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200 20 SH DEC 00014_00

Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

COMPANY Contract No.: LTC/C/NFP/5129/20 CONTRACTOR Project No.: 033764

ASSET

: NFPS

Document Title

:

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

COMPANY Document No.

:

200-20-SH-DEC-00014

CONTRACTOR Document No.

:

033764-E-D00-18-SPM-LP-S-00002

Discipline

: HSE&Q

Document Type

: DESIGN CRITERIA

Document Category/Class

:

1

Document Classification

:

INTERNAL

00 18-JUN-2025 Approved for Construction Rama Krishna K

B

06-MAR- 2025

Issued for Approval

Rama Krishna K

Environmental Specialist

Jerine Baby/ Balasubramani P Jerine Baby/ Balasubramani P

LOSPE Lead

Reetesh Kumar Jha Reetesh Kumar Jha Engineering Manager

REV.

DATE

DESCRIPTION OF REVISION

PREPARED BY

REVIEWED BY

APPROVED BY

Saipem S.p.A

www.saipem.com

THIS DOCUMENT IS PROPERTY OF QatarEnergy LNG. THIS DRAWING OR MATERIAL DESCRIBED THEREON MAY NOT BE COPIED OR DISCLOSED IN ANY FORM OR MEDIUM TO THIRD PARTIES, OR USED FOR OTHER THAN THE PURPOSE FOR WHICH IT HAS BEEN PROVIDED, IN WHOLE OR IN PART IN ANY MANNER EXCEPT AS EXPRESSLY PERMITTED BY QatarEnergy LNG.

200-20-SH-DEC-00014_00

Page 1 of 31

Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

REVISION HISTORY

Revision

Date

Revision Description

A1

A

B

00

06-JAN-2025

Issued for Inter Discipline Check

22-JAN-2025

Issued for Review

06-MAR-2025

Issued for Approval

18-JUN-2025

Approved for Construction

HOLDS LIST

Hold No

Hold Description

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

TABLE OF CONTENTS

1

1.1

1.2

2

2.1

2.2

3

4

4.1

4.2

5

6

INTRODUCTION … 5

Project Objective … 5

Project Scope … 5

DEFINITIONS AND ABBREVIATIONS … 8

Definitions … 8

Abbreviations … 9

REGULATIONS, CODES AND STANDARDS … 12

PURPOSE & SCOPE OF WORK … 16

Purpose … 16

Scope of Work … 16

GENERAL ENVIRONMENTAL PRINCIPLES … 17

ENVIRONMENT MANAGEMENT CRITERIA … 18

6.1

Air Emission Sources … 18

6.1.1 Continuous Emissions … 18

6.1.2

Intermittent emissions … 18

6.1.3 Emissions from Abnormal Operation/Emergency … 18

6.2

6.3

6.4

6.5

6.6

6.7

6.8

6.9

Ambient Air Quality … 18

Stack Emissions … 19

Ozone Depleting Substances … 19

Flaring / Venting … 19

Fugitive Emissions … 21

GHG Emissions … 21

Vessel Emissions … 21

Effluent Discharges … 22

6.9.1 Hydrotest Water … 22

6.9.2 Deck Drainage … 23 6.9.2.1 Open Drain System … 23 6.9.2.2 Overboard Discharge … 24 6.9.2.3 Closed Drain System … 24 6.10 Noise… 24

6.11 Lighting … 25

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

6.12 Chemical Management … 26

6.13 Solid Wastes … 27

6.14 Hazardous Waste … 28

7

8

9

MONITORING … 29

EMERGENCY EVENTS … 30

ENVIRONMENTAL COMPLIANCE REGISTER … 31

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

1

INTRODUCTION

The North Field is the world’s largest natural gas field and accounts for nearly all the State of Qatar’s gas production. The principal objective of the NFPS projects is to sustain plateau from existing QatarEnergy LNG Operation – S1, S2, S3, N1 and N2, production areas by implementing an integrated and optimum investment program consisting of subsurface development, pressure drop reduction steps and compression.

NFPS projects comprise 3 main investment programs:

  1. Investment #1: Drilling and Associated Facilities [WHP12S/ WHP13S/ WHP14S/

WHP12N/ WHP13N]

  1. Investment #2: Trunk line Looping and Intra-field pipeline looping [32” PL1LN, 32”

PL1LS, 38”PL610LS]

  1. Investment #3: Compression Complexes and associated facilities [Phase 1 CP6S & CP7S; Phase 2: CP8S & CP4N; Phase 3: CP4S & CP6N Phase 4: CP1S & CP1N]

Drilling and Looping, Investments #1 and #2, projects are in execution phase and are being executed as I1P1, EPCOL Projects except for WHP13N, which will be part of NFPS Compression Projects execution which compromises total up to 9 COMPs.

1.1 Project Objective

The objective of this Project includes:

• Achieve standards of global excellence in Safety, Health, Environment, Security and

Quality performance.

• Sustain the Qatarenergy LNG North Field Production Plateau by installing new RPs and one WHPs to support new Compression Complex facilities CP6S & CP7S and pre-installed facilities for future Compression Complex facilities including but not limited to CP4N & CP8S tie-in with integration to the existing facilities under Investment #3 program.

• Facility development shall be safe, high quality, reliable, maintainable, accessible,

operable, and efficient throughout their required life.

1.2 Project Scope

The Project Scope includes detailed engineering, procurement, construction, brownfield modifications, transportation & installation, hook-up and commissioning, tie-in to EXISTING PROPERTY and provide support for start-up activities of the following facilities and provisions for future development. The WORK shall be following the specified regulations, codes, specifications and standards, achieves the specified performance, and is safe and fit‐for‐ purpose in all respects.

Facilities - 1A

• RP5S RP with 2 x 28” CRA clad pipelines to RP7S and 2 subsea composite Cables

and associated J tubes from RP7S to RP5S & from CP7S to WHP13S.

• New Fuel Gas 8” CRA Spur-lines and flanged risers from Subsea skid to RP7S. • Hook-up and brownfield modification at WHP5S/RP5S bridge connection & WHP13S/CP7S Composite cable tie-in and E&I integration including RGA Control modification.

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

• Pipeline decommissioning of 28” CS PL5 including associated demolition work at

WHP5S.

