Engineering Procedure

SAEP-32 10 December 2014

Environmental Performance Assessment (EPA) Program
Document Responsibility: Environmental Standards Committee

Saudi Aramco DeskTop Standards

Table of Contents

1 Scope............................................................. 2
2 Applicable Documents.................................... 2
3 Terms and Definitions.................................... 4
4 Program Objectives........................................ 4
5 Instructions..................................................... 5
6 Responsibilities............................................ 11

Appendix A – Overview of Typical

Survey Activities................................... 14
Appendix B – Minor Findings Close Out Form... 15

Previous Issue: 14 February 2011 Next Planned Update: 10 December 2014

Primary contact: Findley, James Eric (findleje) on +966-13-8809761

Copyright©Saudi Aramco 2014. All rights reserved.

Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

1 Scope

This SAEP describes the procedures for the administration and implementation of the
Environmental Performance Assessment (EPA) Program. The purpose of this program
is to conduct periodic facility surveys to determine compliance with Saudi Aramco's
environmental requirements, as well as related Saudi government requirements.

2 Applicable Documents

All EPA surveys shall evaluate proponents compliance with the applicable documents
listed in this section.

2.1 Saudi Aramco References

Saudi Aramco Engineering Procedures

SAEP-302 Instructions for Obtaining a Waiver of a Mandatory
Saudi Aramco Engineering Requirement
SAEP-327 Disposal of Wastewater from Cleaning, Flushing,
and Dewatering Pipelines and Vessels
SAEP-339 Marine dredging and Landfilling Approval and
Permitting
SAEP-340 Air Quality Impact Analysis and Assessment
SAEP-1661 Waste Minimization Assessments

Saudi Aramco Engineering Standards

SAES-A-007 Hydrostatic Testing Fluids and Lay-Up Procedures
SAES-A-102 Ambient Air Quality and Source Emission Standards
SAES-A-103 Discharges to the Marine Environment
SAES-A-104 Wastewater Treatment, Reuse and Disposal
SAES-A-111 Borrow Pit Requirements
SAES-A-115 Groundwater Monitoring Well Design, Installation,
and Decommissioning
SAES-B-005 Spacing and Diking for Atmospheric and Low-
Pressure Tanks
SAES-D-116 Underground Storage Tank System
SAES-S-007 Solid Waste Landfill Requirements
SAES-S-010 Sanitary Sewers

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

SAES-S-020 Oily Water Drainage System

SAES-S-030 Storm Water Drainage Systems

Saudi Aramco Policy Statement

SAPS No. INT-5 Environmental Protection Policy

Saudi Aramco General Instructions

GI-0002.104 Leak and Spill Reporting
GI-0002.400 Offshore Oil Spill Reporting Procedures
GI-0002.401 Inland Oil Spill Response
GI-0002.714 Environmental Protection Policy Implementation
GI-0002.717 Procedures and Guidelines for Handling
Polychlorinated Biphenyls (PCBs)
GI-0006.004 Near Miss Reporting Process
GI-0151.006 Implementing the Saudi Aramco Sanitary Code
GI-0425.000 Management of CFC & HCFC Refrigerants
GI-0430.001 Implementing the Saudi Aramco Hazardous Waste
Code

Saudi Aramco Forms and Data Sheets

GI-6.004 (Supplement 1) Near Miss Report Form
SA 3140 Marine Accident Report
SA 8037 Land Use Permit
SAP EHS (PRC-WAM03) Waste Manifest

2.2 Government Requirements

General Standards Environmental Protection Standards in the
Document No. 1409-01 Kingdom of Saudi Arabia - Presidency for
& Revisions Meteorology and the Environment (PME)
PME National Plan to Combat Pollution from Oil and
Other Harmful Substances in Emergency
Situations
ROPME Protocol Concerning Marine Pollution Resulting
from Exploration and Exploitation of the
Continental Shelf

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

Royal Commission for “Royal Commission Environmental Regulations,”

Jubail and Yanbu Volume I & Volome II, 2004
Royal Decree No. M/9 Regulations for Fishing, Exploitation and
Protection of Marine Life in Saudi Territorial
Waters, November 18, 1987

3 Terms and Definitions

EPA: Environmental Performance Assessment

EED: Environmental Engineering Division

EH&S: Environmental, Health and Safety

EPD: Environmental Protection Department

Finding: Results of the evaluation that are not in compliance with policies, procedures
or requirements.

