CO-IRQ-FOD-PRA-0163-EN

CMIT FOD
Procedural Aid
for
Environment Management Plan

Conformance with this Procedural Aid is mandatory.

You may not ‘opt-out’ of any requirement identified herein.

Han Shun,
Imad Hussein,
HSE Manager of CMIT
CMIT FOD General Manager
Accountable Responsible FOD
Owner: Dai Weihua, Author: Ghazwan Faisal,
CMIT FOD Deputy General HSE Manager of
Manager CMIT FOD
Required Review
Publish Date: 30-Jun-24 3 Years
Frequency:

Effective Date: 30-Jun-24 Revision: 1.0

Applicability: Missan Fields Operating Division

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TABLE OF CONTENTS
INTRODUCTION ..................................................................................................... 3
1.1 PURPOSE ................................................................................................................. 3
1.2 SCOPE ...................................................................................................................... 3
DEFINITION ............................................................................................................. 3
RESPONSIBILITIES ................................................................................................ 4
3.1 HSE DEPARTMENT .................................................................................................. 4
3.2 OPERATIONAL DEPARTMENTS .............................................................................. 4
3.3 CONTRACTORS ....................................................................................................... 4
REQUIREMENT ...................................................................................................... 4
4.1 IDENTIFICATION OF ENVIRONMENTAL ASPECTS, IMPACTS .............................. 4
4.2 MONITORING AND REPORTING OF ENVIRONMENTAL ASPECTS AND IMPACTS
5
4.3 WASTE MANAGEMENT ............................................................................................ 7
4.4 AUDITING AND REPORTING ................................................................................... 9
4.5 EMERGENCY RESPONSE PLAN ............................................................................10
REFERENCES ...................................................................................................... 13
SUPPLEMENTARY INFORMATION ..................................................................... 13
APPENDIX............................................................................................................. 13
APPENDIX 1. SPILL RESPONSE FLOW CHART ................................................................14
APPENDIX 2. EMERGENCY CONTACT LIST ......................................................................15

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INTRODUCTION
1.1 PURPOSE

The purpose of this Procedural Aid is intended to guide the development of detailed
management plans at FOD facilities to be established for the project‘s construction and
operation phases and to define the mitigations and monitoring activities to be carried out
to ensure environmental management principles.

1.2 SCOPE

This Procedural Aid is applicable to all facilities of Missan Oil Fields.

DEFINITION

MOC

Missan Oil Company

MoE

Ministry of Environment, Iraq

MoO

Ministry of Oil

FOD

Field Operative Division

BUT

Buzurgan Terminal

HDPE

High Density Polyethylene

MSDS

Material Safety Data Sheet

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RESPONSIBILITIES
3.1 HSE DEPARTMENT

The HSE Department shall

• Provide advice and assistance to all related departments as and when requested
on environment management options, standards, and practices.
• Provide information and advice on any new/forthcoming legislation
• Ensure EMP program is developed and regularly reviewed covering all FOD
Premises.
• Ensure EMP activities are included in audit programs.
• Monitor and report the implementation of EMP.
• Provide training for HSE activities, as required.

3.2 OPERATIONAL DEPARTMENTS

The Operational Departments shall

• Implement and follow the EMP strictly.
• Ensure team members are aware of EMP.
• Implement the corrective actions required.

3.3 CONTRACTORS

The Contractors shall

• Implement and follow the EMP strictly.
• Ensure team members are aware of EMP and to monitor the plan.
• Implement the corrective actions required and report the same to FOD regularly.

REQUIREMENT
4.1 IDENTIFICATION OF ENVIRONMENTAL ASPECTS, IMPACTS

The plan below identifies these areas specifically and identifies environmental key areas
which have impact and are crucial for environmental mitigation. These identified key
environmental areas are required to be monitored by FOD and its related departments.
These measures ensure environmental monitoring at a detailed level at all FOD facilities
to enable environmental compliance by addressing environmental impacts related to FOD
facilities.

