8 INTERNAL AND EXTERNAL MONITORING

Transcription

1 8 8 INTERNAL AND EXTERNAL MONITORING Compliance monitoring, as well as monitoring to identify potential improvements in the management of environmental, social and cultural heritage issues, is a key component of the ESMS for the Project (see 2004-Q1 report for more detail). It represents the check and improve aspects of the plan-do-check-improve cycle that is an essential part of any good management system. Areas of compliance greatly outweigh areas of non-compliance, and it is therefore not meaningful or practical to report on these. The emphasis of the quarterly reports is therefore on areas of non-compliance and the resulting mitigating actions. The Project s monitoring activities can be categorised into internal and external monitoring (see Box 8.1). A summary of the types of monitoring is shown in Table 8.1. BOX 8.1. DEFINITIONS OF I NTERNAL A ND EXTERNAL MONITORING Internal monitoring is carried out by construction contractors (as a self-audit), BTC or Botaş, or by external (independent) organisations on behalf of the aforementioned parties. Reports from internal monitoring are not usually published externally, but are however available for review by external monitors. External monitoring is carried out by parties that are at arms length from the Project, often through third parties (e.g. government or lenders) and are always viewed as independent. Reports from external monitoring are normally published externally, with the exception of regulatory monitoring. BTC and the Independent Environmental Consultants (IEC) 1 use the same ranking system for rating non-compliances according to the definitions below: Level I: A non-compliance situation not consistent with the original Project requirements but not believed to present an immediate threat to an identified important resource, community or employee health and safety. Repeated Level I concerns may become Level II concerns if left unattended. Level II: A non-compliance situation that has not yet resulted in clearly identified damage or irreversible impact to a sensitive important resource, but requires expeditious corrective action and site-specific attention to prevent such effects. Repeated Level II concerns may become Level III concerns if left unattended or allowed to continuously recur. Level III: A critical non-compliance situation, typically including material damage to a specifically protected sensitive resource or a reasonable expectation of impending material damage. Intentional disregard of specific prohibitions is also classified as Level III. Level III non-compliances must be notified to the Lender Group. Please note that health and safety incidents and performance are covered in Chapter 9. 1 IEC are the Independent Environmental Consultants contracted by the Lenders to Audit BTC on a quarterly basis during construction. 8-1

2 Table 8.1: Types of Internal and External E&S level Scope Timing/frequency INTERNAL MONITORING 1. Contractor Field Inspection 2 and 2. BTC / Botaş Field Inspection and 3. BTC / Botaş Audits or Reviews 3 Compliance with E&S Commitments, Procedures and Method Statements Compliance with E&S Commitments, Procedures and Method Statements Typically involves an audit or a review on a particular theme, which has been identified as an issue; or looks at systemic issues 4. RAP Compliance with the Resettlement Action Plan 5. CIP Review Review and monitoring of CIP programmes relative to objectives as outlined in the PCIP 4 6. EIP Review Review and monitoring of EIP programmes relative to objectives as outlined in the PEIP 5 EXTERNAL MONITORING 1. Independent Compliance with ESAP Environmental Consultant (IEC) 2. SRAP Experts panel Compliance with the RAP 6 and social provisions 7 of the ESAP 3. Caspian Development Advisory Panel (CDAP) 4. Host Government Reports directly to BP Chief Executive Daily field activity Daily field activity Frequency and topic determined according to need and risk Quarterly Approximately halfway through the CIP project s implementation phase Approximately halfway through the EIP project s implementation phase Quarterly Six-monthly At least two formal meetings of Panel each year. One visit a year to the BTC region. Report issued at least once a year. E&S Commitments As determined by the Regulator 5. NGO monitoring 8 E&S Commitments Described for each country in Chapter 6 2 Note that in the field, the contractors and BTC/Botaş are generally working as a team. Internal inspection and monitoring may take place on a joint basis. 3 These may be carried out by BTC or Botaş, jointly with contractors, or contracted out to a third party by BTC. 4 PCIP (Project Community Investment Programmes) are implemented in all countries. The PCIP document forms part of the ESAP. 5 PEIP (Project Environmental Investment Programmes) are implemented in all countries. The PEIP document forms part of the ESAP. 6 RAP covers land acquisition and restoration of livelihoods. 7 Social provisions whose effectiveness is typically tested through interaction and interview with the community. 8 NGO is at various stages of development across the Project. Approach is described in Section

