OISD-GDN- 212
FOR RESTRICTED
CIRCULATION ONLY
GUIDELINES ON
ENVIRONMENTAL AUDIT (INTERNAL)
IN DOWNSTREAM PETROLEUM SECTOR
OISD – GUIDELINES - 212
OIL INDUSTRY SAFETY DIRECTORATE
Government Of India
Ministry of Petroleum & Natural Gas
OISD-GDN-212
FOR RESTRICTED
CIRCULATION ONLY
GUIDELINES ON
ENVIRONMENTAL AUDIT (INTERNAL)
IN DOWNSTREAM PETROLEUM SECTOR
Prepared By
COMMITTEE ON
“GUIDELINES ON ENVIRONMENTAL
AUDIT IN DOWNSTREAM PETROLEUM SECTOR
OIL INDUSTRY SAFETY DIRECTORATE
7th Floor, New Delhi House,
27, Barakhamba Road,
New Delhi - 110001
(ii)
NOTE
Oil INDUSTRY SAFETY DIRETORATE (OISD) publications are prepared for use in the Oil and Gas industry under Ministry of Petroleum & Natural Gas. These are the property of Ministry of Petroleum & Natural Gas and shall not be reproduced or copied and loaned or exhibited to others without written consent from OISD.
Though every effort has been made to assure the accuracy and reliability of the data contained in these documents, OISD hereby expressly disclaims any liability or responsibility for loss or damage resulting from their use.
These documents are intended to supplement rather than replace the prevailing statutory requirements.
(iii)
FOREWORD
Oil industry in India is more than 100 years old handling variety of hydrocarbon material, natural gas, crude oil and petroleum products. With the technological advances and need for transportation of bulk energy carrier and natural gas over the years a variety of practices have been in vogue because of collaboration/association with different foreign companies and governments.
With this in view, the Ministry of Petroleum and Natural Gas in 1986 constituted a Safety Council assisted by the Oil Industry Safety Directorate (OISD) staffed from within the industry in formulating and implementing a series of self regulatory measures aimed at removing obsolescence, , standardizing and upgrading the existing standards to ensure safer operations. Accordingly, the Principal Panelists of OISD were requested to nominate the experienced persons in line for the above functional committee. OISD had constituted the functional committee of expert persons and finalized this draft of guidelines in several periodic meetings and discussions, based on the background note.
Downstream petroleum industry deals with oil refining, gas processing, transportation, pipelines and marketing installation. These activities generate substantial amount of pollutants (solid, liquid and gaseous) which are subjected to treatment to meet the specified standards and if not properly managed shall adversely affect the environment.
Further, to monitor and control the various aspects of environment of petroleum sector the industry has to take appropriate measures through regulations of Government of India and by implementing novel environmental friendly technologies coupled with efficient Environment Management System. In this regard Government of India has issued a gazette notification related to the Environment audit i.e. ENVIRONMENT STATEMENT (as part of Environment audit) 1993 or future amendment to the notification from time to time.
To assist the industry in achieving the above objective, Oil Industry Safety Directorate (OISD), Ministry of Petroleum & Natural Gas, a nodal agency for Petroleum industries has formulated the Guidelines on Environmental Audit (Internal) Downstream Petroleum Sector.
This document was prepared based on the accumulated knowledge and experience of industry members and the various National and International codes and practices. It is expected that these guidelines on environmental audit would be beneficial to user industry.
This document will be reviewed periodically for improvements based on the new experiences and better understanding.
