The Company has presented plans to address the identified impacts, thereby ensuring that the proposed project will, upon the implementation of the specific actions agreed, comply with the environmental and social requirements: 1) the host country laws and regulations; 2) the IFC environment and social Performance Standards; and 3) the applicable and relevant IFC environmental, health and safety guidelines. Where the Company is not the operating partner in any particular operation or activity, the Company will use its reasonable endeavors to bring into effect the aforementioned measures by exercising its rights under the relevant petroleum agreements and joint operating agreement measures. The information about how the potential impacts will be addressed by the Project is summarized in the paragraphs that follow. Further information is provided in the attached documentation. All references in this document to the Project taking any action are to be construed as references to Kosmos using its reasonable endeavors, to the extent possible by exercising its contractual voting rights under the joint operating agreement, to ensure that the Project takes such action.
PS 1 – Social and Environmental Assessment and Management Systems
Assessment: Phase 1 of the Jubilee Field, in which Kosmos is a partner, has an Environmental Impact Statement, accepted by the Ghana Environmental Protection Agency on November 28, 2009, an Environmental Management Plan, and a Public Consultation and Disclosure Plan that addresses the social aspects of the Jubilee Project raised during public consultations. The Jubilee Field Phase 1 is currently operating under a production-phase Environmental Permit, issued on November 26, 2010.
Kosmos’s exploration and appraisal operations outside of the Jubilee Field are the subject of the Preliminary Environmental Report for the West Cape Three Points 2011 Exploration and Appraisal Program Offshore Ghana, dated November 2010. This Preliminary Environmental Report includes a review of these operations in light of the relevant WBG EHS Guidelines.
For all projects supported by IFC funds (‘Applicable Projects’), the Kosmos Corporate Health, Safety, Environment, and Community Management System (‘HSEC MS’) will require that the review of the project be based on the Performance Standards and relevant WBG EHS Guidelines. At a high corporate level, Kosmos will review the social and environmental assessment (SEA) documents. Where there may be gaps between the requirements of the Performance Standards and the Applicable Project, Kosmos will prepare a supplemental environmental and social action plan to bring the project into line with Performance Standards and Guideline requirements. Where Kosmos is not the operator of an Applicable Project, it will use reasonable endeavors to direct the application of the IFC’s Performance Standards to the SEA. For each Applicable Project, Kosmos will also develop an environmental and social management plan (‘ESMP’) that incorporates all plans and procedures identified during the SEA. The content of the ESMP will vary according the circumstances of the individual project, but will contain at a minimum, an emergency response plan (ERP), a spill control and response plan (SCRP), a wasted management plan (WMP), and a stakeholder engagement plan (SEP).
Management System: Kosmos Energy is developing a Corporate Health, Safety and Environment Management System. The corporate management system requires the development of country-specific HSE management systems based on the corporate management system. The country-specific management system may also take into consideration specific expectations for particular countries where the operating environment requires these. The corporate management system has ten elements: policy & leadership, safety & health, risk management, incident reporting & investigation, crisis preparedness, environmental protection, community relations, legal requirements, and continuous improvement. As part of the Project, Kosmos will incorporate the Performance Standards into the corporate management system. Given that community relations is already part of the management system, and in recognition of the social requirements under the Performance Standards, IFC has recommended that the name be changed to the Kosmos Corporate Health, Safety, Environment, and Community Management System
Training: To ensure that environmental and social risk management by Kosmos’s affiliates in individual countries is informed by the Performance Standards and the WBG EHS Guidelines, Kosmos will develop and implement a training plan on the Standards and Guidelines.
Stakeholder engagement: For each Applicable Project, Kosmos will have in place a stakeholder engagement plan, which will include provisions for the disclosure of the major SEA documents associated with the project and a defined grievance mechanism. For the Jubilee Field, the Unit Operator has a Public Consultation and Disclosure Plan that includes disclosure of the EMP for the project and a grievance mechanism. Kosmos has a corporate social responsibility (CSR) plan that includeds stateholder engagement and is continuously updated.
PS 2 - Labor and Working Conditions
Working Conditions: In Ghana, the Company has a human resources policy that recognizes the rights of workers under Ghanaian law, including hours of work, overtime arrangements and compensation, policies on leave, principles of non-discrimination and non-discrimination, and rights to work organization and collective bargaining. The human resources policy will also spell out a worker grievance mechanism that will be accessible, transparent and prompt. Kosmos will develop similar policies, based on host country law, for Applicable Projects in other countries.