Facilities - 2A

• RP6N RP with 1x28” CRA clad pipeline to WHP13N, 2 Subsea composite cables and

associated J tubes from WHP12N to RP4N and RP6N to WHP13N. • New fuel gas spur-line and flanged riser from subsea skid to RP6N. • WHP13N Topside. • Hook-up and brownfield modification at WHP6N/RP6N, RP4N- HPU-Umbilical and tie- in, WHP12N-new J tube installation, E&I migration, WHP6N/RP4N/WHP4N-E&I migration (Pre-CP4N), WHP13N and RP6N interconnection to NFB.

Facilities - 3A

• RP9S RP with 1x28” CRA clad pipeline to RP4S. • Hook-up and brownfield modification at RP4S/WHP9S, Modifications to integrate

RP9S to the RGA control network.

• Pipeline decommissioning of 28” PL9 to WYE on existing 38” trunkline PL49including

associated demolition work at WHP9S.

Facilities - 1B

• New fuel gas spur-line and flanged riser from subsea skid to RP4N. • Fiber Optic Cable from RP6N to onshore LFP East, RP6N to RP4N and RP6N to LQ6S. • Hook-up and brownfield modification at RP6N Composite and FO Tie-ins NFB-PU (East)- FO Tie-in

(East)/BVS

Power & Control modifications, LQ6S/LFP Controls/Telecoms Integration.

Facilities - 2B

• RP5N RP with 2 x 28” CRA clad pipelines to RP4N, 1 x 28” CRA clad pipeline to RP6N and 2 subsea composite Cables and associated J tubes from WHP12N to RP5N & from RP6N to RP5N.

• Hook-up and brownfield modification at WHP5N- RP5N Bridge connection, WHP12N Composite cable tie-in, RP4N Intrafield pipeline Hook up PL54 N/LN and E&I integration including NFB-PU Power & Control modifications.

• Pipeline decommissioning of 2 x 16” PL56/PL54 Subsea Spur line from WHP5N to

reducing barred tee in subsea tie-in skid on PL6 / PL4.

Facilities - 3B

• 2 subsea composite Cables from RP4S to RP9S & from RP4S to WHP12S (with J-

tube).

• New Fuel Gas 8” CRA Spur-lines and flanged risers from Subsea skid to RP4S. • Hook-up and brownfield modification at WHP12S/ RP9S/ RP4S Composite cable tie-

in, Spurline riser installation at RP4S RGA Power & Control modifications.

Facilities - 4B

• 1 subsea composite Cable from CP8S to RP11S (or from RP8S to RP11S as Option). • New Fuel Gas 8” CRA Spur-line and flanged riser from Subsea skid to RP8S. • Hook-up and brownfield modification at WHP8S/ WHP11S for Test separator Internal Upgrade and MEG system modification, Spur lines, Power & Control Tie-ins on RP8S, RP11S/WHP11S-Tie-in (Power and Control), RGA Power & Control modifications.

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

Facilities - 5B

• 2 subsea composite Cables from RT2 to WHP3S & from RT2 to WHP2S (with J-tube)

and FO Cable from RT2 to Barzan WHP1.

• New Fuel Gas 8” CRA Spur-line and flanged riser from Subsea skid to RT2. • Hook-up and brownfield modification at BRZ-WHP1 - FO cable tie-in, WHP2S/ WHP3S/ RT&RT2 Composite cable tie-in and associated modification, RGA Power & Control modifications.

Facilities - 6B

• RP3S RP with 1x24” CRA clad pipeline to RT2 with Stalk on risers. • Hook-up and brownfield modification at RT2 for 24” Intrafield pipeline and Composite/FO cable Hook-up, WHP3S for Production diversion and Utilities, Power and ICSS Hook-up, WHP2S for Composite Cable Tie-ins and Power & Control Integration RGA Power & Control modifications. topside existing and

In-situ abandonment of existing Topside/subsea Composite Cables RT-WHP2S, RT-WHP3S, Topside/Subsea FO cable RT-BRXWHP1.

• Decommissioning at

Figure 1.2.1: NFPS Compression Project COMP3 Scope

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

2 DEFINITIONS AND ABBREVIATIONS

2.1 Definitions

Definition

Description

COMPANY

QatarEnergy LNG.

CONTRACTOR

Saipem S.p.A.

DELIVERABLES

FACILITIES

MILESTONE

PROJECT

SITE

All products (drawings, equipment, services) which must be submitted by CONTRACTOR to COMPANY at times specified in the contract. All machinery, apparatus, materials, articles, components, systems and items of all kinds to be designed, engineered, procured, manufactured, constructed, supplied, tested and permanently installed by CONTRACTOR at SITE in connection with the NFPS Project as further described in Exhibit 6.

fabricated,

A reference event splitting a PROJECT activity for progress measurement purpose.

COMP3 - NFPS Offshore Riser/Wellhead Platform & Intrafield Pipelines Project

(i) any area where Engineering, Procurement, Fabrication of the FACILITIES are being carried out and (ii) the area offshore required for installation of the FACILITIES in the State of Qatar

SUBCONTRACT

Contract signed by SUBCONTRACTOR and CONTRACTOR for the performance of a certain portion of the WORK within the Project.

SUBCONTRACTOR

Any organization selected and awarded by CONTRACTOR to supply a certain Project materials or equipment or whom a part of the WORK has been Subcontracted.

WORK

Refer to article 2 of CONTRACT AGREEMENT.

WORK PACKAGE

The lowest manageable and convenient level in each WBS subdivision.