SAP: It is a company that provides business database software, solutions, applications

and services used by Saudi Aramco in different Organizations.

Survey: General or comprehensive view of or appraise, as a situation, area of study, etc.

4 Program Objectives

The EPA Program was developed in response to Saudi Aramco's Environmental

Protection Policy (INT-5) Statement, which commits the Company to manage and
conduct its activities in an environmentally responsible manner. Implementation of this
policy is provided under GI-0002.714 and promotes protection of the environment,
conservation of natural resources, and protection against liability. The objectives of the
EPA Program are to:
 Assess the environmental performance of Saudi Aramco operating organizations to
ensure proponents compliance with applicable documents listed in Section 2.
 Identify significant environmental compliance issues in Environmental Engineering
(air quality and emissions, wastewater discharges, management of solid, liquid, and
hazardous materials, groundwater quality, spill prevention and control).
 To ensure that major findings (i.e., areas of noncompliance) are appropriately
resolved.
 To provide annual reports to corporate management on the status of the EPA
Program.

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

5 Instructions
Commentary Note:

For further details, refer to the EPA Program Manual and the Team Leader's Handbook
issued by the Environmental Protection Department. The overview process for the EPA
surveys is shown in the Appendix A.

5.1 Planning Activities

5.1.1 Proponent Organization Selection and Scheduling

The Environmental Protection Department (EPD) selects facility or

group of facilities, to be surveyed during the following calendar year.
Selection is based on:
a) The potential impact of the operations on the environment.
b) Continuing compliance problems and/or complaints.
c) Available environmental monitoring data, recommendations and
feedback received from Environmental Engineering Division
(EED) specialists.
d) Current or planned operational status at the facility.
e) Requests by Proponent Departments.

The survey frequency for different types of operations is shown in Table1:

Table 1 – EPA- Survey Frequency

Frequency (years)
Type Operation
Min. Max.
Refineries, Oil/Gas Plants 3 5
Production facilities, Drilling Operations,
5 7
Distribution, Pipelines and Terminals
Industrial Services, Community Services,
7 9
Medical Services

Proponent Organization selection shall be confirmed in November of the

year preceding the surveys.

All facilities administered by the proponent organization should be

included in the survey, whether or not the land used is under its ownership.

Mothballed facilities will be surveyed to ensure that there are no

unresolved environmental violations. Abandoned facilities will be
surveyed on a case-by-case basis.

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

5.1.2 Survey Team Selection

EPD determines the number of survey team members and the type of
expertise needed for each survey, based upon the type and complexity of
the facility.

The Team Leader and one representative team member from each
discipline – Air Quality & Meteorology Unit, Wastewater Management &
Marine Protection Unit, Land & Groundwater Protection Unit - shall be
provided by EED. Specialists from other EPD divisions might be invited
to participate if the facility conditions and characteristics require it.

Other Company Departments may be requested to provide

representatives whose specialized technical knowledge will contribute to
the effectiveness of the EPA Program.

The proponent department shall provide a facilitator during the survey.

This facilitator will assure security access and logistics support.
The facilitator must prepare and provide relevant documentation for the
survey. The facilitator is not considered to be a survey team member.

Survey team composition is finalized by November of the preceding year.

5.2 Pre-Survey Activities

5.2.1 Security Access

Once the facility selection is confirmed by the proponent department, the

proponent facilitator must inform EED of all requirements to access their
facilities at the time of the survey. Requirements might include special
training and/or special passes (e.g., H2S training, Helicopter Certification,
etc.).