Worker Health and Safety: In all projects, Kosmos ensures the appropriate use of personal protective equipment for different areas of operation, identification of hazards and measures to reduce potential injuries to workers, labeling of different materials according to their hazards, training of workers, documentation and analysis of incidents and accidents, and implementation of an emergency response plan to protect workers, as required by PS 2.
In Ghana, four specific plans are of primary relevance to occupational safety: Mobile Offshore Drilling Unit (MODU) Operation Bridge Document, Emergency Response Plan (ERP), Safe Work Permit, and Hazardous Communications Program. The MODU Operation Bridge Document synthesizes the existing environment, health, and safety (EHS) plans of Kosmos and the contractors’ EHS plans. The resulting Bridging Document provides a uniform framework for operations to which all must adhere. The ERP, among other objectives, protects the lives of personnel. It includes a Medical Evacuation Plan in case of serious injury on the off-shore facilities. The Safe Work Permit applies to contactor activities on the MODUs, FPSO and shuttle transport. The Safe Work Permit authorizes a type of work in a specific location - e.g., confined space - following a hazards assessment and identification of protective measures. The Hazardous Communication Program addresses expectations, conditions, and procedures applicable to working with hazardous chemicals on Company vessels or in Company facilities. It includes reviewing new chemicals in the work place, maintaining an inventory list and material safety data sheets for hazardous chemicals, and providing information to workers and managers on those chemicals in a multiple-employer worksite.
PS 3 – Pollution Prevention and Abatement
Well Design and Operations: Kosmos has reviewed the operations of its deep water drilling contractor in Ghana based on the requirements of the US Bureau of Ocean Energy Management. The review included: inspection of surface and subsurface well control equipment to ensure full design capability and proper maintenance; establishment of consistency between design/documents and the actual equipment; confirmation of personnel certifications with respect to well control equipment operation and that all personnel involved in well operations are trained for and capable of performing their tasks under both normal drilling operations and emergency well control operations; check of hot stab functions on sea floor blow-out preventer (BOP); review of all shutdown and emergency positioning procedures related to emergency well control operations; and, inspection of life saving and firefighting equipment for compliance with US requirements, including crew familiarity with the equipment. All key decisions about well casing, cementing, and testing are made jointly between Accra and Kosmos headquarters in Dallas. Additionally, Kosmos has hired one third-party engineering firm to review well designs and model well control situations based on that design, and another third-party engineering firm to review and validate casing and cementing criteria.
Finally, Kosmos is an active participant in the International Association of Oil & Gas Producers (‘OGP’) Global Industry Response Group (GIRG). Key GIRG recommendations include: (i) promotion of human competency management systems and of a culture of adherence to standards and procedures; (ii) recognition of national and international standards as a baseline for industry improvements; (iii) improved technical and operational practices for the overall governance of well construction; and (iv) recommendation for a two-independent-and-physical-barrier policy during the life of the well, with a BOP as one barrier during the drilling, completion and abandonment phases of a well. To ensure that Kosmos’s operations, particularly those in deep water, are using good international industry practice (GIIP), Kosmos will review its well control designs and procedure at appropriate times, but not less than once a year, to consider possible updates based on GIIP.
Atmospheric Emissions and Noise: Dilution and dispersion of air pollutant emissions from the mobile offshore drilling units (MODUs) are expected to be rapid and the potential effects on ambient air quality to be limited to a short distance from the emission sources. No detectable effects on ambient air quality onshore in Ghana and Côte d’Ivoire are expected considering the relatively limited amount of air pollutants emitted and the distance from shore. The Project will ensure that offshore facilities and support vessels will comply with the requirements of MARPOL Annex VI (relevant to sulfur oxide and nitrogen oxide emissions from ship exhausts and diesel engines, prohibition of deliberate emissions of ozone-depleting substances, and prohibition of the incineration of certain products on board) and relevant IFC guidelines for small combustion sources, minimization of venting and flaring (consistent with the Global Gas Flaring and Venting Reduction Voluntary Standard) and minimization of fugitive emissions.
Noise: The MODUs and vessel operations will generate noise into the marine environment with potential impacts on biota. The low-frequency noise levels from offshore drilling and production activities are relatively weak in intensity, but they can be detected and produce some behavioral responses (e.g., avoidance) in marine mammals, particularly baleen whales. However, these levels are much lower than those known to cause hearing loss, discomfort, or injury. Marine mammals do often congregate around offshore platforms and become accustomed to predictable noise, as in the case of ships following a shipping route and stationary sources. Routine inspection and maintenance of engines, generators, and other equipment, noise and air emissions monitoring and use of low-sulfur diesel fuel will be defined as part of the Project’s environmental monitoring program.