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

2.2 Abbreviations

Code

Definition

ALARP

BAT

BOD

BPEO

CFC

CH4

CO2

As Low As Reasonable Possible

Best Available Techniques

Basis of Design

Best Practicable Environmental Option

Chlorofluorocarbon

Methane

Carbon Dioxide

CHARM

Chemical Hazard Assessment and Risk Management

EIA

EPA

EPC

FEED

GHG

GHS

GIIP

H2S

HCFC

HFC

Environmental Impact Assessment

Environmental Protection Agency

Engineering, Procurement and Construction

Front End Engineering Design

Greenhouse Gases

Globally Harmonized System

Good International Industry Practices

Hydrogen Sulphide

Hydrochlorofluorocarbon

Hydrofluorocarbon

HOCNF

Harmonized Offshore Chemical Notification Format

HSE

IAPP

IFC

IMDG

Health, Safety and Environment

International Air Pollution Prevention

International Finance Corporation

International Maritime Dangerous Goods

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

Code

Definition

IMO

MARPOL

MEG

MEPC

MLL

International Maritime Organization

The International Convention for the Prevention of Pollution from Ships

Methyl Ethelene Glycol

Marine Environment Protection Committee

Marine Logistic Lead

MOECC

Ministry of Environment and Climate Change

N2O

NFPS

NOx

NO2

OCNS

ODS

OIM

OSPAR

PFC

Nitrous Oxide

North Field Production Sustainability

Nitrogen Oxides

Nitrogen Dioxide

Offshore Chemical Notification Scheme

Ozone Depleting Substance

Operations Installation Manager

Oslo-Paris Convention

Perfluorocarbons

PLONOR

Posing Little Or No Risk

PM

QE

QG

QG-S

RGA

RGE

RLIC

Particulate Matter

Qatar Energy

Qatargas Operating Company Limited

Qatargas South

RasGas Alpha

RasGas Expansion - Wet Gas System

Ras Laffan Industrial City

ROPME

Regional Organization for the Protection of the Marine Environment

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

Code

Definition

SOx

SO2

TSS

UN

VOC

WB

WHO

WMP

Sulphur Oxides

Sulphur Dioxide

Total Suspended Solids

United Nations

Volatile Organic Compound

World Bank

World Health Organization

Waste Management Plan

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

3 REGULATIONS, CODES AND STANDARDS

In general, all design activities shall confirm to legal and statutory regulations and recognized industry best practices. Conflict among applicable specification and / or codes shall be brought to the attention of the COMPANY for resolution COMPANY decision shall be final and shall be implemented. The latest editions of codes and specification effective as on date of contract shall be followed.

In general, the order of precedence shall be followed:

a) Qatari Governmental and Regulatory Requirements b) COMPANY Procedures, Policies and Standards (Exhibit 5 Appendix I) c) Project Specifications. d) Industry Codes and Standards e) COMPANY and CONTRACTOR’s Lessons Learned

If CONTRACTOR/SUBCONTRACTOR deems any deviations from the specifications will result in significant project cost and schedule saving, proposal to such deviations shall be submitted to COMPANY for review and approval. CONTRACTOR/SUBCONTRACTOR shall not proceed with any deviation to the specifications without prior COMPANY approval.

The following is a list of relevant regulations, codes, standards, specification, COMPANY documents that shall be considered for the PROJECT in the order of precedence listed above:

3.1 Qatari Government and Regulatory Requirements

S. No

Document Number

Title

Law No. 30 of 2002

The Law of the Environment Protection 30/2002

Executive By-Law Law No.30 for 2002

for

Executive By-Law for the Environment Protection Law, Issued vide the Decree Law No. 30 for the Year 2002

Law 21/2007

Control of the Ozone-Depleting Substances

3.2 Company Document

S. No

Document Number

Title

LTC/C/NFP/5129/20

Contract Agreement

EXHIBIT 5

Project Instructions

PRJ-PJL-PRC-004

PRJ-PJL-PRC-005

Facilities Engineering and Vendor Document Numbering Procedure

Facilities, System and Unit Number Codes and Descriptions Procedure

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

S. No

Document Number

Title

PRJ-PJL-PRC-006

Project Information Handover Procedure

PRJ-PJL-PRC-048

PRJ-PJL-PRC-049

Facilities Documentation Metadata Requirements Procedure

Project Acceptance Procedure

Information Handover, Verification and

PRT-HLT-PRC-023_00 Hazardous Materials Management Procedure

COMP-QG-EN-PLN- 00001_00

COMP-QG-EN-PLN- 00002_00

Environmental Management Plan

Regulatory Compliance Plan

7511266-22088

Marine Fauna Observation Plan

PRT-ENV-PRC-002_05 Waste Management Procedure

PRT-ENV-PRC-018_02 Environmental Permitting Procedure

PRT-ENV-PRC-013_05 Environmental Aspects and Impact Procedures

PRT-ENV-PRC-036_02 Spill Prevention and Control Plan

PRT-HLT-PRC-004

QG Noise Control and Hearing Conservation Standard

3.3 Project Documents

S. No

Document Number

Title

Exhibit 6 Appendix J

Environmental Impact Assessment (EIA) Requirements

200-20-SH-DEC-00001 Environment Basis of Design (FEED)

200-20-SH-DEC-00012 Noise Design Philosophy for COMP3 Project

200-20-SH-REP-0001

Regulatory Management Plan (FEED)

Compliance

and

Environmental

200-20-PR-DEC-00051 RGE Process Design Basis for COMP3 Project

200-20-PR-DEC-00052 QG2 Process Design Basis for COMP3 Project

200-20-SH-DEC-00014_00

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

S. No

Document Number

Title

200-20-PR-DEC-00054 Process Design Criteria for COMP3 Project

200-20-PE-DEC-00004 Project Basis Of Design for COMP3 Project

200-20-PR-DEC-00055 Process Drain Philosophy for COMP3 Project

268-23-PR-DEC-00001 Process Description for RP6N

265-23-PR-DEC-00002 Process Description for WHP13N

240-23-PR-DEC-00001 Process Description for RP5S

235-23-PR-DEC-00001 Process Description for RP9S

200-20-SH-LIS-00013

Emissions, Effluent and Waste Inventory for COMP3 Project

200-20-SH-REP-00201 Vent Dispersion Report for COMP3 Project

200-91-EL-DEC-00009

Lighting Design Philosophy for COMP3 Project

200-20-SH-REP-00198 Ship Collision Study for COMP3 Project

200-20-SH-PRC-00017

200-20-SH-PRC-00013

200-20-SH-LIS-00021

Operations Environmental Management Plan COMP3 Project Technical Safety Basis of Design (Offshore) for COMP3 Project

for

Safety, Health, Environment Action Management (SHEAM) Register for COMP3 Project

3.4 International Codes and Standards

S. No

Document Number

Title

Vienne Convention

Vienna Convention for the Protection of the Ozone layer

Montreal Protocol

Basel Convention

Rotterdam Convention

Montreal Protocol on Substances that Deplete the Ozone Layer

Basel Convention on the Control of Trans-boundary Movements of Hazardous Waste and Their Disposal Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade

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COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

S. No

Document Number

Title

Stockholm Convention Stockholm Convention on Persistent Organic Pollutants

Kyoto Protocol

Kyoto Protocol to the UN Convention on Climate Change

OSPAR

Oslo-Paris Convention

ROPME

The Regional Organization for the Protection of the Marine Environment

Kuwait Convention

MARPOL 73/78

GCC Regulation 1997

IFC EHS Guidelines 2007

IFC EHS Guidelines 2015 Directive 2008/1/EC of the European Parliament

AP12021 Publication

International Maritime Organization (IMO)

Report- 29555, World Bank Group

Kuwait Regional Convention for Cooperation and Protection of Marine Environment from Pollution and its Protocols International Convention for the Prevention of Pollution from Ships (1973G) as amended by Protocol MARPOL (1978G) General Regulations of Environment Cooperation Council (GCC) States

the Gulf

in

IFC General Environment, Health, and Safety (EHS) Guidelines, Environmental., April 2007

IFC EHS Guidelines development, June 2015

for offshore oil and gas

EU Directive 2008/1/EC concerning IPPC

American Petroleum Industry Compendium of Greenhouse Gas Emissions Estimation Methodologies for the Oil and Natural Gas Industry, 2021

International Maritime Dangerous Goods (IMDG) Code

A Voluntary Standard for Global Gas Flaring and Venting Reduction, the World Bank, May 2004

NORSOK S-002:2004 Working Environment

OSHA 1910.95

Occupational Noise Exposure

World Health Organization (WHO)

GHS Rev. 9, 2021

WHO global air quality guidelines. Particulate matter (PM2.5 and PM10), ozone, nitrogen dioxide, sulfur dioxide and carbon monoxide, 2021 UN Regulations on the Transport of Dangerous Goods and the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

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NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

4 PURPOSE & SCOPE OF WORK

4.1 Purpose

The purpose of this document is to describe the environmental regulatory requirements and legislation that will apply to the COMP3 Project. This document will outline the considerations for the design and operation of the PROJECT with respect to safeguarding the environment. The general principles are the facilities to be designed and operated in compliance with Qatar regulations, COMPANY policies and standards, and the international treaties to which Qatar is a signatory.

4.2 Scope of Work

This Design is applicable to the Greenfield and associated Brownfield facilities for COMP3 Project.

• The proposed greenfield FACILITIES, i.e., new Wellhead Platform, new riser

platforms bridge connected to existing WHPs, new intra-field pipelines, and

• Brownfield modifications.

Table 4–1: Platforms under COMP3 Scope

Greenfield

WHP13N, RP5N, RP6N, RP3S, RP5S, RP9S, BSP3S, BSP5S

Brownfield WHP4N, WHP5N, WHP6N, WHP12N, WHP2S, WHP3S, WHP4S, WHP8S, WHP5S, WHP9S, WHP11S, WHP12S, RP7S, RP4S, RP8S, RP11S, RP4N, RP6N, RT, RT-2, PU

The scope covers air emissions, effluent discharges, noise and solid waste, and the legislation and regulations pertaining to actual limits for the emissions and discharges.

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Classification: Internal

NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

5 GENERAL ENVIRONMENTAL PRINCIPLES

The PROJECT will aim to reduce all potential environmental impacts that could result from its activities to ALARP levels, based on the following principles:

• Ensure PROJECT design takes into account all environmental considerations. These considerations will be included in the design philosophy within the Environmental Basis of Design, Implement appropriate environmental management measures with the intent of reducing the potential for associated negative environmental impacts to As Low As Reasonably Practicable (ALARP) levels,

•

• Strictly adhere

to relevant national environmental regulations,

international agreements and guidelines, and COMPANY standards, as detailed in the Environmental Basis of Design, and Incorporate Best Available Techniques (BAT), Best Practicable Environmental Option (BPEO) and GIIP, wherever possible.

•

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NORTH FIELD PRODUCTION SUSTAINABILITY (NFPS) PROJECT

COMP3 - NFPS OFFSHORE RISER/WELLHEAD PLATFORM & INTRAFIELD PIPELINES PROJECT

ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

6 ENVIRONMENT MANAGEMENT CRITERIA

6.1 Air Emission Sources

6.1.1 Continuous Emissions

There are no major & continuous air emission sources from COMP3 Project facilities.

6.1.2

Intermittent emissions

• Emissions from Crane operation • Venting to safe location for toxic, flammable and asphyxiating releases (including

startup vents)

• Fugitive emissions from leakage of seals in valves, flanges, pumps, sampling points

etc.

• Marine Vessel operations including TEMPSC maintenance • Diesel driven equipment (to be used by blast and paint teams and during maintenance

Campaigns

6.1.3 Emissions from Abnormal Operation/Emergency

Flaring

Details of the emission sources and quantitative estimation will be elaborated in the Emissions, Discharges and Waste Quantification and Management Report [Ref.33]. The following sections further discuss the criteria for emissions to atmosphere from COMP3 project scope.

6.2 Ambient Air Quality

PROJECT emissions shall meet the national legislative requirements namely the Law on the Protection on the Environment, 2002, of Qatar [Ref.2] for ambient stack emissions which defines the legislative framework for air quality. For ambient air quality limit, it is tabulated in Table 6–1:

Table 6–1: Ambient Air Quality Limits

Pollutant

Average period

Ambient Air Quality Limit (ug/m3)

National Standard (Law 30/2002)

RLIC Env Regulations (2020)

NO2

SO2

1 Hr

24Hr

Annual

1 Hr

24Hr

Annual

400

150

100

365

80

400

150

1300

365

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Pollutant

Average period

Ambient Air Quality Limit (ug/m3)

National Standard (Law 30/2002)

RLIC Env Regulations (2020)

PM5

PM10

H2S

Ozone

24Hr

24Hr

Annual

1 Hr

24Hr

1Hr

24Hr

150

50

235

120

35

40

7

There are no sensitive receptors at COMP3 Facility for continuous exposure of above- mentioned ambient air quality limits, only workers should be present at offshore COMP3 Project facilities. So, we cannot directly interpretate these limits for COMP3 Project facilities. These values can be used for reference purposes.