3 8.1 INTERNAL MONITORING As shown in Table 8.1, internal monitoring takes place on a daily basis or through theme audits and reviews. In some cases the review might raise actions and recommendations for implementation. When the audit or inspection involves a contractor, non-compliances may be raised. It should be noted that the raising of non-compliances is only effective in certain circumstances. It is inappropriate and indeed unmanageable if non-compliances are formally raised for each and every circumstance where a problem or issue has been identified for rectification. If the matter can be rectified in a timely manner through local site intervention, a non-compliance is not generally raised. The raising of formal noncompliances is reserved for persistent issues that need management attention. Such non-compliances can be raised by the contractor, Botaş or BTC MANAGEMENT TOOLS BTC has developed a set of tools to assist in the management of issues and internal resources on an ongoing basis. Detailed monthly reports are produced in each country and are used to generate cross project summaries that feature Project highlights as well as common or hot issues. Implementation performance is rated using a traffic light system to prioritise potential problem areas, useful for identifying areas where cross project sharing may be beneficial or where BTC management may need to intervene at a higher level CROSS PROJECT REVIEWS Table 8.2 outlines the nature and summary of findings of an HSE review conducted in 2004-Q4, as an example of an internal review function that occurs periodically, where a team from the wider BP organisation audits the Project. An outline of a Third Party Facility audit is also provided. Table 8.2: Getting HSE Right Audit, 2004-Q4 Audit / Review BP s Getting Health, Safety, and Environment Right (GHSER) Auditor Auditee Scope Summary of Findings BP BP Azerbaijan Business Unit, BTC Core Management Team, BTC Azerbaijan, BTC Georgia. Validate Azerbaijan BU HSE Management System to ensure it meets GHSER requirements; to determine HSE readiness for First Oil; review legal compliance systems; and identify areas of opportunity for material improvements in HSE practice in the Project. The look ahead to Operations phase provided useful recommendations regarding resourcing and emergency planning. Suggestions to improve BTC action tracking system. Some instances in which BP s Golden Rules of Safety had not been adhered to fully in the field. Organisational lessons learned regarding the lack of flexibility inherent in lump sum contracts. 8-3

4 Audit / Review Third Party Facilities (especially borrow pits and batch plants) Auditor Auditee Scope Summary of Findings BTC BTC/ Contractors in all three countries Assess the current standard of HSE and potential level of Project influence in third party facilities, and develop a consistent management strategy across all 3 countries. A plan for batch plants has been drawn up to address these issues in the field. HSE training material has been printed, and a Project trainer is scheduled to visit batch plants in Azerbaijan and Georgia. In addition, medical kits and PPE will be distributed. The assessment of needs is ongoing in Turkey. For borrow pits, a management strategy has been developed, based on a review of sites on a case-by-case basis against pre-determined criteria. This is being implemented in all 3 countries. In December 2004, BTC contracted an independent organisation to conduct a Mid- Term Evaluation of the Community Investment Program (CIP). The results of this review will be reported in the 2005-Q1 Lenders Report AZERBAIJAN During the reporting quarter, a number of significant internal audits and reviews were undertaken (see Table 8.3). Table 8.3: Summary of Internal Reviews/Audits, Azerbaijan, 2004-Q4 Audit / Review Auditor Auditee Scope Findings and/or Recommendations Mud Volcano Ridge Environmental Plan Audit BTC CCIC Confirmation of: Quality of Reinstatement and Erosion Control Measures. Conditions for Biorestoration and regeneration of the planted seeds. SPJV SPJV Internal review of Project compliance with Environmental and Measurement. No non-compliances raised. Reinstatement performed to a high level with no cases of erosion observed. Matting with Geotextile material and seeding verified as complete. Recommendations included continuation of monitoring of reinstated areas to ensure no damage evident and erosion control is in place. SPJV - 3 Corrective Action Requests. 8-4

