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Guidance on Practice for UXO Risk Mitigation Strategy for Projects GP 04-80 BP GROUP ENGINEERING TECHNICAL PRACTICES Document No. GP 04-80 Applicability Group Date 23 November 2005

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Page 1: GP 04-80  23-Nov-2005

Guidance on Practice for UXO Risk Mitigation Strategy for Projects

GP 04-80

BP GROUP ENGINEERING TECHNICAL PRACTICES

Document No. GP 04-80

Applicability Group

Date 23 November 2005

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Foreword

This document is the first of two of Group Engineering Technical Practices ETP GP 04-80 and GP 04-81 on the development and implementation of an UXO RMS.

The aim of these Guidelines is to ensure that BP’s people, projects and reputations are protected from the affects of encountering UXO contamination as part of the HSSE plan.

The guidelines are in two parts:

• GP 04-80 supports business development managers and projects to evaluate the potential threat to their programme posed by UXO contamination in order to then develop the appropriate RMS.

• GP 04-81 provides guidance on the implementation of the selected UXO RMS.

These guidelines show how UXO RMS is aligned to the CVP.

Copyright 2005, BP Group. All rights reserved. The information contained in this document is subject to the terms and conditions of the agreement or contract under which the document was supplied to the recipient’s organization. None of the information contained in this document shall be disclosed outside the recipient’s own organization without the prior written permission of Director of Engineering, BP Group, unless the terms of such agreement or contract expressly allow.

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Table of Contents

Page

Foreword ........................................................................................................................................ 2

1. Scope .................................................................................................................................... 5

2. Normative references............................................................................................................. 5

3. Terms and definitions............................................................................................................. 6

4. Symbols and abbreviations.................................................................................................. 10

5. Application ........................................................................................................................... 11 5.1. General..................................................................................................................... 11 5.2. Principles .................................................................................................................. 11 5.3. Schematic................................................................................................................. 11 5.4. Alignment of UXO RMS to capital value process ...................................................... 12

6. Strategic options.................................................................................................................. 13 6.1. General..................................................................................................................... 13 6.2. Do nothing ................................................................................................................ 13 6.3. UXO risk education................................................................................................... 13 6.4. Avoid contaminated sites .......................................................................................... 13 6.5. Re-engineer the solution........................................................................................... 13 6.6. UXO clearance operations........................................................................................ 13

7. UXO risk assessment .......................................................................................................... 14 7.1. Conduct of assessments........................................................................................... 14 7.2. Land use................................................................................................................... 14 7.3. General assessment ................................................................................................. 15 7.4. Environment assessment.......................................................................................... 16 7.5. ALERT...................................................................................................................... 16 7.6. Initial assessment ..................................................................................................... 16 7.7. Technical investigation.............................................................................................. 18 7.8. UXO risk workshops ................................................................................................. 20

8. UXO RMS development....................................................................................................... 22 8.1. General..................................................................................................................... 22 8.2. “Access” phase ......................................................................................................... 23 8.3. CVP appraise stage.................................................................................................. 24 8.4. CVP select & define stages....................................................................................... 24 8.5. CVP execute............................................................................................................. 26 8.6. CVP operate ............................................................................................................. 27

9. UXO RMS management ...................................................................................................... 27 9.1. GP maintenance ....................................................................................................... 27 9.2. GP implementation ................................................................................................... 28

10. Training ............................................................................................................................... 28

Annex A (Informative) UXO RMS Principles ................................................................................. 29

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Annex B (Normative) Schematic of the UXO RMS........................................................................ 30

Annex C (Normative) Alignment of UXO RMS to CVP .................................................................. 31

Annex D (Informative) Typical Risk Analysis – Hazard Identification............................................. 32

Annex E (Informative) Project UXO Hazard Analysis Risk Matrix.................................................. 33

Annex F (Informative) Project UXO Risk Mitigation Recommendations......................................... 34

Bibliography.................................................................................................................................. 35

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1. Scope

This GP defines the process and detailed procedures for the production of an UXO RMS and is in line with International Standards developed by the United Nations as the IMAS, ISO 9001, and ISO Guides 51 and 2859.