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There are various environmental aspects and impacts to be monitored based on type of
activity that include construction phase, operation phase, drilling and workover at FOD
facilities to maintain environmental compliance these are divided as per the category
below:
4.1.1 Construction Related Environmental Key Areas:
• Air Quality - Dust emissions from construction activities including drilling and work
over, pollution from diesel equipment like generators and machinery etc.
• Noise - Noise from construction activities, noise from generators and other
construction equipment etc.
• Water - water used for construction, cleaning, commissioning etc.
• Soil - soil contamination due to oil and chemical spills, contamination of soil due to
drilling activities etc.
• Archaeology and cultural heritage – Protection and preservation of any
Archeological sites identified in EIA study
• Waste Management
4.1.2 Operational Environmental Key Areas
• Air Quality - Emissions from stationery sources, diesel generators, ambient air, un-
burnt hydrocarbons, dust from operational activities.
• Noise - Noise from stationery plant equipment, shut down and maintenance
activities.
• Water - Water quality from treatment units, discharges to ground from operational
activities, sewage water etc.
• Soil - Spills from pipelines, maintenance activities, chemical handling and transfer
etc.
• Waste Management

4.2 MONITORING AND REPORTING OF ENVIRONMENTAL ASPECTS AND

IMPACTS

Based on above identified environmental key areas which have to be monitored as per
monitoring program and mitigated to minimize environmental impact based on their aspect
a detailed monitoring plan devised below, this covers all FOD activities that include
operation and construction phases. Individual responsibilities are assigned to related
departments. Based on the environmental key aspects that originates from their respective
area or location.
4.2.1 Air Quality

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The following tables summarize potential significant residual effects on air quality identified
in the Missan oil fields and set out the required mitigation measures to address these
effects. The responsibility for implementing these measures and the criteria to be used to
assess implementation are also identified.
Environmental Aspect Monitoring Program / Mitigation Measure
Deterioration in air quality 1. Diesel generators to comply with standard emission
(including from dust) from limits for plant of that type and with the Iraq limits.
Construction and operational 2. Owner drilling and serve staff accommodation to be
activities used for minimum required period.
Deterioration in air quality from 1. Burning of unprocessed gas at the degassing stations
flare. and CPFs to be minimized.
2. Commissioning of new NGP units to reduce the
unburnt hydrocarbons.
Deterioration in local air quality 1. All reasonable attempts should be made to maximize
due to stack emissions. (NOx, energy efficiency and design facilities to minimize
SOx, CO2) energy use.
2. Stacks serving the proposed power plant will be of
sufficient height to enable adequate dispersion of
emissions.
3. Ensure to reduce dust emissions during drilling
activities by following best practice methods during
drilling activities.
4.2.2 Noise

The following tables summarize potential significant residual effects noise quality identified
in the Missan oil fields and set out the required mitigation measures to address these
effects. The responsibility for implementing these measures and the criteria to be used to
assess implementation are also identified.
Environmental Aspect Mitigation Measure
Noise from the operational and 1. Sensitive location of static plant items, such as
construction activities generators and compressors.
2. Carry out adequate maintenance/lubrication of plant
items.
3. Shut down engines when not in use; Install suitable
mufflers on exhausts; Carryout noise monitoring
whenever required.
4. Provide acoustic enclosures of noisy items of plant
such as generators and compressors.
5. Ensure all FOD employees and Contractors are made
aware of noise related hazards by Toolbox talks and
sign boards displayed on sites at noisy areas.
4.2.3 Soil and Geology

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Environmental Aspect Mitigation Measure