5 Audit / Review Auditor Auditee Scope Findings and/or Recommendations Emissions of vehicles and generators SPJV SPJV A past internal audit on transport raised several CARs on transportation. SPJV accepted BTC recommendations on vehicle maintenance. Emission testing was undertaken to verify the effectiveness of adopted measures. CAR closure to be considered upon review of vehicle emission test results. Hydrotest Audit BTC/ Environ BTC/ CCIC Evaluate implementation of CCIC Hydrostatic Test Water Management Plan and identify opportunities for improvement. Good level of general awareness of environmental issues associated with Hydrotesting. Recommendations include improvements in management of change and to the practical implementation of protective measures set out in the Hydrostatic Test Water Management Plan. Waste Tracking System BTC CCIC Assist Contractor implement improvements to waste management (based on findings of Waste Management Duty of Care Audit in July 2004). CCIC adopted the Waste Tracking System of ACG. Training on good waste tracking system was delivered to CCIC personnel. BTC was involved in the design and planning, and subsequent inspections of the CCIC pollution prevention infrastructure upgrade works. The main results of the work carried out are outlined below (Box 8.2). BOX 8.2. UPGRADE O F CCIC POLLUTION PREVENTION I N FRASTRUCTURE BTC provided support to CCIC to assist them in improving the capacity of the construction camp infrastructure to capture and treat oily water generated by project related activities. The following refurbishments were undertaken: Resurfacing of diesel loading slabs to promote surface water run-off toward gully pots; Extension of diesel loading slab footprints to accommodate anticipated delivery tankers; Introduction of reinforced concrete upstands to diesel loading slabs; Introduction of type tested and certified oil/water interceptors to existing drainage networks; Waterproof render finishes applied to all concrete or masonry bund walls; Grout repairs made to the reinforced concrete base slabs of bunds exhibiting surface cracking; and Roof structures fabricated and erected to all fresh oil and waste oil storage bunds. In addition, improvements were made to third party owned and operated vehicle wash facilities utilised by the construction teams. Typically, the following upgrades were made: Resurfacing of vehicle wash slabs to promote surface water run-off to perimeter channel drains; Re-levelling of perimeter channel drains to promote flow towards the discharge point; and Introduction of type tested and certified washdown separators to existing drainage network. It is anticipated that all of the improvements will be complete mid Q1. 8-5