6.3 Stack Emissions

There are no permanent and continuous emission stacks in COMP3 Project facilities. So, offshore facilities, Qatar Oil and Gas Industry stack emission standards are not specified in this Design Basis.

6.4 Ozone Depleting Substances

The State of Qatar has signed and ratified the Montreal Protocol in 1996. PROJECT design shall comply with the provisions defined in the Montreal Protocol on prohibiting systems filled with chloro-fluorocarbons (CFC), hydrochlorofluorocarbons (HCFC) or halons listed as banned or to be banned, under the Protocol. These materials are considered to cause depletion of the ozone layer in the stratosphere and initiate other environmental damage [Ref.41]. As permitted by the Montreal Protocol the PROJECT shall use hydrofluorocarbons (HFC), which are not harmful to the stratospheric ozone although HFCs are to be phased out in Qatar in 2028 as per the Kigali Agreement of the Montreal Protocol. Alternatives to HFCs include natural refrigerants (e.g. propane or ammonia based), hydrofluoroolefins (HFOs), and HFC-HFO blends can be used.

6.5 Flaring / Venting

The Flare System will be provided for emergency and maintenance depressurization of the topside equipment and piping in COMP3 Project.

Flare KO Drum only exists in WHP13N. In all other platforms, only Closed Drain Drum is available. A common Flare KO / Closed Drain Drum shall be considered to collect fluids from closed drain header and flare header [Ref.30].

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The RP5S will be connected to the existing wellhead platform WHP5S which does not have a permanent flare system. A vent header on RP5S will be provided to gather all the manual vent lines and future Test Separator PSV and route these to the existing vent system on WHP5S. Therefore, a future Flare Header, to future compression platform (CP7S), will be provided on RP5S to accommodate emergency topsides depressurization loads [Ref.31].

The RP9S will be connected to the existing wellhead platform WHP9S which does not have a permanent flare system. Two flare headers will be included on RP9S to collect and route the pipeline depressurization lines to WHP9 temporary Low Capacity and High-Capacity Flare Tips. A vent header on RP9S will be provided to gather all the manual vent lines and future Test Separator PSV and route these to the existing vent system on WHP9 [Ref.32].

The riser platform RP6N is bridge linked to WHP6N which does not have a permanent flare system. On WHP6N, space is provided to install a temporary flare system for trunkline and for intra-field pipelines manual depressurization. Vent header is included in RP6N to gather all the manual vent lines, excluding from the future Test Separator and route it to WHP6N Closed Drain header, to be further collected in Closed Drain Drum and relieved to atmosphere at safe location. Relief / vent from future Test Separator will be routed to future compression platform CP6N [Ref.29].

A venting system shall be applied to maintain atmospheric pressure in the open systems and in non-blanketed storage tanks. A slightly positive pressure will be maintained in blanketed storage tanks like MEG [Ref.30].

There are two types of vents:

  1. To atmosphere at a safe location (toxic, flammable and asphyxiating streams), and
  2. To atmosphere (all non-hazardous venting).

It is noted that hydrocarbons, flammables, or other toxic vapor mixtures venting to atmosphere shall not be permitted and avoided as practicably possible. The discharge of all atmospheric vents shall be at a safe location away from personnel and areas where personnel may be present and away from areas where vented vapours can collector accumulate, outside of building, away from the hot exhaust or other ignition sources and away from ventilation intakes and also access or passageway.

Equipment and systems shall be vented to atmosphere at safe location and shall include open drain systems, diesel storage tank (equipped with flame arrestor), MEG tank with nitrogen blanketing, nitrogen system, chemical injection system (as necessary for the chemicals selected). Separated gas from Closed Drain Drum from RPs & WHP is routed via vent line.

Low pressure atmospheric tanks and vessels containing non-volatile liquids such as diesel fuel, treating chemicals, etc. shall be provided with open vent lines as the requirement to vent to “a safe location”. Gas blanketed and atmospheric tanks and other small lighter-than-air vents shall be piped past the edge of the platform for discharging at high, outboard points. Vapor from the Open Drain Tank and CP Separator is vented to the atmosphere through a flame arrestor at safe location.

Equipment to be vented to atmosphere include compressed air, instrument air.

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Vent dispersion study [Ref.34] will be carried out for vents releases of HC, H2S and N2 gases for credible scenarios to determinate the final location at safe position of vent pipe termination.

As per IFC guidelines [Ref.56], continuous venting is not considered GIIP and should be avoided. Hydrocarbon gas streams should always be routed to an efficient flare gas system including during emergency events or process upset, although continuous flaring of gas should also be avoided wherever practical and possible. Adequate assessment of alternatives should be conducted and if flaring is the only viable option, elimination of continuous flaring shall be achieved.

6.6 Fugitive Emissions

Fugitive emissions of hydrocarbons shall be minimized through a combination of good engineering design practices and good operation and maintenance practices for reducing fugitive gaseous compounds that affect air quality. All valves in Sour Service NACE shall be fugitive emission tested as per ISO 15848-2 class B with 10% of test in case of failure upgrade at 100%. A Leak Detection and Repair Program (US EPA Leak Detection and Repair: A Best Practices Guide) will be implemented during PROJECT facility operations to minimize fugitive CH4 and/ or VOC emissions. Other specific measures to be implemented as necessary, wherever practicable, including:

• Routing the discharge of safety relief devices in hazardous services to a closed flare

system;

• Using plugged or capped ends on drain valves, sample valves and test connections to

minimize emissions from open-ended connections; • Using closed-loop sampling systems where possible; • Using suitable pump, compressor seals to minimize gas release; • Minimizing the number of flange fittings; • Using welded pipework and low leakage valve systems; Implementing leak detection and repair programs; and • Installing vapor control units for hydrocarbon loading and unloading. •

6.7 GHG Emissions

The State of Qatar has signed and ratified the Kyoto Protocol in 2005 [Ref.45]. The Kyoto Protocol aims to limit the emissions of six GHGs, namely carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrochloro-fluoro-carbons (HCFC), perfluoro-carbons (PFC) and sulfur hexafluoride (SF6). The PROJECT shall employ effective energy efficiency measures with regards to minimizing CO2 emissions arising from fuel gas combustion.

