HSE-P-05 Identification of Environmental Aspects Issue 3.1

HSE Procedures
SUEZ OIL COMPANY Cairo-HSE-P-05

Paper Copy Valid one month from Print Date
Identification of Environmental Aspects
Cairo-HSE-P-05
1.0 Purpose
The purpose of this procedure is to describe how environmental aspects are

identified, evaluated and recorded to facilitate effective environmental
management.
2.0 Scope of application
This procedure covers procedures to be followed in identifying Environmental

Aspects and Impacts applicable to all SUCO operations at Cairo and the fields. It
includes activities generated and managed by Cairo Head Office and implemented
at the fields.
3.0 Responsibilities
The Environment Assistant General Manager maintains files of relevant technical

data that support the initial review and significance assessments.
The Field General Manager in co-ordination with the HSE General Manager
defines the field environmental co-ordinators for each field.
The field environmental co-ordinator maintains files of local information relevant

to the initial review and significance assessment.
The field environmental co-ordinator maintains the local environmental

significant aspects register.
The field environmental co-ordinator updates the local environmental significant

aspects register as circumstances change, and annually in October.
Field production engineers carry out environmental aspect reviews on any plant
modifications or any activity that may lead to a changed environmental impact.
They communicate the findings to the field environmental co-ordinator for
updating the significant aspects register.
Field production engineers evaluate the environmental implications of proposed

new chemicals and inform materials of the required environmental controls. They
communicate the findings to the field environmental co-ordinator for updating the
significant aspects register
Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 1 of 14

HSE Procedures
Field maintenance engineers carry out environmental aspect reviews on any new
plant maintenance activities. They communicate the findings to the field
environmental co-ordinator for updating the significant aspects register.
Departments proposing the use of contractors must evaluate the environmental

implications and include relevant provisions in the contracts. Proposed contracts
are circulated to HSE Division for comment before sending out to tender.
The field environmental co-ordinator assesses any changes or input from planned
inspections, audits etc. and updates the significant aspects register as they occur.
The Environmental Assistant General Manager evaluates legal requirements and

communicates relevant changes to the field co-ordinators.
4.0 Procedure
4.1 Initial Review
The basis for any aspect identification is the previous work done in the Initial
Review. The Initial Review involved the following activities:
Existing geotechnical and environmental reports were gathered together by

the Safety & Environment Supt. and the key points from them extracted to
show local soil and sub-soil conditions, ground water, air quality, any land
use and any critical wildlife habitats. Wherever possible this was displayed
in map form.
Periodic comprehensive surveys were undertaken by independent and

qualified organisations to measure compliance to legal requirements and to
identify the impact of SUCOs operations on the local environment.
This work constitutes identification of past environmental aspects and

consequent impacts. When it is necessary to re-confirm past aspects then
this procedure will be repeated
Existing descriptions of site activities were assembled together with those

items and aspects that were identified as part of the Health Control
programme.
Each of the areas identified under Planned Inspections and Maintenance

activities were assessed for Normal, Abnormal and Emergency situations.
Note: - In this case Normal is the design state. Abnormal is when

controlled intervention work such as Maintenance, Well Intervention or
Drilling is carried out and Emergency is when full control has been lost
on the activity, which could or does lead to an undesired event or accident.

HSE Procedures
Emissions to the Atmosphere were calculated using the UKOOA EEMS

Model.
Quantities of solid waste generated and wastewater volumes discharged

were measured or calculated.
Noise and Radiation surveys were carried out.
Environmental aspects of products in use were identified on a general level

as being indirect. SUCO has limited control over the use of the product.
However, the main aspect of product significance is the potential for
spillage, which is identified as significant and is subject to legal controls.
Other Indirect Environmental aspects have been identified through the

purchasing and contractor process. There is limited control of these outside
the SUCO environment. Whilst inside the SUCO areas these are considered
direct.
Future environmental aspects were considered through a variety of routes.

For short term future aspects then these were identified through the change
management process and aspect identifications updated accordingly. For
longer-term issues such as acquisition and abandonment these would be
considered by Environmental Impact Assessment by independent bodies as
part of the project.
All records and evaluations made are maintained as part of the

Environmental Register for each field.
This process has given rise to a variety of aspects and impacts that vary in detail
and description depending on how they have been developed.
4.2 Environmental Aspect Identification
The basis for any aspect identification is the previous work done in the Initial
Review and recorded in the Field Environmental Aspects Register.
The identification and evaluation of Environmental Aspects on an ongoing basis

requires the use of a variety of tools and involves several steps to ensure that the
information is kept up to date.
The identification of any Environmental Aspect relies on the recognition that

change has taken place in an activity, product or service that has or could have
significant impact. Similarly if any new activity, product or service is
contemplated. This recognition can be pro-active, when planning the change, or
reactive, having been discovered during routine operations monitoring.