6 In addition to the monitoring and audits outlined in Table 8.3, BTC Environmental Field Officers and Field Environmental Co-ordinators continuously conduct inspections of the ROW and all permanent and temporary facilities (see Case Study 5.1). Typical results of these daily inspections are described in Box 8.3. Real time coaching and where necessary the raising of Corrective Action Requests will translate an issue into a traceable corrective action. BOX 8.3. EFOS DAILY INSPECTIONS A recent Kurdamir Camp inspection by an EFO identified good fuel storage and refuelling practices by CCIC, but improvement was needed in waste segregation and the availability of spill kits on site. Reported noise levels at sensitive offsite receptors in Kurdamir were marginally above the Project limits. Noise issues in Yevlakh Camp have been addressed and are subject to ongoing monitoring. The Tovuz Camp inspection identified a good waste segregation (particularly separation of hazardous and non-hazardous wastes). Camp housekeeping was also good. Kurdamir Pipe Yard inspection showed good security measures with the yard completely fenced and the site well secured. Inspection of Ganja Pipe Dump identified minor non-compliances of waste management, mainly regarding waste labelling and segregation. Subsequent to this finding, BTC delivered a Duty of Care workshop to CCIC staff, which included a presentation on good waste management practices. BTC also continually monitors the Contractor waste tracking systems. In Q4 the field laboratory was equipped to analyse hydrostatic test water samples to support technical and environmental assurance activities. Non-Compliances Table 8.4 outlines non-compliances recorded in Azerbaijan in Q4 that were identified by theme audits or by day-to-day monitoring and regular inspections. BTC continued working in conjunction with CCIC to deliver a one-team approach to assurance and monitoring, to minimise any duplication of effort and to agree corrective actions. Table 8.4: Azerbaijan Non-Compliances, 2004-Q4 Level of Non-compliance (I: least significant; III: most significant) October November December I II III The two Level II non-compliances raised during November and December related to inadequate waste management and pollution prevention practices. Further information about these non-compliances and information on the closure status of associated corrective actions is provided in Appendix 1. There were no significant environmental or social incidents in Azerbaijan during 2004-Q GEORGIA Table 8.5 outlines the internal audits carried out during the reporting quarter. 8-6

7 Table 8.5: Summary of Internal Reviews/Audits, Georgia, 2004-Q4 Audit / Review Auditor Auditee Scope Summary of Findings Top Soil Management (report received in Q4) Water Sustainability Studies Dr. Mike Hann 9 (Soil Scientist Cranfield University) BTC Consultant (Hydrologist) SPJV BTC/ SPJV Review of topsoil and subsoil management (in particular with respect to impact of changes to the original reinstatement specifications). To assess retrospectively any effects that Project construction activities may have had on local groundwater resources. Mitigation techniques for potential deterioration of the topsoil seed bank include aeration during reinstatement and the addition of hay from adjacent vegetation to supplement indigenous seeds. It is anticipated that this will encourage successful revegetation with the in situ flora. These studies have been completed and no evidence has been found of the construction activities adversely affecting local groundwater resources. Table 8.6 summarises the number of non-compliances identified as a result of ongoing day-to-day field monitoring by BTC. Table 8.6: Georgia Non-Compliances, 2004-Q4 Level of Non-compliance (I: least significant; III: most significant) October November December I II III The 5 Level II non-compliances raised on the Contractor in Q4 concerned reinstatement, pollution prevention, waste management and transport management practices. Further details on these non-compliances and the closure status of noncompliances raised in previous quarters are provided in Appendix 1. There were no significant environmental or social incidents in Georgia during 2004-Q TURKEY During the reporting quarter, a number of internal audits and reviews were conducted in Turkey, as summarised in Table Dr. Hann had significant input into the original reinstatement specification with respect to soil management practices to ensure reinstatement success. 8-7

8 Table 8.7: Summary of Internal Reviews/Audits, Turkey, 2004-Q4 Audit / Review Auditor Auditee Scope Summary of Findings Lot B Third party general environmental management audit Employment and Training Management Cinar Various Turkish Universities 10 EPC Contractors EPC Contractors Audit of Fuel Storage and Handling, Compliance of Waste Water Treatment Plants, waste management practices, air emissions and noise. recruitment and work conditions of Contractor employees in Lots A and C to ensure compliance with legal requirements. Report awaited. The key findings of the report will be included in the 2005-Q1 report to Lenders. In both Lots, living/working conditions for workers were reported as excellent. The Lot A Contractor performed above the expected standard with respect to employment of disabled, ex-convicted and terror-suffered people 11. The Lot C Contractor made positive use of unskilled labour although improvements in the hiring of disadvantaged groups as described above were highlighted. Recommendations were made to both contractors to improve promptness of wage payment and overtime; and to issue additional winter PPE. Environmental Management System DNV EPC Contractors (Lot C) ISO 14001, 9001 and audit to determine effectiveness of management plans and procedures to meet HSEQ criteria. This was a follow-up audit to determine if issues raised in previous audits had been satisfactorily closed. This was confirmed. 10 Atatürk University: Lot A; Cumhuriyet University: Lot B; Sütçü Imam University: Lot C; Erciyes University: PTs; Çukurova University: CMT. 11 As required under Turkish Law. 8-8