Greenhouse Gas Emissions: The Company is monitoring CO2 emissions under the requirements of Ghanain environmental permit. The project is estimated to emit 135,000 tonnes per year of CO2.
Drilling Fluids and Cuttings Management: Both water-based fluids (WBFs) and low-toxicity mineral oil based fluid (LT-MOBFs) are used during the drilling of production and injection wells off shore. WBFs will be used in the upper sections of the well bore, down to approximately 500 m below the mudline. LT-MOBFs will be used to drill the mid- and lower well sections to the bottom of each hole (approximately 2,500 m). The Project will ensure that LT-MOBFs will not be discharged and they will be recovered and returned to the vendor for recycling.
The Company evaluated feasible alternatives for the disposal of spent drilling WBFs and all drilled cuttings as part of the development of the Jubilee Field, including disposal through (i) injection, (ii) containment and transfer to shore for treatment and disposal, and (iii) discharge to sea. Discharge of drilled cuttings continuously to sea during drilling, both with WBFs and with LT-MOBFs, is considered to be the only present alternative, since water depth precludes injection of muds and cuttings, and environmental impacts associated with barging cuttings to shore are estimated to be greater than discharging. Drilling discharges for each well are estimated to include 1,014 bbl (161.1 m3) of WBFs, 1,497 bbl (237.8 m3) of WBF cuttings, and 1,478 bbl (235 m3) of cuttings with adhering MOBF. Kosmos developed a cutting dispersion model for two drilling sites, Mahogany-4 and Mahogany Deep 2 and applied the model to its current drilling at West Cape Three Points. The modeling predictions suggest that a small area near the discharge point would be intermittently exposed to turbid water. The maximum extent of the turbid plume, defined as a concentration of 0.1 mg/L of suspended solids, is predicted to be approximately 1.35 km2 for the Mahogany-4 well and 1.44 km2 for the Mahogany Deep 2 (formerly Exp-1) well. The value of 0.1 mg/L is a conservative threshold; the practical lower limit of the total suspended solids (TSS) method used for the Jubilee Field EBS is 4 mg/L. Actual TSS concentrations measured during the EBS ranged from 6.39 to 45.23 mg/L. The modeling also showed that hazardous concentrations of bentonite and barium, two components of the drilling fluids would not occur and that initial concentrations should disappear within a few minutes of disposal. Dispersion should also minimize benthic impacts. The results show that although a thin layer of cuttings and drilling fluids would be distributed over a broad area, only a small area (0.50 hectares or less around each wellsite, for a total of 1.5 hectares for the three drilling sites) would receive deposition thick enough, 54.0 mm, to cause burial impacts to 50% or more of the benthic species. Even in these areas, the disturbed benthic communities are expected to re-establish themselves within a few years. A geohazards survey has been conducted, which indicates no sensitive benthic habitats (hard bottom areas or chemosynthetic/seep areas) are likely to be present around the well sites.
A cuttings dryer will be used to minimize retention of MOBF to the cuttings to a level below 5%. The levels are above the IFC guideline on oil content of cuttings disposed to the sea, though the IFC guideline is not achievable through available technology. The IFC Guideline specifically says that an exception to the guideline is acceptable where the project’s environmental documents provide a justification. Because the alternatives are not feasible or may cause greater environmental harm, both the EIS for the Jubilee field and the Preliminary Environmental Report for Cape Three Points provide such justifications. The methods and procedures will be prepared taking into account cuttings and fluid dispersion, chemical used, environmental risk, and necessary monitoring.
A similar approach will be taken in other offshore Applicable Projects. Where feasible Kosmos will seek onshore disposal, as implied by the IFC EHS Guideline. But it will have to evaluate drill cuttings disposal for other projects based on an analysis of the options for disposal.
Waste: Waste streams associated with Kosmos’s offshore drilling activities will be sanitary and domestic wastes, bilge water, deck drainage, ballast water, cooling water, and solid waste.
Sewage will be treated using marine sanitation devices that will produce an effluent with a minimum residual chlorine concentration of 1.0 mg/L and no visible floating solids or oil and grease. Treatment sludge will be transported to shore for disposal at an approved facility. Food waste will be ground prior to discharge, in accordance with MARPOL requirements. The MODUs include design features that will contain runoff and prevent oily drainage from being discharged, diverting potentially contaminated deck drainage collected by an open drain system to oil water separation systems. Project’s operations will only allow for discharge of water meeting the criteria of 42 mg/L and 29 mg/L oil, maximum weighted daily and monthly averages respectively, and will not allow discharge of free oil in deck drainage that would cause a film, sheen, or discoloration of the surface of the water, or a sludge or emulsion to be deposited beneath the surface of the water. The drain system on the processing deck will also include a closed drain system, collecting oily fluids, which will be sent to a cargo tank.
