and Safety System that will provide an integrated monitoring, control, protection and safety system for the entire production, topsides, marine, and subsea facilities, and the ORF. A Supervisory Control And Data Acquisition (SCADA) system will also be installed.  Fire and gas detection systems, emergency shut-down system, and emergency blowdown (depressurization) systems will be installed at onshore and offshore facilities, according to good industry practice. Equipment for depressurization of gas injection flowlines and riser system will be provided on the FPSO. Specifications for accommodations, lifeboats and life rafts, helideck, deluge system, hull equipment spaces will comply with international standards and applicable Safety Of Life At Sea (SOLAS) requirements.

Specific requirements, providing for controls for all vessels activities and based on international guidance, including the International Safety Guide for Oil Tankers and Terminals, will be developed to govern all crude oil transfers from the FPSO to shuttle tankers. 

All wells will be equipped with a blowout preventer (BOP) during drilling. The drillship will be equipped with two 15,000 psi BOPs, each with two shear rams, in accordance with Eni well control policy and international standards. The BOPs will be hydraulically operated from two remote panels, and drilling parameters will be monitored by two independent systems of sensors, which will operate in continuous mode. Consistent with industry best practice and Eni S.p.A. policy for deep water development wells, during development drilling Eni Ghana will implement well integrity and control strategies and develop specific Well Control Emergency Response Plans (WCERP). All drilling programs will be approved by Eni S.p.A in the Milan headquarters (that will act as independent, expert third party in charge of verification/review) in due time. These plans will contain strategies to respond to specific situations, including well kicks and blowouts, including drilling of a relief well, as needed. Eni Ghana has confirmed that the company has in place a global agreement for Emergency Subsea Well Capping Equipment.

Monitoring and Review. The ESHIAs outline a number of monitoring plans that will be needed for the project, both offshore and onshore. Monitoring will be conducted to ensure compliance with regulatory requirements as well as to evaluate the effectiveness of operational controls and other measures intended to mitigate potential impacts, as identified in the ESHIAs. On this basis, Eni Ghana will develop the specific monitoring plans that will describe the effects and indicators to be measured and the frequency, and will define roles and responsibilities for monitoring and reporting. A number of pre-construction surveys will also be implemented, including pre-construction fish catch surveys at Sanzule and in the project area of influence, with specific focus on beach seine fishing activities. Phyto- and zooplankton surveys will be carried near the same time as the catch surveys and focusing on fishing grounds. 

Eni Ghana will keep Ghana EPA and regulatory authorities informed of the project performance with respect to E&S matters by way of written status reports and face-to-face meetings, as required. For social performance activities, Eni Ghana will submit twice a year reports to the six District Assemblies and the Regional Coordinating Council in Takoradi. Eni Ghana will also release corporate annual reports on environmental and social performance which will be available to the public via Eni’s website, and will present relevant sections to affected communities as appropriate. Monitoring reports will also be submitted to the WBG.

As required by the IMS, Eni Ghana performs a number of internal and external HSE audits and inspections annually and, during development and production, will develop and implement an audit schedule. Contractors will be required to provide HSE performance reporting on a regular basis and include audits in their respective Contractor HSE Plans.

Cumulative Impacts. Potential cumulative impacts of the project have been identified through a rapid cumulative impact assessment (RCIA) presented in the Phase-2 ESHIA. Cumulative impacts were identified in relation to (i) the TEN project from Tullow Oil, located approximately 70 km west of the OCTP block, for which the EIS is under evaluation, (ii) other projects related to oil and gas developments, such as plans under consideration for a liquefied natural gas (LNG) receiving and regasification facility along the coast in Western Province (Phase-2 of GNGC Gas Plant at Atuabo, about 10 km west of Sanzule) and pipelines to connect it to West African Gas Pipeline (WAGP) and to potential consumers; and (iii) the Lornho Oil Service Port at Atuabo, located a minimum of 15 km west of Sanzule, for which the EIS is under evaluation. The Jubilee Field Development (about 50 km west of the OCTP block), Phase-1 of the GNGC Gas Plant at Atuabo and the road construction project along the GNGC pipeline right-of-way were not included in the cumulative impact assessment as they are operational or underway and their effect on the environment has been already taken into account in the description of the existing baseline.  

The RCIA was aimed at (a) determining the significance of the overall cumulative impacts and project’s contribution to these cumulative impacts, and (b) identifying the need of environmental and social management plans and procedures to appropriately mitigate those contributions. The main cumulative impacts offshore will be from planned exploration and appraisal drilling and potential future development projects in the adjacent licensed blocks. Cumulative impacts from increases in the level of shipping and helicopter traffic servicing other oil and gas field exploration and development programs in the area will also occur. The onshore facilities of the project will be located in an area where there is limited industrial activity. Cumulative impacts would thus be primarily related to the in-combination effects of the project with potential future development in the immediate area around the project site. 

While Eni Ghana is accountable for the design and implementation of mitigation measures commensurate with the magnitude and significance of its contribution to the cumulative impacts, the company will use their best efforts to engage other developers, local institutions and government, and other stakeholders in designing coherent management strategies to mitigate cumulative impacts. Coordination of the relevant operators, agencies and stakeholders under the direction of the Government of Ghana will be essential in order to mitigate and manage potential cumulative effects. Actions that will be explored and promoted by Eni Ghana, with the support of the partners, will include: 
- collaboration with other operators and developers along the coast of the Western Region, and the relevant Government agencies on the identification of common standards and actions for the management of potential cumulative impacts, with focus on land based and fisheries based livelihoods, surface and ground water systems and wetland conservation, coastal process and marine biodiversity, price inflation, socio-cultural changes, social infrastructure, and community health, safety and security;
- collaboration with other oil and gas operators, marine logistic and shipping companies, Ghana Maritime Authority, and Ghana EPA to join and strengthen environmental protection expertise and resources, and to coordinate approaches for oil spill preparedness and response.