9 Audit / Review Auditor Auditee Scope Summary of Findings RAP Cultural Heritage Publication Quality Assurance Rural and Urban Development Foundation (RUDF) Ankara University British Institute of Archaeology (BIAA) Botaş Gazi University of Land Acquisition and Compensation Process of Construction Impacts (on land) Household surveys Fishermen Livelihood Restoration BIAA is working with Gazi University to ensure that monographs completed to report scientific results generated through the excavation works conducted at archaeological sites 12 are suitable for submission to an international referee and for publication in international journal. Summary of findings contained in Chapter 7. Ongoing monographs are expected to be completed, ready for publication in July QHSER Audit In this quarter Botaş undertook their bi-annual Quality Health, Safety and Environment Review (QHSER). An overview summary of the issues raised is provided in Table 8.8. One issue alone remained open from the Q2 QHSER, which was included into this QHSER 13. Table 8.8: Summary of number of issues raised in Botaş Internal QHSER Lot/Facilities Number of Issues Raised % Closed in this Quarter A 9 0 B 7 43 C Pump Stations CMT Yüceören, Büyükardıç, Tasmasor and Sazpegler. 13 The open action regarded compliance of waste water treatment plants in Lot A (Kars and Hanak Camps). Hanak camp has since been closed. The finding remains relevant for Kars camp and actions are being taken to close this out. 8-9

10 A summary of the QHSER main findings is listed below: Lot A: Biorestoration and construction schedules in ESAs; winterisation preparation and implementation; archaeological site management; monitoring of discharge from oil separator; WWTP discharge compliance; outstanding accounts with local suppliers and compensation payments for damage to property. Lot B: Post river crossing monitoring for suspended solids and oils; implementation of winterisation measures; safety measures at open trenches; outstanding accounts with local suppliers and compensation payments for damage to property. Lot C: Maintenance of quarry register; WWTP discharge compliance. Pump stations: Winterisation preparation and implementation; timely monitoring of Osmaniye WWTP; preparation of water sustainability study for IPT1; preparation of environmental management plan for hydrotesting; timely development of site-specific reinstatement and restoration plans; WWTP discharge compliance; appropriate discharge of concrete batching plant wastewater; irregular use of waste transfer notes; access to spill kits on site. CMT: Reinstatement documentation; waste management including timely waste transfers and use of appropriate recycling facilities. Internal Non-compliances Both BTC and Botaş field officers can raise non-compliances against the EPC Contractors on a day-to-day basis where breaches of project commitments are observed. Corrective actions are identified, often in consultation with the Contractor, and the execution of the action(s) is monitored. A summary of the non-compliances raised in Turkey this quarter is shown in Table 8.9. Table 8.9: Turkey Non-Compliances, 2004-Q4 Severity Level of October November December Non-compliance I II III Level I non-compliances recorded during the reporting period related to issues ranging from use of unapproved access roads, fuel spillage, use of unapproved borrow pits, use of land outside the ROW, waste and soil management. Further details of the nature of the Level I non-compliances are presented in Appendix 1. Issues covered in the Level II non-compliances referred to above were as follows: Poor waste management on the ROW; Failure to provide adequate erosion control measures to backfilled sections; Illegal discharge of waste water to a stream; Use of unapproved land outside of the ROW; Working in an archaeologically sensitive area without a watching brief; Inappropriate use of topsoil (as padding material); and Persistent use of an unlicensed borrow pit. 14 Please note that in reality there were only 5 Level I NCRs raised in this month but due to double counting between Botas and BTC two non-conformances have been recorded twice. 8-10