Loss of Containment / Leak from 1. Ensure implementation of maintenance procedure,
Project Crude Oil Containment inspect all critical areas prone to loss of
System/ facilities contamination or leakages.
Accidental spillages from drilling 2. Conduct visual inspection and maintain checklist with
and work over activities at drilling updates.
sites 3. In case of spill contain the spill, collect the
Diesel Fuel Spills/Leaks contaminated material separately and notify
Chemical Spills during transfer or concerned department.
injection 4. Implement and follow Oil Spill response Plan Tier 1
Oil Spill Response Plan.
4.2.4 Water Resources
Environmental Aspect Mitigation Measure
Sewage Water 1. With Sewage Treatment Plant in operation the water
is treated and reused for plantation.
2. All sewage water from contractor locations and
remote sites shall dispose sewage in proper way at
an appropriate destination.
Wastewater from Construction 1. Any wastewater generated from construction
activities activities can be discharged into an open pit to be
naturally evaporated if it has no hazardous pollutants.
Wastewater from drilling sites 1. Wastewater produced from drilling sites Shall be
disposed in to cutting pits next to the location with
HDPE layer, tested and if found should be disposed
as per MOC instructions.
Wastewater from Operations 1. Wastewater within process area is being routed to
WTP and oil water treatment plant and later after
appropriate treatment is routed to injection wells.

4.2.5 Archeology and Cultural Heritage Sites

Environmental Aspect Mitigation Measure
Archeological sites and antique 1. Ensure the all Archeological sites identified in EIA
materials in Missan oil fields study are not accessed and no activities are
undertaken by unauthorized access
2. If any Archeological locations are identified as per EIA
studies or in the later stage report the same to MOC.
4.2.6 Ecology
Environmental Aspect Mitigation Measure
High ecological /sensitive areas Endure High ecological / sensitive areas and species
and species identified during Environmental Impact Assessment study
and are guarded and monitored, no activities shall be
undertaken by FOD or its contractors that will disturb the
ecological nature of location.

4.3 WASTE MANAGEMENT

4.3.1 Measures taken for Reduce, Reuse and Recycle

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Reduce: Using construction material appropriately by assessing the construction

requirements, wastages that occur during the construction phase etc.

Reuse: Treatment of treated gas by routing it to Compressors for power plant where
treated Natural gas for furthering generating captive power.

Recycle: Process water from oil treatment is recycled in Water Treatment Plant where the
water is treated by chemical mixture process and the same is injected back to sub surface
through injection wells.

FOD has assessed and planned its waste management based on the actual waste
generation, its availability of local waste management infrastructure and service provider
to devise below hierarchy.

Figure 1.1. Waste and Resource Management Hierarchy Principles

4.3.2 Waste Classification and Disposal

FOD classify the waste as the requirements of MOC and Ministry of Environment (MoE).
There are Hazardous and Non Hazardous wastes that are generated and these wastes
streams are to be segregated based on their properties, all contractor wastes shall be also
be reported to FOD whereas the responsibility of management, disposal of contractor’s
waste is solely on contractors.

4.3.2.1 Non-Hazardous Waste

• Construction Waste: If the waste majorly consists of construction debris like
concrete, wood, soil from construction activities this shall be disposed at assigned
waste dumping yard.
• Metal Waste: If the waste majorly consists of metal waste namely metal scrap then
this waste shall be disposed into metal waste dumping yard.

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• Domestic Waste: If the waste majorly consists of domestic waste i.e. paper waste,
food waste, cartoons packing material etc. then this waste shall be disposed at
assigned waste domestic waste dumping yard.

FOD generated domestic waste shall be transported to designated landfill such as Amara
or Mushara Municipal Sanitary Landfills. Furthermore, FOD plan to construct advanced
waste landfill after approved by local authorities.

For Sewage waste all the locations are provided with sewage collection pit where sewage
is collected on a regular basis. Sewage water is majorly collected and sent to Sewage
Treated Plant (STP) at work base camp to be treated.

4.3.2.2 Hazardous Waste Disposal

Types of Hazardous Wastes:

• Hydrocarbons, Lube Oil and Hot Oil.
• Spent Oil and air filters, oil rags, filters
• Chemical Drums (used) metal and plastic, Laboratory wastes
• Drilling fluids and expired chemicals from drilling activities etc.