All solid waste generated during drilling will either be incinerated aboard the MODUs or transported to shore by service vessels for disposal at approved facilities. Disposal of trash and debris in the ocean will be prohibited consistent with MARPOL requirements.
For all Applicable Projects, whether onshore or offshore, Kosmos will adopt and implement (and will require its contractors to adopt and implement) a Waste Management Plan that contains a clear waste tracking mechanism to track waste consignments from the originating location offshore to the final waste treatment and disposal location. Efforts will be made to eliminate, reduce, or recycle wastes at all times. The Project will ensure that all waste materials will be segregated offshore into non-hazardous and hazardous wastes at a minimum, and shipped to shore for re-use, recycling, or disposal, as needed, and that a Hazard Communication (HAZCOM) Program will be implemented to handle all hazardous chemicals that are produced, used, or stored aboard Project vessels or facilities, consistent with IFC guidelines. Transportation of hazardous material will comply with United Nations regulations and specific training will be provided to all personnel.
Emergency Preparedness and Response: As part of its operations in Ghana, Kosmos has developed an Emergency Response Plan (ERP) that includes procedures for medical evacuation, search and rescue, fire prevention and protection, environmental emergencies, and other incident responses.
A Spill Containment and Response Plan (SCRP), considering potential spill scenarios, will be developed for each Applicable Project and will be structured consistent with the IFC guidelines. As part of its oil spill response planning offshore of Ghana, Kosmos has developed oil spill trajectory uncertainty maps for its drilling operations. Depending on the time of year, an oil spill could move toward Cote d’Ivoire, directly toward the nearest shore, or toward Nigeria. These maps, along with the identification of sensitive habitat, e.g., turtle nesting areas, were used to identify shorelines at risk in the event of a spill and to gauge the time needed for a spill to reach the coast, as an aid in response planning. Because some potential scenarios indicate a spill reaching the coast in approximately 14 hours, Kosmos has entered into an agreement to position a large amount of response equipment in-country to facilitate a quick response in the unlikely event of a spill. Kosmos has an Oil Spill Response Plan (OSRP) that describes detailed procedures for responding to a spill, including: (i) procedures for assessing and monitoring a spill and predicting spill movement; (ii) identification of receptors at risk; (iii) shoreline protection methods; (iv) 0il and debris removal and disposal procedures; (v) dispersant use plan; (vi) spill reporting and notification procedures; (vii) response team organization; (viii) available equipment, supplies, and services; and (ix) Training and exercise procedures. The OSRP provides detailed information about three levels response from local (Level 1) to national/international (Level 3). Kosmos is an associate member of OSR and has access to their equipment, expertise, and resources in the event of a spill. The response to all Tier 1 spills will remain the responsibility of Kosmos. In Tier 2 and 3 spill situations, the response strategy set out in the OSCP aligns with the Ghana National OSCP and complies with its requirements. The intention is that in any major spill situation there would be cooperation among Kosmos, other offshore oil and gas operators in the region, and the Government of Ghana to ensure an effective spill response. In respect to the capabilities of the Jubilee Field Unit Operator, one of the possible sources of support, there is a fully developed Incident Command Center; oil spill response equipment and other resources to handle Tier 1- and 2- level responses up to Tier 3 (effectively Tier 2 plus); and a multipurpose vessel being deployed with four rigid inflatable boats (RIBs) to assist with spill control activities. The Ghana Incident Management Plan (GIMP), which involves elements of the Government of Ghana, has been developed and is being implemented and revised on the basis of drills and exercises.
Kosmos has also undertaken additional steps towards a potential response to an oil spill. In addition to participating in GIRG Core Areas 2&3, which cover capping & containment and spill preparedness & response respectively, Kosmos has been working with Tullow and Anadarko, two other Jubilee Partners, on a Mutual Assistance Agreement (MAA) for the Gulf of Guinea that is similar to the MAA in the Gulf of Mexico in case of the need for a relief well. They are also seeking an Emergency Resource Allocation Agreement for Ghana with the Jubilee Partners and others.