Whereas IMAS is centred on the removal of landmines in regions of conflict by humanitarian organisations, this GP uses these established standards of good practice for operations containing all manner of unwanted explosive ordnance. Therefore, where IMAS refers to “mines”, this GP refers to UXO both on land and offshore. The key premise of IMAS is that the contaminated area in question should be made “fit for purpose” while ensuring the safety of both the site users and the EOD Contractors through the internal adoption and external verification of a prescribed quality management regime.

The overall objective of the UXO RMS is to assure the client Business Unit that a systematic process for identifying and assessing the potential risk posed by UXO to personnel and projects is in place in order to determine and implement the most appropriate and proportionate means of risk mitigation. It provides quantifiable assurance that land or seabed is fit for purpose. The assurance that the land or seabed is fit for purpose is provided by the processes used and by reviewing the project at various key stages in its development to ensure the right things are happening at the right time and being done to the correct standard.

UXO RMS is an element of a project’s HSSE Plan; as such, it should look at not only the safety and security issues surrounding UXO contamination but the environmental ones as well. This GP provides guidance for Business Unit Leaders and Project Managers on the development of a UXO RMS and indicates links with the CVP (Ref. 2). UXO RMS contributes to the HSSE element of the Decision Support Package required at each gate of the CVP.

It should be noted that this GP is written around the development and implementation of a UXO RMS in support of the main construction activity for a project. Business Unit Leaders need to consider their duty of care to their Survey, Drilling, and Environmental assessment teams that deploy early to a site. The process and options remain the same just the scale of activity is likely to differ.

The O&G industry’s experience of UXO shows that it can have a significant impact on projects.

2. Normative references

The following normative documents contain requirements that, through reference in this text, constitute requirements of this technical practice. For dated references, subsequent amendments to, or revisions of, any of these publications do not apply. However, parties to agreements based on this technical practice are encouraged to investigate the possibility of applying the most recent editions of the normative documents indicated below. For undated references, the latest edition of the normative document referred to applies.

International Mine Action Standards (IMAS) IMAS 01.10 Guide for the application of International Mine Action Standards. IMAS 04.10 Glossary of Terms and Definitions.

International Organization for Standardization (ISO) ISO 9000 Quality management systems – Fundamentals and vocabulary. ISO 9001 Quality management systems – Requirements. ISO Guide 51 Safety aspects – Guidelines for their inclusion in standards.

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ISO Guide 2859 Sampling procedures for inspection by attributes.

BP GP 48-50 Guidance on Practice for Major Accident Risk Process. GP 48-1 Guidance on Practice for HSSE Review of Projects. E&P risk management guidelines for major projects.

3. Terms and definitions

For the purposes of this GP, the following terms and definitions apply:

AAP6 AAP 6 is the document that defines NATO terms.

Alert (http://projects.bpweb.bp.com/alert/) ALERT is a structured and facilitated session to discuss the risk and uncertainties of a project. It is usually conducted in the Appraise stage of project development to enable early management intervention and to promote development of effective risk management and opportunity capture plans.

Accreditation The procedure by which an organisation is formally recognised as being competent and able to plan and manage UXO risk mitigation activities safely, effectively and efficiently.

Bomblet, (see submunition)

Clearance (explosive ordnance clearance) Tasks or actions to reduce or eliminate the explosive ordnance (EO hazard) from a specified area in order to provide land fit for use. [NATO study 2187]. This can also be referred to as Explosive Ordnance Disposal (EOD) operations.

Cleared Area An area that has been physically and systematically processed by a demining organisation to ensure the removal and /or destruction of all mine and UXO hazards to a specified depth. [IMAS]

Destroy (destruction) in situ [“blow in situ”] the destruction of any item of ordnance by explosives without moving the item from where it was found, normally by placing an explosive charge alongside.

Disarm The act of making a mine (munition) safe by removing the fuse or igniter. The procedure normally removes one or more links from the firing train.