Suggestions from industry members may be addressed to :
The Coordinator
Functional Committee on
“Guidelines on Environmental Audit in Downstream Petroleum Sector”
“OIL INDUSTRY SAFETY DIRECTORATE
7th Floor, New Delhi House,
27, Barakhamba Road,
New Delhi - 110001
(iv)
COMMITTE ON
GUIDELINES ON ENVIRONMENTAL AUDIT (INTERNAL)
IN DOWNSTREAM PETROLEUM SECTOR
------
NAME ORGANISATION
------
LEADER
MOHAN KRISHNAN INDIAN OIL CORPORATIN LTD, MUMBAI
MEMBERS
K. RAMADORAI CHENNAI PETROLEUM CORP. LTD., CHENNAI
K. C. JOHN KOCHI REFINERIES LTD., KOCHI
R. NEWAR NUMALIGARH REFINERY LTD., NUMALIGARH
N. K. BHARADWAJ NUMALIGARH REFINERY LTD., NUMALIGARH
T. K. KUMAR INDIAN OIL CORP. LTD., NOIDA
VINOD MOUDGIL IBP LIMITED, NEW DELHI
C. J. IYER BHARAT PETROLEUM CORPORATION
LIMITED, MUMBAI.
K. SWAMINATHAN INDIAN OIL CORPORATION LIMITED,
NEW DELHI
J. S. SHARMA OIL INDUSTRY SAFETY DIRCTORATE
COORDINATOR
V. K. SRIVASTAVA OIL INDUSTRY SAFETY DIRCTORATE
------
(v)
GUIDELINES ON ENVIRONMENTAL AUDIT (INTERNAL)
IN DOWNSTREAM PETROLEUM SECTOR
CONTENTS
SECTION DESCRIPTION PAGE NO.
1.0 INTRODUCTION 1
2.0 OBJECTIVES OF ENVIRONMENTAL AUDIT 1
3.0 SCOPE 2
4.0 METHODOLOGY FOR ENVIRONEMNTAL AUDIT 2
5.0 USE OF ENVIRONMENTAL AUDIT CHECKLISTS 2
6.0 PREPARATION BEFORE SITE VISIT FOR AUDIT 2
7.0 ENVIRONMENTAL AUDIT 3
8.0 AUDIT REPORTS 4
9.0 FOLLOW UP AND IMPLEMENTATION OF AUDIT RECOMMENTATIONDS 5
ANNEXURE – I
CHECKLIST FOR OIL REFINERIES AND GAS PROCESSING 6-20
ANNEXURE – II
CHECK LIST FOR PIPELINES & MARKETING TERMINALS 21-30
ANNEXURE - III
FORMAT FOR THE ENVIRONMENTAL AUDIT REPORT 31
(vi)
GUIDELINES ON
ENVIRONMENTAL AUDIT (INTERNAL)
IN DOWNSTREAM PETROLEUM SECTOR
31
1.0 INTRODUCTION
The environmental audit is an important tool for checking and verification of environment management plans and provides detailed information on the types, volumes, locations and handling procedures of all materials that have or likely to have potential impact on the environment which determines whether operations are in compliance with statutory requirements.
Environmental audit helps find ways to make the operating facilities more safe sufficient in the use of resources, reduce generation of wastes and adverse impact on the environment to improve the work environment and protect the health of the workers. As a result the organizations gains by lower input cost, environment friendly operations harmonious relations with the local committee as well as the regulatory agencies, goodwill of the customers and enhanced corporate image.
The audit also helps in developing environment management plan which sets the framework for future actions and necessary planning for the resources required for enhanced environmental performance of an organisation.
Therefore, necessary guidelines on the subject have been evolved considering the complexity and hazardous nature of various process and operating facilities of oil refining and gas processing,
transportation, pipeline and marketing installations.
2.0 OBJECTIVES OF ENVIRONMENTAL
AUDITS
While the basic aim of environmental audit is to identify the areas of weaknesses and its strengths, environmental audits are undertaken to meet different specific objectives viz.
1. To identify any design deficiencies and also any weaknesses which might have cropped up during modifications / additions of facilities.
2. To ensure that environmental protection facilities and systems are well maintained.
3. To ensure that operating / maintenance procedures , work practices are as per those stipulated in the manuals and standards to protect the environment.
4. To check whether management of the company is prepared for handling environmental emergencies and an effective environmental management plan is available.
