Tullow Oil plc, through its subsidiary, Tullow Ghana Limited, has interests in two exploration blocks in Ghana – Deepwater Tano and West Cape Three Points. Tullow is the operator of the Jubilee field, which straddles both blocks, and lies approximately 60 kilometres off the coast of Ghana. The Jubilee field was discovered in 2007 and First Oil was celebrated on 15 December 2010 following first initial production in November.

Jubilee is a world-class oil field with estimated recoverable resources of up to 1 billion barrels. In addition to Jubilee, these licences hold further exploration potential, which is currently being explored.On the 25 July 2011, Tullow completed the acquisition of the Ghanaian interests of EO Group Limited for $305 million, increasing Tullow’s interest in the West Cape Three Points licence by 3.5% to 26.4% and in the Jubilee field, which Tullow operates, by 1.75% to 36.5%. Other partners in the Jubilee Unit Area are Kosmos Energy (23.49%), Anadarko Petroleum (23.49), the Ghana National Petroleum Company (13.75%) and Sabre Oil & Gas (2.81%). Tullow also has a 49.95% interest in the Deepwater Tano licence which includes the TEN discoveries.

The purpose of the audit was to assess whether the systemic environment, health and safety (EHS) routines worked satisfactorily. The Environmental Protection Agency has among other things examined whether the enterprise’s system for internal control is appropriate and adequate activities are carried out such as they are described and stated the enterprise achieves its goals and conducts its operations within both a self-imposed framework and the framework imposed by the authorities.

The audit was conducted by reviewing documents interviewing key personnel in the organization verifying (through spot checks) that routines, procedures, and instructions are adhered to in actual practice.

The audit’s areas of focus:

1. Discharges to water

2. Chemical management

3. Waste management

4. Oil spill contingency planning

This report pertains to non-compliances and observations that were uncovered during the audit and does not provide a comprehensive status report on the enterprise’s environmental work or environmental status.

Definitions Non-compliance: Non-compliance with a legal obligation established by an act or pursuant to such an act.

Observation: A state of affairs that the supervisory bodies consider it necessary to point out in order to preserve the external environment, but that is not covered by the definition of non-compliance.

Audit results This report pertains to non-compliances and observations with regard to Tullow’s Jubilee Oil Field that were presented during the audit’s final meeting on 13 December 2013. The Environmental Protection Agency uncovered 5 non-compliances and 4 observations during the audit.

Non-compliances

1. Updated versions of Emergency Preparedness Plans were not submitted to EPA.

2. TGL has not ensured that ecotoxicological testing of chemicals prior to usage on the FPSO is done.

3. Monthly reports sent to EPA do not reflect the amount of hazardous waste, which is lifted from the FPSO in 2013.

4. Some chemicals on the FPSO were stored next to a gangway on a metal grating with no secondary containment.

5. The methodology for the determination of oil in water content is not according to the environmental certificate.

Observations

1. The biocides XC80105 and XC85293 is not stored with the MSDS present on the FPSO

2. There is the need to improve the water treatment system of produce water as well as inline produced water analyzer

3. TGL is not able to monitor whether their waste minimization targets are met.

4. TGL is not able to monitor its waste manifest to ensure that all parties have the appropriate hardcopy of the manifest

CONCLUSIONS

The audit was carried out in open and transparent manner. That is, in accordance with OECD principle of regulatory transparency:

Policy objectives, including the need for regulation, are clearly defined and effectively communicated to all those concerned.

Regulations should be simple and clear.

Those being regulated must be made aware of their obligations and be helped to comply by enforcing authorities;

Proposals must be published.

Ample time for consultation must be given before decisions are taken.

Regulatory failures must be handled openly by government.

The enterprise, Tullow Ghana Ltd, was very cooperative during the audit. Five (5) non-compliances and four (4) observations were made during the audit. Tullow Ghana Ltd, operators of the Jubilee oil field must send written confirmation by 31st March 2014 that the non-compliances have been rectified.

Source: EPA

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