6.8 Vessel Emissions

Although the State of Qatar has not signed the Annex VI of the International Convention for the Prevention of Pollution from Ships (MARPOL) on the Prevention of Air Pollution from Ships, QG has committed to meet the Annex VI requirements [Ref.49]. Therefore, all vessels involved in the PROJECT (including rigs) will require adherence to MARPOL Annex VI requirements including possession of a valid International Air Pollution Prevention (IAPP) certificate.

Atmospheric emissions from vessels at all phases of the PROJECT shall adhere to MARPOL Annex VI requirements, notably:

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• Marine fuel shall meet a Sulphur limit of 0.5% in accordance with Resolution

MEPC.320(74); and

• NOx emissions from diesel engines shall be controlled in accordance with the NOx

Technical Code 2008 (Resolution MEPC.177(58)).

For marine vessel movement during operation phase for COMP3 Project, refer to Ship collision study for COMP3 Project [Ref.36].

6.9 Effluent Discharges

PROJECT activities will generate liquid, semi-solid and solid wastes that will need to be disposed of safely without causing harm to the environment or personnel. These discharges require specific management to reduce the risk of harming the environment and personnel to the level of ALARP. Offshore wastewater discharges will comply with the limits prescribed by the Executive by Law No. 4 (2005) (Environmental Protection Standards) [Ref.2]. In the absence of any specific Qatar limits, relevant international standards and guidelines shall apply. For existing facilities, the discharges are required to meet ROPME Protocol requirements [Ref.47].

Potential effluent sources from the COMP3 Project are limited to the following:

• Hydrotest water from pipeline commissioning; • Deck drainage; • Overboard discharge; • Produced water.

Effluent management principles should include the following:

• Water use to be minimized and wastewater reused (following appropriate treatment)

or recycled, wherever practicable;

• Risks of contamination to the environment must be minimized; • Discharges shall be in compliance with Qatar water discharge limits as detailed below; • Appropriate engineering controls shall be in place to prevent leakages from pipes and

vessels, including regular maintenance and inspection to detect leaks;

• Adequate spill control (bunding/ coaming) and drainage arrangements shall be provided where hydrocarbon and chemical inventories are stored, handled or processed; and

• All environmentally harmful liquids shall be stored on a hard-surfaced coaming area to

act as a barrier to prevent pollution.

6.9.1 Hydrotest Water

Hydrotest water shall be monitored to meet Qatar legislative discharge standards in the marine environment [Ref.2]. In the absence of specific guidelines on hydrotest water management in Qatari Law, the pollution prevention and control measures outlined in the IFC guidelines [Ref.52] shall be applicable, as follows:

• Minimize the volume of hydrotest water offshore by testing equipment at an onshore

site prior to loading the equipment onto the offshore facilities;

• Use the same water for multiple tests;

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• Reduce the need for chemicals by minimizing the time that test water remains in the

equipment or pipeline;

• Carefully select chemical additives in terms of dose concentration, toxicity,

biodegradability, bioavailability, and bioaccumulation potential; and

• Send offshore pipeline hydrotest water to onshore facilities for treatment and disposal,

where practical.

A hydrotest water management plan will be developed by Contractor’s concerned discipline and reviewed and approved by engineering discipline of the Company.

6.9.2 Deck Drainage

Drainage system is split into three systems: Open Drain System, Closed Drain System and Maintenance Drain.

6.9.2.1 Open Drain System

The Open Drain System shall be provided on both the Wellhead Platforms and the Riser Platforms. Open Drain System is segregated into hazardous and non-hazardous open drains. Hazardous drains are open drains collected from hazardous area Zone 0/Zone 1/Zone 2 and non-hazardous drains are open drains collected from non-hazardous area. The segregation is meant to avoid migration of a fire, flammable liquids or vapours, or toxic liquids or vapours from one hazardous area to another, or to a non-hazardous area. Liquid seal is provided at the end of both hazardous and non-hazardous header to prevent gas migration.

Hazardous area drip trays, hazardous area deck drain from wellhead and riser platforms shall be collected via gravity flow headers to Open Drain Tank. The Non-Hazardous Area Open Drain System shall collect drainage from non-hazardous areas of platform, such as rainwater, washdown water, deluge etc., via gravity flow headers. [Ref.31].

Open Drain Tank will be sized to provide a minimum of 10 minutes retention time for the amount of rainfall collected on the plated areas of the deck during a 10-year rainfall event. The Open Drain Water Pump and the CP Separator will be sized to handle the amount of rainfall collected on the plated areas of the deck during a 50-year rainfall event. The Open Drain Oil Pump capacity will correspond to minimum 10% of the capacity of the Open Drain Water Pump [Ref.28].

Open Drain Tank shall be a rectangular atmospheric tank provided with two compartments: one compartment collects the liquids from open drain headers and the other receives the oil from the CP Separator. The separated water in the Open Drain Tank is pumped to the CP Separator for further treatment prior to disposal overboard. Recovered oil collected from the CP Separator skim bucket will be drained to oil compartment of Open Drain Tank. Oil from the oil compartment of Open Drain Tank will be pumped to the Closed Drain Drum.

Overflows from Diesel Storage Tank sent to oil compartment of Open Drain Tank and subsequently to Closed Drain System via Open Drain Oil Pump. Refer Process Drain Philosophy [Ref.28] for details.

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6.9.2.2 Overboard Discharge

The Non-Hazardous Area Open Drain System shall collect drainage from non-hazardous areas of platform, such as rainwater, washdown water, deluge etc., via gravity flow headers. Drainage from some areas (helideck, toilets and AHU, Deluge test line, firewater from wellhead area) where no hydrocarbon spillage can occur should be routed directly overboard rather than to the Open Drain Tank [Ref.24]. In general, all overboard discharges are not expected to be contaminated with chemicals, however, these discharges to sea shall comply with the standards stipulated in Annex 4 under MOECC Executive By-Law [Ref.2 & 20], as given in Table 6–2:

Table 6–2: Qatar Standard for Discharges into the Aquatic Environment [Ref.2]

Parameter

Symbol

Limit

pH

Temperature Rise

∆T

6 to 9 Not more than 3 oC above the prevalent temperature

Total Dissolved Solids

TDS

Total Suspended Solids

TSS

Floating Particles

Oil and Grease

6.9.2.3 Closed Drain System

1500

50

Nil

15

Unit

mg/l

mg/l

mg/l

Drains and sample connections on level instruments, vessels and equipment with a substantial hydrocarbon or toxic inventory, or operating at high pressure, shall be tied into the closed drain system. This shall consist of headers segregated according to the piping class, terminating at the Closed Drain Vessel. The liquids collected in the closed drain vessel shall be returned by means of a pump to export header. This closed drain vessel shall not receive effluents from the open drains nor discharge into an atmospheric enclosure receiving open drain effluents. Recovered oil from the open drain tank will be routed to the Closed Drain Vessel.