5. To check the compliance of statutory regulations , standards codes etc.
3.0 SCOPE
The scope of these guidelines is limited to downstream petroleum sector facilities namely crude/product pipelines, oil refineries, gas processing plants and marketing installations.
It does not cover the road / rail tanker transportation and retail outlets of oil and gas .
4.0 METHODOLOGY OF
ENVIRONMENTAL AUDIT
Before starting the audit programme the frequency, composition of audit team and duration of audit should be clearly spelt out. As a guideline following is the suggested frequency, size and composition of team and duration of the audit.
4.1 Frequency
The audit should be carried out once every year for all downstream petroleum sector installations including oil refining and gas processing plants, pipeline and marketing terminals.
4.2 Multi Disciplinary Audit Teams
i. The audit should be carried out through multi disciplinary audit teams. The composition of the audit may vary depending of the group and areas to be audited. The team members should have necessary experience and background to undertake in-depth environmental audit for the facilities to be audited. A team of 3 to 4 experienced officers from various disciplines having knowledge of environmental aspects related to downstream petroleum sector.
One of the senior member of the team should be designated as the leader of the audit team .
4.2 Duration
The duration of the audit for oil refining and gas processing should be 4 to 5 days and Marketing and Pipelines should be 1 to 2 days.
5.0 USE OF ENVIRONMENTAL AUDIT CHECKLISTS
A Checklist for facilities of oil refining and gas processing has been prepared and is enclosed at Annexure – I. The same for pipelines and marketing terminals has also been prepared and is placed at Annexure –II . The data in this checklist should be filled by the units / facilities wherever it is applicable for their plant and units.
6.0 PREPARATION BEFORE SITE
VISITS FOR ENVIRONMENTAL AUDIT
Before the audit team visits any particular facility for carrying out the environmental audit it would be essential to study all relevant documents as below:
- Layouts
- P & IDS
- Operating Manuals
- Maintenance/ Inspection Manuals
- Consent letters from Regulatory Authorities.
7.0 ENVIRONMENTAL AUDIT
7.1 Kick off Meeting
The audit shall start with kick off meeting wherein objectives of the environmental audit, its background and modalities shall be very clearly explained to the managers of the site.
7.2 Document Review :
Plant/site managers are need to be informed about inspection and evaluation of documents which will be inspected, verified and observed during the audit. These documents are listed below :
i. Copies of valid latest statutory authorization and consents under air, water and hazardous waste act obtained from the regulatory authorities.
ii. Copy of environmental clearance conditions laid down by MOEF while according environmental clearance.
iii. Copy of NOC and environment clearances obtained for different projects from statutory authorities.
iv. Environmental Impact Assessment report (if not available then status of air water and land environment).
v. Environmental Management Plan
vi. Risk assessment study report and Disaster Management Plan.
vii. Unit Operational manuals and manuals describing different waste water connecting networks and treatment facilities hazardous waste management and storage facilities treated effluent reuse network and other pollution control and monitoring facilities.
viii. Copies of last internal and external environmental audit reports including latest audit findings with their compliance.
ix. Copy of environmental statement submitted to state pollution control board from time to time.
x. Description of pollution control facilities available for air, water and solid waste treatment.
xi. Details of underground / aboveground Oily Water Sewer , Contaminated Rain Water Sewer & Drains along with details of Effluent Treatment Plant.
xii. Details of ambient air quality monitoring being carried out indicating number of stations and parameters being monitored.
xiii. Record of stack flue gas monitoring.
xiv. Copies of status of review of conditions given in various consent / authorisation / clearances / NOCs.
xv. Complaints if any by local residents and other Non Govt. Organizations (NGO) and Govt. bodies.
xvi. Record of Occupational Health & Environmental monitoring.