EED will request the security access according to EPA Manual procedure.

5.2.2 Pre-Survey Information

Minimum four (4) weeks prior to the on-site visit, the proponent
department will provide EED with all information requested by EED.

This information mainly consists of the pre-survey questionnaire that is

released by EPD through SAP EH&S to the proponent. The questionnaire
must be completed and entered on SAP EH&S as support documentation
for the survey and future surveys.

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

5.2.3 Team Preparation and Documentation Review

The team members prepare for the survey by familiarizing themselves

with the facility organization and functions. All previous EPA reports
should be reviewed, as well as documentation regarding past
environmental problems, non-compliance incidents and formal
complaints. The Team reviews the pre-survey information input in
SAP EH&S by the proponent and may ask the proponent to submit
additional information that will help prepare the EPA team for their visit.

5.3 On-site Survey Activities

5.3.1 Opening Meeting

The EPA Opening Meeting is held before the site visit commences and is
organized and presided by the EPA Survey Team Leader. In attendance
are the survey team, the Proponent Manager, appropriate facility
supervision (as invited by the manager) and proponent facilitator.
The purpose of the Opening Meeting is to introduce the EPA survey
team and facility management, give an overview of the EPA process,
clarify any areas of uncertainty, discuss site details and logistics, and set
a time and location for the Closing Meeting.

5.3.2 Collecting and Verifying Information

During the site visit, the EPA team members might request to the
proponent department provides additional information for review.
This documentation may include procedures, licenses and permits,
records of monitoring and results of measurements. The team will verify
the information given by the proponent during the pre-survey stage.

5.3.3 Field Visit

The survey team will assess the facility's environmental performance by

evaluating compliance with the Company documents listed in Sections
2.1 through 2.3. The duration of the survey varies according to the size,
nature and complexity of the organization. This duration is established
during the planning activities described in section 5.1.1.

The environmental items to be reviewed and evaluated during the survey,

as a minimum are:
 Air pollutant emissions and air quality problems
 Wastewater discharges and management
 Solid and hazardous waste disposal and management

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

 Environmental monitoring, testing & sampling program data

 Spill containment and contingency planning
 Environmental incidents reporting
 Environmental awareness campaigns and training
 SAP EH&S waste manifest records
 Verification of the pre-survey information sent by the proponent.

To assess the items listed in this section, the survey team should walk
through and inspect the facility, interview personnel, review pertinent
files, and investigate facility procedures. Checklists are required to be
used by the team members as a reminder of things to look for and to
document findings.

The survey team will check the status of the minor findings from
previous EPA survey. Unresolved minor findings may be elevated to
major status in the current EPA survey.

Each EPA is an independent survey and will be managed as such. The

survey team shall ensure that major findings are not repeated from
previous EPA surveys. Findings from each survey will be tracked
separately.
Commentary Note:

EPD has the right to add an EPA finding to any proponent organization
outside the scheduled EPA event if serious violations have been reported
to EPD/EED either by an entity inside or outside the company. EPD/EED
will investigate the violation, evaluate its seriousness and will decide
whether or not will be considered an EPA finding. This will be
communicated to the proponent organization in writing signed by the
General Supervisor of EPD/EED.

5.3.4 Summary Report and Closing Meeting

After completion of the onsite survey and initial data evaluation, the team
shall prepare a Summary Report that contains the major and minor
findings. This report will be presented in a closing meeting. In attendance
are the survey team, the proponent manager, and appropriate facility
supervision (as invited by the manager). Three types of findings may be
reported:
a) Major findings are items that conflict with a Saudi Arabian
government and/or Saudi Aramco environmental requirement,
and/or represent significant cost to the Company if left unresolved,

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

and/or could have a significant adverse effect on the environment if

unresolved. The findings should be supported by reference to a
specific mandatory requirement.
b) Minor findings are issues that should be brought to the attention of
facility management. These are generally findings that can be
resolved within 6 months and may require some local funding.
The facility should seek to permanently resolve these findings as
soon as possible.
c) Exceptional efforts and/or best practices will be highlighted.
EPD recognizes and promotes environmental commitment.