6.10 Noise

Noise will be emitted from various sources of the COMP3 Project. The main sources of noise are as follows:

• Rotating Equipment (Electric Motors, Pumps, etc.) • HVAC Equipment (Air Handling Unit, Air Cooled Condensing Units, etc.) • Fans • Motor Operated Valves, Flow Control Valves, Flow Meter, Restriction Orifice • Flares & Atmospheric vents • Pressure Safety Valves & Blowdown Valves • Transformers • Hoist motor etc.

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ENVIRONMENTAL BASIS OF DESIGN FOR COMP3 PROJECT

COMPANY requirement levels of noise exposure and workplace noise levels are principally derived from relevant standards and procedures [Ref.19 & 21]. Table 6–3 summarizes the noise limits for workplace applied in this PROJECT.

Table 6–3: PROJECT Noise Limits

Item Description

PROJECT Noise Limit

COMPANY Standard

Remark

General Working Area Noise Level for RPs & WHPs

1

83 dB(A) Leq12h 85 dB(A) Leq8h

83 dB(A) Leq12h 85 dB(A) Leq8h

2

Absolute Noise Level

115 dB(A) Outdoor

115 dB(A)

With respect to COMPANY’s Noise Control and Hearing Conservation Program 83 dB(A) is the noise limit for an 12 hour TWA exposure.

Absolute limit anywhere in a work area – personnel will not be permitted to work in the area where noise at this level is present. Sound resulting from emergency noise sources such as atmospheric Process Safety Valves (PSVs) and Flares shall not exceed 115 dB(A) at reasonably accessible in-plant locations

There are currently no prescribed limits for underwater noise under Qatari legislation or other applicable international standards or guidelines. Although no prescribed limits are available, the IFC guidelines [Ref.52] provide recommendation on mitigation measures that can be employed to reduce the risk of underwater noise impacts to marine species from noise- generating activities.

In accordance to GIIP, this PROJECT shall employ mitigation methods to mitigate noise- inducing activities to ALARP levels through:

• Usage of quietest possible technology/Equipment; • Employing physical methods to reduce the source level; •

Implementing physical methods to reduce the transmission of sound beyond the source; and

• Establishing exclusion zones to reduce potential noise exposure to levels causing

injuries or behavioral disturbance to marine fauna.

The other details are mentioned in Noise Design Philosophy for COMP3 Project [Ref.22].

6.11 Lighting

Without compromising safe workplace lighting conditions, the PROJECT shall minimize environmental and visual impacts. In EIA report [Ref.20], it is mentioned that artificial lighting

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impact will be highly localized and of minor consequence to the ecosystem from the facility. These artificial lighting effects are already present at the existing platforms in the area, and hence they may not be impact for this PROJECT.

In the absence of any legislative requirement for light emissions for Qatar, OSPAR [Ref.46] for minimizing impacts of lighting to biodiversity receptors shall be considered, including the following:

• Assessing all lighting equipment on offshore installations potentially emitting light outside the physical boundary of an installation to determine whether the light is essential for safety reasons and whether there is potential for reducing external emissions;

• Reducing the number of lights and intensity of lights, and adapting the light spectrum

•

to those that will have low impacts to biodiversity; In areas where lighting is not a continuous requirement, installation of automatic switches and light sensors should be considered. Otherwise, light sources should be automatically or manually controlled through the process control system. Normally unmanned platforms should have switches installed and during unmanned periods light should be switched off apart from lighting requirement to comply with national and international regulations on aviation and shipping navigation; and

• Where possible, external lights should be shielded to direct light only to areas where it is needed, and lights should be positioned in places where emissions to the surrounding environment can be minimized. Plant lighting will be designed as per Electrical Basis of Design for COMP 3 Project [Ref.35].

6.12 Chemical Management

Chemical selection shall be in alignment with ROPME protocols [Ref.46] and guidelines and according to the lowest toxicity, lowest bioaccumulation potential and highest biodegradation potential, as applicable. Chemicals shall be selected according to the harmonized pre- screening scheme based on the OSPAR methodology [Ref.47].

All chemicals selected for the PROJECT shall be registered in the Offshore Chemical Notification Scheme (OCNS) and regulated according to Harmonized Offshore Chemical Notification Format (HOCNF) and ranked as GOLD/ SILVER under the Chemical Hazard Assessment and Risk Management (CHARM) model or classified as chemicals with the least environmental risk (Category C to E) ranking for non-CHARMable products. Chemicals listed as Posing Little Or No Risk (PLONOR) under the OSPAR list are preferred.

Chemical storage areas shall adhere to the following requirements:

• Hazardous waste must be placed, stored in UN approved drums/containers, labelled and transported onshore for waste disposal or treatment in an MOECC approved facility;

• Each chemical container shall have hazard labelling according to UN Globally

Harmonised System for Classification and Labelling of Chemicals (GHS);

• Only chemicals approved for use should be stored in the site storage facility, while those not yet approved shall be quarantined, controlled and monitored in a dedicated area until cleared;

• Only authorised personnel shall have access to the chemical storage area;

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• The first- expire / first- out principle shall be implemented in order to reduce the

possibility of having expired chemicals in stock; and

• Site is responsible to maintain and update its chemical inventory.

All storage areas for chemicals must be designed so that risk to personnel and the environment is minimized. The key areas which must be addressed for storage areas include:

• Spill containment; • Coaming requirements; • Separation of storage area from offices, boundaries and the like; and • Segregation of incompatible chemicals.