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There are several circumstances that may arise and the current mechanisms
therefore include the need for identification of Environmental Aspects. Once
these have been identified, they are assessed for significance as described later in
this procedure.
4.2.1 Change in Equipment
The procedure for assessing the acceptability of new equipment or facilities (Plant
Modification Certificate) is used to assess whether any changes are made that give
rise to different environmental aspects. Plant Modification Certificates are
circulated to field HSE for comment.
4.2.2 Change in Purchase Materials/Chemicals
When new chemicals or materials are proposed the approval mechanism includes
an evaluation of the new environmental aspects carried out by the operations and
HSE Department staff.
4.2.3 Change in Activity or New method
When it is proposed to change the defined operating procedure or work method

involving in-house or contract staff, an evaluation of the effect on the
environment is carried out by the relevant staff involving the HSE Department.
This also applies to organisational changes.
4.2.4 Change in Supplier/Contractor
When it is proposed to use a new Supplier or Contractor or to change the existing

situation, an evaluation of the effect on the environment is carried out. This is
done by relevant staff who also involve the HSE Department.
4.2.5 Change in External Circumstances
When new information arrives from external sources, such as Cairo Office,
Regulators, Customers, or Interested Parties that has an effect on what is
considered as an environmental aspect, the HSE Department Staff assess the
implications and evaluate these as new aspects.
4.3 Environmental Aspect Consideration
Although the current information relates to a comprehensive initial review it is

necessary to remember when assessing environmental aspects to consider the
different situations of relevance.
First of all the aspects are assessed with respect to the expected situation:

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Normal operation
Abnormal operation
Emergency conditions
Secondly the aspects are assessed on the basis of time to consider:
Current impacts
Future Impacts
(Past Impacts should already be identified though it may be worth reviewing
these)
Lastly it is necessary to examine the level of control or influence SUCO has on

the Aspect. For example, the impact of manufacture of chemical supplies may be
high but there is little ability for SUCO to do anything about it.
4.4 Assessing Significance of Environmental Aspects
The compilation of the Aspects Register has resulted in a variety of Aspects with
differing levels and scope of definition. This process is intended to be the
foundation for the identification of aspects therefore the Significant Aspects
Register will be in a constant state of revision as new aspects arise or as
definitions of aspects change. This section describes the ongoing process both for
defining Aspects and Impacts and for assessing significance.
4.4.1 Evaluation of an Environmental Aspect
As a means to defining Environmental Aspects the table in Appendix 1 is used.
When any of the change mechanisms identified in Section 4.2 are used the
Environmental Aspects are examined using this table. The clearly defined Aspect
(quantified where possible) is then assessed against the likely Environmental
Impact to determine significance.
This process involves three screens applied in series:
Screen 1 Legal Considerations

Screen 2 Environmental Risk Assessment
Screen 3 SUCO significance criteria
If an aspect is identified in the first screen as significant from a legal point of view
then this aspect is added to the Aspect Register as significant.
If it is not significant then the environmental risk screen is applied. If it passes

through this screen as not significant then a final screen of important issues for
SUCO is applied.

HSE Procedures
This mechanism is used to ensure that the relevant weight is placed on all
environmental issues, not just those with legal significance or high emergency
potential.
4.4.2 Legal Screening
The first screen addresses all Environmental Aspects that are covered by Legal
Controls. To carry out this screen the field environmental co-ordinator reviews
the proposed change against the summary record of legal requirements. To ensure
that potential items are not missed as they are controlled through legislation not
currently relevant, the field environmental co-ordinator confers with the
Environmental Assistant General Manager in Cairo Office.
Any Aspect identified as covered by legislation is automatically considered

significant.
4.4.3 Environmental Risk Assessment
For those items that pass through the legal screen, the second screening based on
environmental risk is applied. This screen focuses on major harm to the
environment, and uses standard risk assessment approach to evaluate severity,
frequency and likelihood.
A table of relative consequences with significance ratings is shown in Appendix

3.
4.4.4 SUCO Criteria
For those items that pass through the legal screen and the second screening based
on environmental risk, a further screening is used to identify significance based on
a wider range of criteria. This screen focuses on relevant industry practices and
standards, interested party views and management priorities.
The criteria used are shown in Appendix 4.
4.5 Other Inputs to Updating the System
The compilation of the Aspects Register has been a continuous process. During
normal work some existing Environmental Aspects that have not, as yet, been
documented are occasionally found. This section describes the process for
dealing with those.
It is intended that Aspects identified from any source are evaluated using the
methodology described in this procedure. Therefore this section describes the
sources where these overlooked Aspects are identified.
Environmental aspects are identified occasionally during other activities such as:

HSE Procedures
Planned General Inspections

Accident/Incident Investigation
Contract Reviews
Planned maintenance
Staff training
Audits
Where aspects are observed they are evaluated using the above screening process
by the relevant HSE Department staff member. The Register is then updated with
the relevant Management System Elements as shown in Appendix 5.
4.6 Reviewing the System
In addition to the continuous update described above, the Environmental Assistant

General Manager reviews the Field Registers annually in October to ensure that
the contents reflect current operations.
The HSE General Manager then prepares a report on the process for the
Management Review meeting to consider.
5.0 Applicable Forms
Aspect Evaluation form

Environmental Aspect Register
6.0 Required Records
The HSE General Manager and Field HSE Superintendents hold a record file of
all Field Aspect Registers.
Field HSE Superintendents keep files of all Aspect Evaluations carried out.
The HSE General Manager retains all summary and analysis reports.
A file of correspondence will be held centrally.

HSE Procedures
Cairo HSE- P 05 Appendix 1

To ensure clarity of definition it is necessary to define environmental aspects at the level where clear understanding is
reached of what control measures are necessary.
For example a typical Environmental Aspect related to driving could be described as:
Driving a car
Exhaust gases from a car
Carbon dioxide emissions from a car
It is clear that only the last is adequate enough to define what a real environmental issue is (Climate change through
global warming). Hence the SUCO approach is to aim for this end of the Aspect spectrum.
Area/Activity Environmental Aspect Defined Aspect Quantify if possible
Emissions to Air
Emissions to Water/discharges
Waste management
Land Contamination
Use of Resources
Other local and environmental issues

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Cairo HSE- P 05 Appendix 2
An example of each is shown to illustrate the process
Area/Activity Environmental Aspect Defined Aspect Quantify if possible
Emissions to Air Carbon dioxide emissions from flares 30% of 2.5 MMSFCh
Emissions to Water/discharges Oil content in Produced water 12 ppm
Waste management Norm Contaminated Waste Production 1 tonne/year
Land Contamination Fuel Oil contamination from spillages Round diesel tanks
Use of Resources Fuel gas used in Turbine 15 tonnes/day
Other local and environmental issues Glycol regenerator Odour when wind from
North

HSE Procedures
Cairo HSE P 05 - Appendix 3
Significance Levels in Environmental Aspects.
LEVEL OF IMPACT DEFINITION
Change to the local or Global Ecosystem leading to long-term

(10+years) damage and poor potential for recovery to normal state.
Likely effect on human, as well as animal and plant health.

SEVERE
Legal requirements on discharge etc.
(Significant)
Long-term or severe loss, or change to users or public finance
Changes to the local ecosystem or activity over a wide area leading to

medium term (2+ years) damage but with a likely hood of recovery
within 10 years.
MAJOR
Possible effect on human health
(Significant)
Financial loss to users or public
Changes in the local ecosystem or activity in a local area for a short

time, with good recovery potential. Effects may be cumulative and
repetition may have major significance.
MODERATE
Potential for damage to health is low but may cause a nuisance effect
to users or the public.
Change which is within the scope of existing variability and which

require regular monitoring to even detect.
MINOR
May effect behaviour but not a nuisance to users or the public.
Changes which are unlikely to be noticed or are below the limits of

measurement.
NEGLIGIBLE
Negligible effects to health
No interaction and therefore no effect or change. NONE
Likely to cause some enhancement to the ecosystem or activity within

the local area
BENEFICIAL
May improve conditions for the users or public

HSE Procedures
Cairo HSE P 05 - Appendix 4
List of relevant significant environmental issues from SUCO perspective.
Issue Significant Aspects Chemicals
Climate Change CO2 emissions and VOC emissions from CO2 Methane, Nitrous Oxide, organic solvents and fuels
fossil fuel combustion and flares
Vehicles and maintenance
Ozone Depletion Emission of chlorinated solvents by Chlorofluorocarbons, halons, chlorinated solvents

evaporation or disposal from laboratories
and storage areas
Halon discharges from fire suppression
and extinguishers
NOx emissions from combustion
Acid Rain NOx and SOx emissions from SO2, NOx, HCl, halons, chlorinated solvents
combustion sources
H2S emissions
Water Quality Water pollution from oils, heavy BOD and COD
metals, detergents, drugs, Heavy Metal Content
biological materials and pesticides Oil and organics
Faecal Coliform
Suspended solids
Nitrates, phosphates and chlorides

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Persistent Organics Pesticides Organochlorides, polychlor, biphenyls,

