We take a systematic approach to the management of environmental issues in Georgia.
We carried out thorough Environmental and Social Impact Assessments (ESIA) when first developing the BTC and SCP pipelines, which resulted in commitments in an environmental and social action plan.
We have recently completed an ESIA for the SCPX project. These processes identify potential impacts and mitigations and necessitate a rigorous approach to action tracking and closure.
Our environmental management system is based on the ISO 14001 ‘plan-do-checkact’ cycle, which is fully incorporated into the OMS improvement cycle.
The effectiveness of our environmental management is also assessed during annual reviews by the independent environmental consultant appointed on behalf of the original project lenders.
Responsibility for implementing and maintaining the EMS rests with the leadership team.
The Georgia compliance and environment team is responsible for EMS co-ordination and maintenance, while the regulatory compliance and environment director oversees the system across the BP regional business. Site managers are responsible for its maintenance in the field.
In everything we do we aim to avoid, minimize or mitigate environmental impacts.
We continue to work to raise contractors’ awareness of environmental matters and to help align all projects with the requirements of our environmental management system.
We use an environmental risk assessment tool for individual projects and modifications to give ourselves assurance that requirements are being met in the field.
We carried out more than 50 site inspections in 2014 and reviewed contractor project documentation such as pre-construction surveys that include environmental site assessments.
We obtain site completion reports that show how environmental requirements have been addressed.
We are continually working to find innovative and efficient ways to reduce and manage waste.
We have sought to reduce hazardous waste by buying modern equipment for waste processing and have been putting waste products and substances to good use – such as using them as a source of energy.
The majority of hazardous waste from our activities, such as oily rags or sludge, has been collected, compacted and stored at a central waste accumulation area at PSG1 on the BTC pipeline.
Historically, hazardous waste was prepared for export to EU-compliant facilities outside Georgia because local recycling companies were notable to ensure its safe disposal.
We have now evaluated Georgian operators who could operate an EU compliant hazardous waste incinerator, and are looking to work with a local company to do this.
The establishment of a facility of this type would represent a significant step forward in the development of national waste management capability.
We have continued to recycle paper, plastic and metal, working with Georgian companies that now have the capability to recycle different types of waste products.
Our incident management system includes commitments related to responding to an incident were wildlife suffer from the effects of oil.
We have built a wildlife response centre adjacent to the oil spill response base at PSG1 and ran an emergency response exercise on wildlife protection in 2014.
The wildlife rehabilitation centre is supplied with equipment in line with best international practice.
To test our preparedness to respond to an incident involving oiled wildlife, we have undertaken three sets of training for volunteers, delivered by International Bird Rescue and the Oil Spill Training Company Ltd.
Training has been provided to representatives from non-governmental and state institutions, local certified veterinarians and volunteers.
With the support of BP personnel, 36 volunteers participated in training at locations near the Jandari and Tsalka lake shorelines, chosen because of their ecological sensitivity.
The initiatives tested our wildlife response preparedness and included identifying baselines, examining potential environmental impacts, and assessing different tiers of possible response.
Spill behaviour was modelled, using geographic information systems, and communication plans were tested.
A theoretical element was complementedby tests of the wildlife response equipment stocked at the center to assess approaches to mobilization, deployment and operations.
The exercises were concluded with analysis of lessons learned. Findings and recommendations were shared among the participants.
In line with the three-year review cycle, the environmental management system was independently audited in 2014. The management system was found to be effective with no non-conformities issued.
We maintain comprehensive systems to stay compliant with applicable HSE requirements.
Because of significant change in local environmental legislation in recent years, we undertook an extensive review of local environmental regulatory requirements in 2014.
As a result, we identified specific tasks which need to be carried out by operations and environment staff to make sure we remain compliant.
These items are maintained in a compliance task manager database, which enables required actions to be tracked.
The development and early implementation of the SCPX project has been a multi-disciplinary effort that incorporates lessons learned from past projects and operations in Georgia.
Productive cooperation continued with project staff through the review of the ESIA addendum and close coordination on waste management.
The 16th annual post-financial audit of the independent environmental consultant acting on behalf of BTC lenders was completed in Georgia in 2014.
These audits monitor compliance with BTC environmental and social commitments. No non-compliances were identified.
We work with contractors to try to make sure they meet our environmental standards. In 2014, we included detailed clauses within our contractual terms and conditions relating to environmental management.
Provisions covered topics such as waste management, flora and fauna, air and water quality, and ecological management.