PS 4: Community Health, Safety and Security
Safety and Security: The Project will have 500 m exclusion zones around its drilling ships (MODUs). These zones will protect other vessels from collision with the project vessels and fouling the anchor lines. Because the project is in deep water, the possible fouling of flow lines by nets and other fishing gear is considered unlikely. Small fishing canoes and their nets run greatest risk with MODUs that use a global positioning system and propellers to maintain constant repositioning because the nets and boats can be caught by the propellers. Kosmos’s current drilling operation use a MODU that is anchored to the sea bottom rather than a constant repositioning system. All the same, small canoes pose other operational risks and need to be kept at a distance. MODUs can act inadvertently as fish attracting devices to which fishing canoes can, in turn, be attracted. Maintenance of these safety zones will come through a combination of educating fishing communities onshore and intervention at sea around stationary vessels. The at-sea intervention will, in the first instance, be carried out by the Project’s own vessels in a non-threatening way. Direct intervention by Ghanaian law enforcement may be necessary where a vessel persists in encroaching into a safety zone and approaching a Company vessel. The Ghanaian Navy, which has primary responsibility for enforcement of the zones, has received training on the US-UK Principles on Security and Human Rights as part of the Jubilee project, and will use these principles in the enforcement of the zones.
PS 5: Land Acquisition and Involuntary Resettlement
Currently, PS 5 does not apply to any Kosmos operations or activities. In Ghana, exploration activities are located in deep water, off shore. The impact on traditional fishing resources is minimal. Some on-shore exploration activities are expected with Kosmos’s licenses in other parts of West Africa. In general, exploration activities may be located away from communities and have limited impacts. The applicability of PS 5 may become more prominent if exploration moves towards production in any on-shore discoveries in Kosmos’s other West African licenses.
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management
There are no marine protected areas at or near the Jubilee Field. Marine waters offshore Ghana are within the Central West African upwelling zone, with a major upwelling season from July through September and a minor upwelling season from December through March. Upwelling of cool, nutrient-rich water results in enhanced primary production, and therefore a situation conducive to high productivity for fish resources. Approximately 480 fish species are reported to be native to the coastal areas of Ghana, out of which approximately 180 are associated with deepwater habitats. Over 300 different species of commercially important fishes are also reported for Ghana. The upwelling zone at its peak approximately coincides with the Ghana Exclusive Economic Zone (EEZ), of which the area directly affected by Jubilee Field Phase 1 Development (approximately 64 km2) represents 0.03%. Although the Project’s direct footprint can be seen as negligible with respect to the extent of upwelling and its impact on fish resources, potential impacts on are managed as described in PS 4 and the Environmental Monitoring Plan for the Jubilee Field includes sampling fish every two years.
Soft bottom benthic communities are expected to be consistently present in the Project affected area. Although extensive hard bottom areas occur offshore of Ghana, a geohazards indicated there are no hard bottom features. The same geohazard study did not identify any seabed features (e.g., mounds, faults, craters, wipeout zones) that are known to be associated with high-density chemosynthetic sites. Therefore, the presence of chemosynthetic communities is not expected, although they have been reported in the region offshore of Ghana. The Environmental Baseline Study for the Jubilee Field Phase 1 development included substrate-living, benthic fauna sampling in portions of the West Cape Three Points, Deepwater Tano Blocks, and some shallower stations on the continental shelf. A total of 253 taxa were identified from15 box core samples. The samples low densities of fauna living in the soft bottom substrate and having most taxa represented by a few individual, i.e., a low level of biodiversity.
The regional waters are known to support a diverse marine mammal fauna, including baleen whales, toothed whales and dolphins. As part of the Jubilee Field environmental monitoring program, a marine mammal observer (MMO) program was initiated. During 2010, MMOs recorded 35 sightings of dolphins, 19 sightings of whales and 13 sightings of turtles. Very large pods of dolphins with over 100 individuals were observed in the field on a number of occasions. Whale sightings varied with species, with large pods of pilot whales observed as well as a number of single and paired animals (i.e., humpbacks). No evidence to date indicates that the offshore exploration and production areas are critical habitat for marine mammals
As noted during the appraisal of the first Kosomos project, five species of sea turtles have been recorded in the Gulf of Guinea, including along the 70% of the Ghanaian coastline that is suitable for turtle nesting, with 80 km that are densely nested. Two species, hawksbill and leatherback turtles, are classified as Critically Endangered by the IUCN Red List, and three species, green, loggerhead, and olive ridley turtles - the latter being the most common in Ghana - are Endangered. The nesting season is from August through March, with a peak from September through January. Thirty-six sites, including five along the coast, have been designated as Important Bird Areas (IBAs) in Ghana. The closest IBA to the Project area is the Amansuri wetland, which is located west of Takoradi. The wetland is not situated along the direct line of flight for helicopters supporting Project’s operations. Project activities will not directly affect nesting sites and other sensitive coastal areas, including the IBAs, and the risk of accidental oil spill impacts to these sites will be minimized and mitigated through prevention and response measures developed in the Oil Spill Response Plan, as discussed under PS 3.