As per Iraqi Laws and regulations, Paint related waste, Hydrocarbon Filters, Batteries/Dry
cell batteries, Amid, florescent lamps and Oil rags shall be segregated and transfer these
wastes to assigned temporary hazardous waste storage location.

MOC shall support FOD to handle, transfer and dispose hazardous waste from temporary
storage yard to offsite disposal facility that is finalized by MOC.

Any offsite transfer of Hazardous wastes shall be accompanied by supporting records, the
records shall as a minimum contain, waste transporter license to transport hazardous
waste, Truck number, volume, and final disposal location.

4.4 AUDITING AND REPORTING

4.4.1 Record Keeping

Information generated from auditing and monitoring will be stored by FOD to enable
corrective actions identified during the inspection / auditing process to be recorded,
tracked a finalized.

The FOD will keep the following key records:

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• Monthly records of Environment Monthly Performance Report from all

concerned departments that includes waste data, spills occurred, waste water
generated etc.
• Waste register including hazardous and dangerous materials.
• Other records prescribed by government agencies through the licensing and
permitting of these activities.
• Environmental training and induction.
• Complaints and incidents.
• Inspection and audit details including findings.
• Corrective actions.
4.4.2 Auditing
• FOD conducts Quarterly Site Environmental Inspections to ensure effective
environmental compliance is being followed at all facilities.
• FOD will report environmental compliance on monthly basis.
• The audit report shall also contain recommendations on any non-compliance
or other matter to improve compliance.
• FOD will immediately act upon any recommendations arising from the audit
report and investigate any non-compliance issues identified.
• As soon as practicable, implement measures or take necessary action to
ensure compliance.
• When first becoming aware of a non-compliance, the FOD will undertake
action to bring the matter into compliance within an effective time frame.

4.5 EMERGENCY RESPONSE PLAN

Emergency response situations that affect environmentally and cause damage due to
nature of activities in oil field operations are common, these incidents are majorly spills
that influence environmentally and cause collateral damage and have other types of
impact.

FOD has identified these spill incidents as per their nature of activity and distinguished
them as per their category and nature these are as follows:
4.5.1 Chemical Spills

Chemicals spills are those that occur due to some situations and cause environmental
damage to the soil, and contaminate the area these may be spills that occur during
transportation of chemicals, spills that occur during transferring chemicals from drums,
tote tanks in to units in plant and spills that occur in plants due to malfunction or faulty

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equipment. In all the above scenarios there is a potential of spill causing environmental
damage to soil and contaminate the ground and this plan addresses how to effectively
prevent, address spill response, and contain and clean up under section 4.5.4 Spill
Response Strategies.
4.5.2 Spills from Waste handling, transportation, and storage

Spills from waste are those that occur due to some situations and cause environmental
damage and contaminate the area these may be spills that occur during transportation of
waste from one point to another on trucks, spills that occur during transferring waste from
waste storage containers onsite in to trucks and spills that occur due to high winds that
carry away waste and scatter the waste all along the area around leading to environmental
hazard.

In all the above scenarios there is a potential of spill causing environmental damage to
soil and contaminate the ground and this plan addresses how to effectively prevent,
address spill response, and contain and clean up under section 4.5.4 Spill Response
Strategies.
4.5.3 Possible Oil Spill Scenarios

At Missan Oil Fields the probability of Oil spills is more due to the nature of activity involved
in oil extracting operations, drilling activities etc., added to this some oil pipelines being
old and gain corrosively leading to leaks and repairs.

The Tier 1 Oil Spill Response Plan describing in detail the communication system, site
emergency response operation, duties and responsibilities of personnel and action to be
taken in the event of an emergency.
• Primary high-risk area at well pad, degassing stations, CPD and drilling and
work over. Potential spillage would directly impact the ground. the most likely
causes of a spill, which can result to a Tier 1 incident, are:
• Leaks during maintenance activities and/or normal operations
• Oil and hydraulic fluid leaks from machinery/storage facilities or line failures
(burst of hydraulic hoses and cylinders)
• Spills during refueling operations (e.g. bunkering hose failure, overfilling of
tank, pump malfunction) Uncontrolled refueling operation.
• Spills because of an accident (e.g. excavation, grounding, collision, sinking,
fire or explosion).