The Summary Report is presented to facility management at the Closing

Meeting, which is normally held the last day of the site visit. The team
presents all findings, highlighting items that need immediate attention
and those that require significant capital expenditure. A copy of the
Summary Report is left with facility management.

The Summary Report will be included as an attachment to the EPA Final

Report and will be attached to the SAP EH&S notification which will be
opened for the tracking of the major environmental findings.

5.4 Post - Survey Activities

5.4.1 Final Report

The Survey Team Leader is responsible for issuing and circulating a

draft report to the team members and the EPA Program Coordinator
within three (3) weeks of completion of the site visit. The Final Report
shall be completed within four (4) weeks of the site visit and is sent to
the Proponent Manager.

Concurrently, EED will originate a SAP EH&S notification with all

major findings described in the final report and initiate a workflow.
The SAP workflow is approved by EPD manager and is sent to the
proponent manager.

The written Final Report and Summary Report will be attached to the
SAP EH&S notification.

SAP EH&S system is considered to be the company's official database

for reporting and tracking the major EPA findings.
Note: A year-end annual report is submitted to corporate and executive
management by the Vice President, Engineering Services,
summarizing all of the EPA surveys completed to date and the

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

progress made by facilities in resolving major findings as per the facility

action plans.

5.4.2 Proponent Organization Action Plan

After receiving and reviewing the Final Report and receiving SAP
workflow, the proponent shall complete the action plan for each finding
through SAP EH&S, which addresses resolution of the major findings.
This plan, with estimated dates of completion, shall be input into the SAP
system within four weeks of receipt of the Final Report.

The proponent shall resolve the major findings within the estimated dates
of completion (EDC), using appropriate Company resources as needed.

EPD concurrence with this Action Plan is necessary to ensure prompt

closure. If the EDC must be revised, department head approval is
required for the first revision and admin area head approval is required
for the second revision.

Proponents should provide pertinent and verifiable documentation to

support closure of major findings. Relevant documentation should be
attached to the SAP EH&S notification in support of closure.
Field verification of implementation may be conducted by the EPD.

Minor findings should be resolved in no more than one year.

These findings will be will be tracked in a separate database so that they
can be re-evaluated at the next scheduled survey and, if unresolved, may
be elevated to “major” status.

The proponent must inform the EPA Coordinator of the closure of each
minor finding using the format in Appendix B.

5.4.3 Survey Follow-up

EPD will request that the proponent department update the status of the
major findings every 6 months. An automatic status request message
will be sent by EPD through SAP EH&S. This automatic message will
be received by the proponent manager and proponent environmental
coordinator until the findings are resolved to the satisfaction of EPD.

Proponent's updates will be reviewed by EED specialist and commented

accordingly.

A finding involving project action is not considered ‘closed’ until the

project has been completed and commissioned. Copy of the commissioning
certificate should be attached to the SAP EH&S notification.

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

Where a regulatory agency is involved, a letter indicating the solution

has been accepted or approved by that agency is required. Copy of the
approval letter should be attached to the SAP EH&S notification.

EPD shall have final concurrence on the resolution and authorize closure
of all major findings.

6 Responsibilities

6.1 Environmental Protection Department

 Is responsible for the administration, coordination, and execution of the EPA
Program.
 Shall finalize facility selection by September, and the survey team
composition by November of the preceding year.
 Shall circulate the draft EPA Final Report within three (3) weeks of the site
survey to the team members and EPA Program Coordinator for comments,
and shall distribute the Final EPA Survey Report within four (4) weeks of
the site survey.
 Shall originate and approve a SAP EH&S notification with all major
findings information contained in the final report.
 Shall initiate a SAP workflow, and send the SAP notification to the
proponent manager.
 If requested, EPD shall provide consultation on the development of a
corrective action plan for the facility.
 Shall request the Proponent Department via SAP EH&S to update the status
of all open items on their action towards resolving the major findings every
six (6) months, until the findings are resolved.
 Shall track the findings via SAP EH&S and work with the Proponent
Department to ensure resolution.
 Shall prepare an Annual Report for submission to Corporate and Executive
Management that summarizes all of the EPA surveys conducted to date and
the progress made by facilities in resolving major findings.