PCBs in Transformers/electrical organosilicones, polybrominated compounds
equipment
Medicines and drugs
Air Quality Combustion products from VOC

furnaces flares and vehicles, NOx/SOx
gases and particulates Particulates
Mineral dusts from quarrying and Mineral dust
digging Metal dusts
Metal and Metal Oxide dusts from
welding, grinding and machining
Noise/Vibration Seismic test explosions In unusual cases only

Flares
Transportation
Operating equipment
Visual Impact/Amenity Smoky Flares In unusual cases only

Transportation
Chemicals
Waste storage

HSE Procedures
Contaminated Land Chemical and oil Spillages See wastes below

Solid Wastes disposal offsite
Solid and liquid Waste storage
onsite
Oil from vehicles
NORM Sludge
Waste Management Liquid Effluent onshore and Sewage same as water quality list above
offshore Oils
Solid Wastes Scrap metals
Special Wastes NORM
Oils chemicals and solvents from Chemicals and solvents
vehicles, labs, workshops, Medical and Clinical
operational and accommodation Domestic
areas Food
Hazardous materials
Old electrical equipment
Old A/C and refrigeration equipment
Old fire fighting equipment/materials and chemicals
Asbestos from insulation, construction and buildings
Major Spills and Incidents Oil spills onshore and offshore Many effects including air, water and land
Major fires contamination

HSE Procedures
Appendix 5 Significant Aspects and Control Measures
Department: Location: Environmental Aspect: Activities/Products/Services
Job Title: Prepared by: Date: Reference No.:
ID Activity/Product/ Aspect Potential Impact Situation Control System Measures

Service
Procedures
Procedures
Emergency
Emergency
Awareness
Significant
Objectives
Abnormal
Induction
Normal
Other
Rules
PPE

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HSE Procedures

SUEZ OIL COMPANY Cairo-HSE-P-05

Identification of Environmental Aspects

The purpose of this procedure is to describe how environmental aspects are

2.0 Scope of application

This procedure covers procedures to be followed in identifying Environmental

The Environment Assistant General Manager maintains files of relevant technical

The field environmental co-ordinator maintains files of local information relevant

The field environmental co-ordinator maintains the local environmental

The field environmental co-ordinator updates the local environmental significant

Field production engineers evaluate the environmental implications of proposed

Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 1 of 14

Departments proposing the use of contractors must evaluate the environmental

The Environmental Assistant General Manager evaluates legal requirements and

4.1 Initial Review

Existing geotechnical and environmental reports were gathered together by

Periodic comprehensive surveys were undertaken by independent and

This work constitutes identification of past environmental aspects and

Existing descriptions of site activities were assembled together with those

Each of the areas identified under Planned Inspections and Maintenance

Note: - In this case Normal is the design state. Abnormal is when

Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 2 of 14

Emissions to the Atmosphere were calculated using the UKOOA EEMS

Quantities of solid waste generated and wastewater volumes discharged

Noise and Radiation surveys were carried out.

Environmental aspects of products in use were identified on a general level

Other Indirect Environmental aspects have been identified through the

Future environmental aspects were considered through a variety of routes.

All records and evaluations made are maintained as part of the

4.2 Environmental Aspect Identification

The identification and evaluation of Environmental Aspects on an ongoing basis

The identification of any Environmental Aspect relies on the recognition that

Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 3 of 14

4.2.1 Change in Equipment

4.2.2 Change in Purchase Materials/Chemicals

4.2.3 Change in Activity or New method

When it is proposed to change the defined operating procedure or work method

4.2.4 Change in Supplier/Contractor

When it is proposed to use a new Supplier or Contractor or to change the existing

4.2.5 Change in External Circumstances

4.3 Environmental Aspect Consideration

Although the current information relates to a comprehensive initial review it is

Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 4 of 14

Secondly the aspects are assessed on the basis of time to consider:

Lastly it is necessary to examine the level of control or influence SUCO has on

4.4 Assessing Significance of Environmental Aspects

4.4.1 Evaluation of an Environmental Aspect

As a means to defining Environmental Aspects the table in Appendix 1 is used.

This process involves three screens applied in series:

Screen 1 Legal Considerations

If it is not significant then the environmental risk screen is applied. If it passes

Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 5 of 14

4.4.2 Legal Screening

Any Aspect identified as covered by legislation is automatically considered

4.4.3 Environmental Risk Assessment

A table of relative consequences with significance ratings is shown in Appendix

4.4.4 SUCO Criteria

The criteria used are shown in Appendix 4.

4.5 Other Inputs to Updating the System

Issue 3.1 August 2006 Next Revision Date - 31/07/08 Page 6 of 14

Planned General Inspections

4.6 Reviewing the System

In addition to the continuous update described above, the Environmental Assistant

5.0 Applicable Forms