7.3 Site Visit / Verifications
Discussions with concerned operating personnel should be carried out during audit with the following point of view:
i. Review of processing facilities should be carried out and records should be evaluated for verification of different material balances including sources and extent of pollution generation.
ii. Review of Pollution control and monitoring facilities such as effluent treatment plant, Amine Treating Unit / Sour Water Stripper Unit /Sulfur Recovery Unit/ or nay pollutant reducing units and ambient air quality monitoring stations should be visited with a view to verify the performance of these units.
iii. Statutory Aspects and compliance should be verified.
iv. Critical review and observation on work place environment should be carried out.
v. Observation on house keeping and green belt should be made.
vi. Resource conservation efforts being made by the plant authorities should be reviewed .
vii. Calibration record of monitoring and other equipment should be reviewed.
viii. Adequacy of laboratory equipments, test methods, procedures and record keeping should be reviewed.
ix. Preparedness for oil spill response management should be reviewed.
x. Adequacy of disaster management plan and preparedness should be reviewed.
xi. Training procedures and general competence and awareness of concerned personnel should be reviewed and evaluated.
.
7.4 Close -off Meeting
Team should organize close off meeting wherein leader or his nominee should present the broad findings of the audit to the management of the company.
8 PREPARATION OF AUDIT
REPORTS
The audit team should prepare the environmental audit report which should contain observations and recommendations including the brief of modalities adopted for conducting the environmental audit before finalising the report the team should give a presentation to the operating / management personnel of the organisation which has been audited. The report should be in the format given in the Annexure – III.
9 FOLLOW UP AND IMPLEMENTATION OF THE AUDIT RECOMMENDATIONS
Appraisal of audit report shall be submitted to the management of the plant along with action plan with time frame for further improvement and follow up by the management of the company should be done regularly to assess the status of implementation of the recommendations and quarterly compliance report should be submitted to auditors.
31
ANNEXURE – I
CHECK-LIST
FOR
ENVIRONMENTAL AUDIT
FOR DOWNSTREAM PETROLEUM SECTOR
(Data to be filled by Refineries / Gas Processing Units
wherever and whichever is applicable for their facilities)
NAME OF THE UNIT / FACILITY ------
TYPE OF THE UNIT / FACILITY Refinery / Gas Processing
AUDIT FOR THE YEAR ------
DESIGN CAPACITY FOR
THE AUDITED YEAR ------
ENVIRONMENTAL STATEMENT ------
SUBMITTED TO STATE POLLUTION
CONTROL BOARD FOR THE YEAR
PART A : WATER ENVIRONMENT
A.1 / RAW WATER INVENTORY / DESIGN NORMS / ACTUAL / REMAKRSA.1.1 / RAW WATER SOURCE
River / Municipal / Borewell
A.1.2. / RAW WATER INTAKE, M3/HR
(MIN.)
(MAX.)
(AVG.)
(DESIGN)
A.1.3 / RAW WATER TREATMENT
SCHEME
A.1.4 / RAW WATER BALANCE
- INTAKE M3/HR
- OUTPUT MR/HR
- (% AGE OF INTAKE)
- BLOW DOWN & LOSSES M3/HR
(% AGE OF INTAKE)
Please attach a chart for water balance. / DESIGN NORMS / ACTUAL / REMARKS
A.1.5 / TREATED WATER DISTRIBUTION
- PROCESS UNITS, M3/HR
- COOLING TOWER MAKE UP M3/HR
- DRINKING WATER M3/HR
- DM PLANT FEED M3/HR
- FIRE WATER MAKE UP M3/HR
- OTHERS (SPECIFY) M3/HR
- LOSSES M3/HR
- CYCLE OF CONCENTRATION IN COOLING TOWER / DESIGN / ACTUAL / REMARKS
A.2 / EFFLUENT INVENTORY
A.2.1 / QUANTITY GENERATED, M3/HR
(DRY WEATHER FLOW)
MIN
MAX.
AVG.