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• Designated vehicle maintenance areas and workshops/ Uncontrolled vehicle

maintenance on site.
• Uncontrolled vehicle maintenance on site.
• Uncontrolled refueling operation.
• Pollution/spillage from onshore oil storage tanks /oil storage facilities (Less
than 50 m3 capacity).
• Releases due to road accidents.
As per MOC the Tier 1 Spill Prevention and Response Procedure shall address small
scale spills based on a tier level approach:
• Tier 1 Minor Spills: In case any spill can be controlled by the FOD, restricted
within the project site boundaries, and the response measures can be
effectively managed by FOD’s own spill equipment available on site as
specified in Tier 1 Emergency Oil Spill Response Plan.
• Tier 2 Major Spills: In case FOD cannot control the spill, the spill spreads
outside project site boundary; spill magnitude/type requires evacuation for
protection of staff and the response measures available onsite are not
sufficient. Additional resources or external party experts (MOC) must be called
upon or support from relevant authority will be required.
4.5.4 Spill Response Strategies

The Initial Response to any Spill incident shall be:

• Site conditions will be assessed along with the environmental impact of

various clean-up procedures.
• As assessment will be made of the potential for Chemical /fuel recovery.
• On-site personnel will be deployed to mobilize pumps and empty drums (or
other appropriate storage) to the spill site.
• Absorbents and will be used as necessary.
• All contaminated debris will be properly disposed, as per Waste Management
Plan.
• All necessary precautions will be taken to ensure that the incident does not
reoccur.
• In an event of spill, the document may be revised to incorporate mitigation
measures and prevention actions as

A Spill Response Flow Chart detailing the process flow during an event of spill is detailed
in Appendix 1.

An Emergency Contact List that details all important contact details to be reached in an
event of spill is demonstrated in Appendix B, this list will be updated on a periodic basis.

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REFERENCES
Missan oilfield shall comply with all relevant environmental legislations and good practice
as well as FOD’s own health, safety, and environment (HSE) policies.
• Law No. 27 of 2009 related to Protection and Improvement of Environment
• Law No.471 of 2012 related to protection of ambient air quality
• Law No. 449 of 2012 related to Local treated effluent water quality standards for
usage in irrigation of farmlands/crops.
• Instruction No.4 of 1989 Safety Instruction for Storage/handling of Chemical
Material
• Law No. 3 of 2011 related to environmental specifications for establishment project

SUPPLEMENTARY INFORMATION
To be interpreted by FOD HSE Department.

APPENDIX
Appendix 1: Spill Response Flow Chart

Appendix 2: Emergency Contact List

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APPENDIX 1. SPILL RESPONSE FLOW CHART

Notices the Spill

Spill Response Coordinator
Informs Dept HSE Manager,
Environment Engineer

Informs Supervisor

Inform Emergency Spill

LSD Workshop Manager/ Response Coordinator/ on
Provides required duty Spill Response
assistance from workshop Coordinator takes lead

FOD General Spill Response team sets

Manager/Deputy out to for Spill Response
Communicates information
to external Parties (if
required) and hands over
site to MOC/MOO
emergency services if the
Spill level is above Tier I Spill Response actions
clean up and disposal of
waste actions

Investigate the Incident and

generate relevant report

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APPENDIX 2. EMERGENCY CONTACT LIST

Emergency Resource Contact Number
07822835357
HSE General Office
07822709045
07822709469
Operation Department (OPD) Spill Response
07822709466
Center
07813975270
07812266531
Central Processing District (CPD) Spill 07803027161
Response Center 07710882334
07710324764
07800570741
Logistic Support Oil Spill Response Center
07830662626

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