11 Specific details of the 8 Level II non-compliances are given in Appendix 1, along with corresponding corrective actions and closure status. 8.2 EXTERNAL MONITORING The main types of external monitoring are outlined in Table 8.1 while the timing of the visits is shown in Table Table 8.10: External-monitoring visits carried out for BTC (excludes regulatory monitoring) Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec IEC SRAP CDAP Completed Provisional Reports from all of these external monitoring visits are available via The sections below outline the main issues raised by these external parties during the quarter, and BTC s response to the findings and recommendations. IEC Table 8.11 presents a log of IEC monitoring visits together with a record of where BTC s responses to issues raised by IEC have been reported. Table 8.11: Log of IEC visits Visit Reference Visit Date Party BTC Response to Findings and Recommendations IEC-Q October 2003 Mott MacDonald Contained in BTC-Q report; Any items still open are contained in this report (Appendix 2) IEC-Q March 2004 D Appolonia Contained in BTC-Q report; Any items still open are contained in this report (Appendix 2) IEC-Q July 2004 D Appolonia Contained in BTC-Q report; Any items still open are contained in this report (Appendix 2) IEC-Q October 2004 D Appolonia All contained in this report BTC-Q (Appendix 2) IEC-Q February 2005 D Appolonia Will be contained in BTC-Q report 15 Note that this audit was pre-financial close. 16 First post-financial close audit. 8-11

12 The IEC visit reports document non-compliances against the ESAP and assigns them a level of importance (using the same categories as BTC). The IEC also verifies closure of BTC s responses to non-compliance as part of subsequent monitoring visits. However, the closure status is not documented in their reports. Appendix 2 contains BTC s response and progress towards implementing and effectively closing out the non-compliances. Items raised by IEC that remain open are reported in the BTC Quarterly Reports until they have been closed. Items that have been closed do not appear in subsequent reports. In adopting this approach, the Project aim to provide the transparency and assurance that measures are being taken to ensure that they are addressed. Such an example is the BTC response to previous non-compliances raised on potable water (see Chapter 9: Health and Safety). The general conclusion of the IEC-Q3 monitoring visit is reproduced in Box 8.4. BOX 8.4. IEC-Q VISIT GENERAL CONCLUSIONS Overall, progress in complying with ESAP commitments in all three countries is positive, but the arrival of the winter season is a critical time for the Project. The peak of construction has passed, at least in Azerbaijan and Georgia, and the timeline for mechanical completion is rapidly closing. The Project has committed to minimise the footprint that will remain after construction has completed. The fulfilment of this commitment in all three countries is not clear, particularly in regard to third party sources of aggregate and access management. Reinstatement progress is far behind schedule in Lots A and B in Turkey and it is doubtful that any significant further ROW reinstatement will occur in More importantly, temporary erosion measures are still not in place in many locations along the ROW in these Lots to protect topsoil and sensitive environmental resources over the winter months. Hydrotesting in Turkey has also been initiated over an incompletely reinstated ROW. In the rush towards mechanical completion and meeting the date for first oil, the Project cannot overlook the importance of initiating closure and ensuring that all ESAP commitments are met during remaining construction activities in all three countries AZERBAIJAN Table 8.12 presents a summary of the non-compliances for Azerbaijan from the IEC-Q monitoring visit. Appendix 2A provides details of all non-compliances, and close out status for Azerbaijan. Table 8.12: Summary of IEC Non-compliances for Azerbaijan, 2004-Q3 Non-compliance Area Non-compliance Level I II III Third party facilities (borrow pits, batch plants) Solid Waste Management Potable Water Waste Water Treatment Plants Hydrotest Noise TOTAL GEORGIA Table 8.13 presents a summary of the non-compliances for Georgia from the IEC-Q monitoring visit. Appendix 2B provides details of all non-compliances, and close out status for Georgia. 8-12