6.13 Solid Wastes

The ‘Duty of Care’ principle shall be adopted for the management of waste streams generated by the PROJECT’s facilities. Under the ‘Duty of Care’ principle, the waste producer (COMPANY) shall be responsible for ensuring the proper and safe disposal of wastes, even after it has been passed to another party. The Duty of Care for waste cannot be contracted away or delegated to a third party. The COMPANY is required to take all reasonable steps to manage any waste it generates and ensure its lawful disposal. A Waste Management Plan (WMP) documenting the waste strategy, storage (including facilities and locations) and handling procedures should be developed as recommended in the IFC guidelines [Ref.51, 52]. The WMP should also include a clear waste tracking mechanism to track waste consignments from the originating location to the final waste treatment and disposal location.

As a minimum, the following shall apply:

• No floating foams or any solids may be discharged to sea; • All domestic waste shall be segregated to biodegradable, recyclables and reusables,

and transported to shore for disposal; and

• All hazardous waste shall be stored in a designated area prior to being transported to

shore for disposal at an approved MOECC facility.

The waste storage area shall be segregated for non-hazardous and hazardous wastes, and labelled accordingly. Non-hazardous wastes shall be further segregated based on its chemical and physical properties (e.g. biodegradable, recyclable, etc.). Hazardous wastes shall be managed according to International Maritime Dangerous Good (IMDG) Code and Qatar legislative requirements. Hazardous wastes shall be packaged and labelled accordingly throughout its storage prior to being transported onshore for treatment and/ or disposal. Refer Section 6.14 Hazardous waste for details.

No sand production is expected since the reservoir is of carbonate formation and the offshore wells are not designed for sand production consequently.

Ship waste is to be managed in accordance with MARPOL Convention. Macerators or incinerators shall also be provided onboard and ship waste should not be discarded within 500 meter zone [Ref.49]. Any applicable waste discharged to sea shall be macerated to an approved size as per MARPOL requirements. Waste materials shall be segregated into non- hazardous and hazardous waste for appropriate management. For non-hazardous wastes, disposal of non-hazardous solid and non-biodegradable wastes into the sea is not permitted with the exception of macerated food wastes. Non-hazardous wastes are to be segregated

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accordingly to its chemical and physical properties and transported onshore for disposal or recycling by a government approved contractor.

6.14 Hazardous Waste

Hazardous materials shall be handled as per COMPANY Procedure [Ref.11]. Hazardous waste shall be managed according to International Maritime Dangerous Goods (IMDG) Code [Ref.55], UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS) [Ref.60] and Qatar legislative [Ref.2] requirements. Hazardous wastes shall be packaged and labelled accordingly prior to delivery onshore for treatment/ disposal by a government approved contractor. Selection of waste treatment options shall take into account BAT principles, minimization of risk and long-term liability.

As the presence of Mercury is anticipated in the separator gas as trace contaminant, the COMP3 Project shall adhere to the seawater quality standard as stipulated under Qatari legislation [Ref.4], where the concentration of Mercury in seawater shall not exceed 0.4 µg/l. According to the QG-S RGE Compression BOD [Ref.23], Mercury levels will be monitored quarterly based on EPA 245.2 AA Cold Vapor method and concentration is expected to be within 1 µg/m3 (or 0.001 µg/l), therefore is compliant with Qatari legislation [Ref.2].

Traces of Mercury, Arsenic, Radan etc. are reported in gas composition [Ref.25]. However, these traces are not directly discharging into either in air environment or marine environment or in the form of solid waste from COMP3 Project.

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7 MONITORING

COMPANY shall, during all phases of the PROJECT (pre-construction, construction, operation, decommissioning, closure and post-closure), engage in continuous, proactive and comprehensive self-monitoring to ensure compliance with applicable legislation and guidelines, this BOD and the Environmental Management Plan [Ref.37]. A monitoring program should be developed to appropriately monitor emissions, effluent and waste in accordance with BAT principles for the incorporation of online analyzers and/ or manual sampling. Monitoring frequency should be sufficient to provide representative data for the parameter being monitored. Monitoring should be conducted by trained individuals following monitoring and record keeping procedures and using properly calibrated and maintained equipment. Monitoring data should be analyzed and reviewed at regular intervals and compared with the operating standards, so that any necessary corrective actions can be taken.

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8 EMERGENCY EVENTS

The following principles shall also be applied to mitigate impacts on environment from an emergency event occurrence:

• All flammable, toxic and waste fluid from the emergency condition, start - up or maintenance or operational relief/ depressurization requirements for all hydrocarbon process systems will be routed to the flare system. • Installations shall be designed to avoid risks of leak of toxic gases and liquid [Ref.38] • Adequate gas detection and mitigation measures shall be implemented to minimize

H2S emissions during loss of containment incidents [Ref.38].

• The QG field is not an oil-producing field and the export will be condensate and gas, hence the risk of oil pollution could arise from diesel. Refer to the Marine Operation Manual [Ref.5] for oil pollution control measures.

• Adequate spill control (bunding/ coaming) and drainage arrangements shall be provided where hydrocarbon and chemical are stored, handled or processed. Drainage system will take into consideration deluge water where possible [Ref.38].

• Any spillage of fuel must be reported to QG (Operations Installation Manager (OIM) for

•

offshore and Marine Logistic Lead (MLL) for onshore). In the event of any emergency in QG offshore facilities involving hazardous materials, the roles and responsibilities provided in COMPANY’s Offshore Emergency Response Plan will be followed by offshore personnel. Any leaks, spills and unintentional releases should be reported in accordance with COMPANY Procedure [Ref.18] and Emergency Response Plan for Operation Phase for COMP3 Project. Upon completion of emergency response, removal of contaminated material and clean-up will be the responsibility of end user of the Individual Asset or Operations group with support from other QG disciplines.

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9 ENVIRONMENTAL COMPLIANCE REGISTER

A Safety, Health, Environment Action Management (SHEAM) Register [Ref.39] is developed to facilitate compliance to regulatory requirements applicable for the NFPS Compression Project COMP3 scope. This register tracks environmental issues to ensure PROJECT execution in full compliance with the applicable national and international laws, regulatory requirements, and industry standards.

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Project: Q-32705 - Saipem COMP3 Folder: 1. 26.06.25


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