6.2 Proponent Organization

 The Proponent Department shall provide a facilitator with the qualifications,
environmental knowledge and experience. Facilitator must provide pre-

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

survey information requested by EED, relevant documentation, maps and

drawings.
 Proponent Department shall provide any information requested by EPD
within the deadline stipulated by EPD during the pre-survey activities stage,
section 4.2.
 The Proponent Department shall provide access and logistical support to the
survey team to inspect its facilities, interview its employees, and review its
documents.
 The Proponent Department shall submit a facility action plan for the
resolution of major findings (if any) within four (4) weeks of receipt of SAP
EH&S workflow and EPA Final Report.
 The Proponent Department shall track the resolution of all findings and
provide six (6) months periodic status for major open findings as outlined in
Section 4.4.3. Proper documentation will be uploaded in SAP EH&S to
support closure of resolved findings.
 The proponent department must inform EED of the closure of minor
findings using the format in Appendix A.
 The proponent department shall provide a person to be responsible for the
follow up of all environmental findings via SAP EH&S and to be the contact
point between the proponent and EED.
 The proponent department shall inform the EPA team of all facilities that are
under his ownership. Also, all mothballed and abandoned facilities shall be
noted and known in advance.
 The proponent department shall inform the EPA team of all facilities under
their administration. Also, all mothballed and abandoned facilities shall be
noted in advance.

6.3 Support Departments

If requested to participate, support departments shall provide specialized

technical representatives that will contribute to the thoroughness of the EPA
program.

6.4 EPA Survey Team

 The EPA Team Leader shall direct the course of the survey. This may include
assigning tasks to team members in order to efficiently utilize their expertise.
 The EPA team members shall participate full-time during the onsite survey.

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

 The team members shall finalize their findings by the end of the survey
period and present them in a Summary Report at the Closing Meeting.
They shall assist the Team Leader in preparing the EPA Final Report.
 The team members shall review proponent updates for open findings and
provide feedback on the proponent's actions via SAP EH&S.
Commentary Notes:

For SAP EH&S Waste Manifest findings, EPD will not close the finding
until it sees that proponent has used the system for at least one full year.
This policy can also be extended to other findings in which the proponent did
not do the required documentation (e.g., water disposal approval form).

For closures of any finding that requires operation of new equipment or

changing how operations do something, six months of data demonstrating
compliance with the finding is required for closure.

Revision Summary
10 December 2014 Revised the Next Planned Update, reaffirmed the content of the document, and reissued
as major revision.

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

Appendix A – Overview of Typical Survey Activities

Planning Activities

 Facility selection and scheduling

 Survey team selection

Pre-Survey Activities

 Security access
 Pre-survey information
 Team preparation and
documentation review

Survey Activities

 Opening meeting
 Field visit
 Collecting and verifying
information
 Summary report and closing
meeting

Post-Survey Activities

 Preparing the final survey report

 Approving and distributing final
survey report (written & via SAP
EH&S)
 Facility Action Plan
 Survey follow-up

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Document Responsibility: Environmental Standards Committee SAEP-32
Issue Date: 10 December 2014
Next Planned Update: 10 December 2019 Environmental Performance Assessment (EPA) Program

Appendix B – Minor Findings Close-Out Form

MINOR FINDINGS CLOSE OUT FORM

Date:
EPA Number & Survey Date

Minor Finding No & Description

Recommendation Description

Actions involved & Recommendation Status

Reason for modifying the Recommendation, if applicable

Identification of key documents (i.e., Work Order #, MCC, etc.)

Completion Confirmation
Processor Name Signature Date

Accepted
Environmental Name Signature Date
Coordinator

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