13 Table 8.13: Summary of IEC Non-compliances for Georgia, 2004-Q3 Non-compliance Area Non-compliance Level I II III Solid Waste Management Potable Water / Sustainability Studies ROW Management (Topsoil Management, Open Trench) Pollution Prevention Third party facilities (borrow pits, batch plants) Waste Water Treatment Plants TOTAL In addition to the IEC audit, a second external audit was undertaken in October on BTC s ESMS. The review was conducted by the environmental advisors to the Government of Georgia. No non-compliances were raised TURKEY SRAP CDAP Table 8.14 presents a summary of the non-compliances for Turkey from the IEC-Q monitoring visit. Appendix 2C provides details of all non-compliances, and close out status for Turkey. Table 8.14: Summary of IEC Non-compliances for Turkey, 2004-Q3 Non-compliance Area Non-compliance Level I II III Solid Waste Management Potable Water / Sustainability Studies Waste Water Treatment Plants ROW Management (Reinstatement, NGL Line, Open Trench) Pollution Prevention Third Party facilities (Borrow Pits; Batch Plants) River Crossings TOTAL The SRAP monitoring process is biannual, and aims to provide practical guidance and advice to the Projects management team on the land acquisition and resettlement process and in the management of other social issues, as well as to carry out a compliance review. The results of the most recent SRAP report were presented in the 2004-Q3 Lenders Report. The next audit will take place in February - March The results of this audit will be summarised in the 2005-Q1 Lenders Report. BP established CDAP in January 2003 as an independent external panel providing advice and counsel to the BP Group Chief Executive, Lord Browne. For more detail see the CDAP website, Table 8.15 presents a log of CDAP visits. All CDAP reports and BP s response to them can be found on CDAP visited the region again in October 2004 and their third report will be issued in the first quarter of

14 Table 8.15: Summary of CDAP Visits to Date Reference Date of Visit Scope CDAP 1 March 2003 Azerbaijan and Georgia Economic, Social and Environmental Issues CDAP 2 September 2003 Turkey and Project Related Security and Human Rights Issues in Azerbaijan, Georgia and Turkey Extra visit May 2004 Information gathering on environmental and social aspects by independent consultants to CDAP. CDAP 3 October 2004 Azerbaijan, Georgia and Turkey Economic, Social and Environmental Issues BTC Response to Recommendations / Closure Status Implementation of recommendations tracked at the Business Unit Level. General progress updated in BTC Q3 report. CDAP publish an annual report (expected 2005-Q1) The consultants will provide findings to CDAP. These will be incorporated into the annual CDAP report. Implementation of recommendations tracked at the Business Unit Level. General progress updated in this BTC-Q report. CDAP publish an annual report (expected end 2005-Q1). Following the October visit CDAP provided initial feedback in a letter to the BP Group Chief Executive, Lord Browne, containing draft findings and recommendations. The CDAP letter, and the response to the Panel from BP, has been published on the CDAP website. Whilst being generally favourable about the economic, social and environmental aspects of the BP developments in the Caspian region, CDAP did raise a number of key issues, including: Maintaining high standards in health, safety, environmental and social management through to the end of the construction phase for the various projects; Maintaining the support of Stakeholders in the Region; Ongoing support of sustainable investment initiatives; and Continued promotion of transparency in BP operations, the oil industry and the Region HOST GOVERNMENT MONITORING AZERBAIJAN The Ministry of Ecology and Natural Resources (MENR) conducted ecological monitoring along the BTC Pipeline ROW in December This involved a review of all construction activities and addressed key issues such as waste management. Positive interim feedback was received upon completion of the visit. Formal feedback has been requested. Ongoing discussions have been held with the MENR regarding approvals for certain activities including the river crossing of the Hassan Su. The MENR was notified in writing of two instances of non-compliant discharge of small volumes of hydrotest (depressurisation) water. A joint review of the "Omnibus Land Lease Agreement" package with the Ministry of Fuel and Energy, State Land and Cartography Committee and Ministry of Justice was completed. 8-14