A.2.1.1 / PLANT WISE BREAK UP (AVG.) DRY WEATHER FLOW)
- TANK FARM
-OM&S
-PROCESS UNITS
- DESALTER BRINE
- SPENT CAUSTIC
- SWS DRAINS
FLOOR WASHINGS
C/T BLOWDOWN
THERMAL POWER STATIONS
BOILER BLOWDOWN
DM PLANT ( NEUTRALISED EFFLUENT)
WORKSHOP
LABORATORY
COKE CUTTING
SANITARY EFFLUENT
- FROM PLANT
- FROM TOWNSHIP
OTHERS (PLS. SPECIFY)
TOTAL QUANTITY M3/HR
A.2.2 / SEGREGATION, BUILT IN
(a) BETWEEN OIL CONTAMINATED & (NON CONTAMINATED STREAMS
(SPECIFY)
(b) BETWEEN HIGH & LOW TDS STREAMS (SPECIFY)
COMMENT ON SEGREGATION / TREATMENT / REUSE / DISPOSAL INFRASTRUCTURE & PRACTICES. / COLLECTION / TREATMENT / REUSE/
DISPOSAL
A.2.3 / DETAILS OF ETP SCHEME WITH WRITE UP AND FLOW DIAGRAM / DESIGN / ACTUAL OPERATIONS / REMARKS
A.2.4 / ETP PERFORMANCE
(AVG.QUALITY,MG/LT)
QUALITY AT INLET TO ETP
QUALITY AT OUT LET OF PRE TREATMENT
QUALITY OF OUTLET OF CHEM ICAL TREATMENT
QUALITY OF OUTLETOF BIO TREATMENT
QUALITY OF OUTLETOF TERITIARY TREATMENT
QUALITY OF EFFLUENT AT FINAL OUTLET
MINAS REQUIREMENTS
ANY DEVIATIONS WITH RESPECT TO MINAS
“*” DENOTES “In PPM / PH OIL* / SULPHIDE* PHENOL* / BOD* TSS*
A.2.5 / QUALITY ASSURANCE OF MONITORED DATA
pH
OIL
PHENOL
SULPHIDE
BOD
TSS
COD
HEAVY METALS ETC. / METHOD
PRESCRIBED / OF TESTING
ACTUALS / REQUENCY OF QA CHECKS* / REMARKS
A.2.6 / TREATED EFFLUENT DISCHARGE POINT / CONSENT/ DESIGN / ACTUAL / REMARKS
A.2.7 / TOWNSHIP EFFLUENT DISCHARGE POINT / DESIGN / ACTUAL / REMARKS
A.2.8 / STORM WATER DISCHARGE POINT / DESIGN / ACTUAL / REMARKS
A.2.9 / QUALITY OF RECEIVING WATER BODY
UPSTREAM OF DISCHARGE POINT
DOWNSTREAM OF DISCHARGE POINT
(INCLUDE PARAMETERS AS PER NOTIFICATION GSR 422(E) DATED 19.5.93
A.3 / COMPLIANCE OF STANDARDS / CONSENT
A.3.1 / CONSENT FOR EFFLUENTDISCH. VALID TILL
A.3.2 / EFFLUENT DISCHARGE QUANTITY M3/HR / AS PER CONSENT / ACTUAL / REMARKS
A.3.3 / PERFORMANCE BASED ON LOAD BASED STIPULATIONS (Kg per 1000 tons of crude processed)
OIL
PHENOL
SULPHIDE
BOD
TSS
OTHER PARAMETERS, IF ANY AS PER CONSENT (PLEASE LIST) / AS PER CONSENT / ACTUAL / REMARKS
A.3.4 / NO. OF DAYS OF NON-COMPLIANCE AND REASONS FOR SAME
A.3.5 / CORRECTIVE ACTION TAKEN
A.3.6 / RESULTS AFTER CORRECTIVE ACTION
A.4 / DETAILS OF STORM WATER COLLECTION SYSTEM
B. AIR ENVIRONMENT