15 GEORGIA The Government of Georgia (GoG) Environmental Advisor Team of Auditors (experts from Ministry of Environment (MoE), GIOC and BEICIP who are advisors to the MoE and funded by the World Bank) continued performing their regular environmental compliance audits during this reporting period. This included an audit of the BTC Environmental and Social Management System, undertaken in October The audit report was received at the end of November and raised no non-compliances. BTC is continuing discussions with the MoE regarding development and implementation of a conditioning improvement plan for the Iagluja Municipal Waste Disposal Site. TURKEY In addition to regular State authority meetings, Botaş and BTC facilitate regulatory monitoring along the ROW. The monitoring activity provides the state ministries with the opportunity to observe environmental issues on site and provide feedback to the project. Botaş coordinates this activity with support from BTC. BTC conducted meetings in all 10 provinces along the ROW in December. These meetings were attended by State authorities, local NGOs, universities and members of the press. In addition, BTC met and consulted with the Governors of the 10 provinces (see Chapter 6). In Turkey in Q3, representatives from Ministry of Environment and Forestry visited Lot A, PT1 and PT2 to undertake environmental monitoring. The Project anticipated being in a position to comment on the results of the monitoring in this quarterly report, however Botaş is still awaiting formal feedback NGO MONITORING NGO monitoring of the Project was a recommendation made by the CDAP panel. BTC is working to facilitate national NGO monitoring of the BTC Project in all three countries. The background and objectives were described fully in the BTC-Q and BTC-Q reports. The current status of the NGO monitoring programmes in each country is provided below. AZERBAIJAN In Azerbaijan, monitoring is being coordinated and facilitated via Open Society Institute Azerbaijan (OSI). OSI is responsible for facilitating the process by which the NGOs have chosen monitoring themes, teams and timeframes; co-ordinating the capacitybuilding; helping to co-ordinate visits; and liasing between BP and the NGOs. The Local Content, Cultural Heritage, Land/Worker Rights, Environmental and Social Working Groups (WGs) all completed their data-gathering phase during the quarter, which included field visits and meetings with BTC staff. The NGOs received planning and report writing guidance from OSI and an audit expert contracted by OSI. More information is presented in Chapter 5. Reports will be submitted to BTC for review in February 2005 and subsequent responses will be published in March A second cycle of monitoring is planned for 2005, with emphasis on continued capacity building. The NGOs will have an opportunity to evaluate aspects of the SCP construction as well. Details of other meetings held between BTC and NGOs during the quarter are provided in Chapter

16 GEORGIA Eurasia Foundation (EF) is the facilitating organisation for monitoring by NGOs in Georgia. EF is receives financial assistance from IFC and UNDP and logistical assistance from BP. The initial meeting with interested local NGOs is scheduled to take place in January It is anticipated around 20 local NGOs will be involved, and that there will be four main monitoring themes: Social, Environmental, Human Rights and Cultural Heritage. Training in audit techniques and ongoing mentoring and support will be provided to the NGOs, as in Azerbaijan. BTC staff will be providing presentations and information about the Project to the NGOs. OSI in Baku have offered to share their experiences with Eurasia Foundation. Further such shared learning exercises will be encouraged. It is currently envisaged that reports will be produced by the NGOs in 2005-Q2. TURKEY In Turkey a facilitating/capacity building organisation is not being used as many national NGOs are already involved in the Project, their experience is generally greater, and there was a lack of demand for a facilitated scheme. NGOs have full access to the biannual Provincial meetings and to the annual meetings, which are held in Ankara and Istanbul. The Q4 meetings are described in Chapter 6, section In December a round of stakeholder meetings was held in all the provinces along the ROW. Meetings were held with local and provincial authorities and with community stakeholders, media and NGOs. A further round of stakeholder meetings both in the Provinces and in Ankara and Istanbul, are planned in 2005-Q