Disposal The final acts that removes the hazards presented by a UXO. The final disposal of explosive ordnance which may include demolition or burning in place, removal to a disposal area or other appropriate means. [AAP-6]

Note: In a number of countries, the final “Disposal” of UXO remains the responsibility of the national authority.

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Early Assessment (EA) The first part of a GA the aim of which is to determine whether there is evidence of potential UXO contamination within a broad project footprint and local environs.

Environmental Impact Assessment (EIA)/ Environmental and Social Impact Assessment (ESIA) A process to assess the potential impact and environmental (/ social) improvement opportunities of all stages of the future development on the surrounding environment (and social conditions).

Explosive Ordnance All munitions containing explosives, nuclear fission or fusion material, and biological and chemical agents. This includes bombs and warheads, guided and ballistic missiles; artillery, mortar, rocket and small arms ammunition; all mines, torpedoes and depth charges; pyrotechnics; clusters and dispensers; cartridge and propellant devices; electro-explosive devices; clandestine and improvised explosive devices; and all similar or related items or components explosive in nature [AAP-6].

Explosive Ordnance Disposal (EOD) The deliberate searching for (detection), identification, evaluation, render safe, recovery/removal and destruction/fin al disposal of unexploded ordnance.

Note: For the purpose of GP 04-80 & GP 04-81, the term EOD should be considered to cover all the services provides by an EOD authorities, agencies, and contractors in support of a project’s UXO Risk Mitigation Strategy including the delivery of Mine Risk.

Explosive Ordnance Disposal (EOD) Consultant EOD Consultants provide advice on managing EOD programmes. This may include putting in place management systems, the conduct of UXO Risk assessments, the production of UXO RMS and the audit of working systems.

Explosive Ordnance Disposal (EOD) Contractors This covers contractors employed to deliver Mine Risk Education, Technical Investigation (TI), Clearance, Disposal and QA/QC.

Note: In a number of countries the final “Disposal” of UXO remains the responsibility of the national authorities.

Explosive Ordnance Safety and Awareness Briefing (or Training), (see Mine Risk Education).

General Assessment (GA) The continuous process by which a comprehensive inventory can be obtained, and developed, of all reported and/or suspected locations of UXO contamination, the quantities and types of explosive hazards, and information on local land and sea conditions. This includes but is not limited to: soil characteristics, vegetation, geology, hydrography and climate; and assessment of the scale and impact of the UXO problem on the project or activity.

Note: For the purpose of GP 04-80 & GP 04-81, the term GA covers the rolling assessment of the UXO risk to a project or activity. The GA encompasses the Early Assessment, the Initial Assessment, the Risk Estimation, the Risk Workshops and Technical Investigations.

Hazard Potential source of harm from items of UXO or component parts.

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[based on ISO Guide 51:1999(E)]

Initial Assessment (IA) A stage in the General Assessment the aim of which is to quantify, by type, the potential UXO contamination within a project footprint. The IA examines:

• The probability of the risk event occurring.

• The potential impact of the risk if it occurs.

• The ranges of uncertainty in impact and probability.

• The risk rating (a function of probability and impact).

• And advice on how easily the risk can be managed.

International Mine Action Standards (IMAS) IMAS provides a framework of international standards and guidelines, sponsored by the United Nations, for Mine action. The aim is to improve safety and efficiency in mine action by promoting the preferred procedures and practices at both headquarters and field level.

Note: IMAS provides the only internationally agreed standards that cover EOD operations.

Note: IMAS allows for National and other Military standards to be at variance the central standard.

Mine Risk Education A process that promotes the adoption of safer behaviours by at-risk groups, and that provides the links between affected communities, other mine action components, and other sectors. [IMAS 04.10].

Note: For the purpose of GP 04-80 & GP 04-81 the term MRE cover the training and education of Company and contractor staff in the risks associated with operating in a UXO contaminated area and the measures that they need to take in order to mitigate the risk they face.

Munitions (Also “Ammunition”) - A complete device charged with explosives, propellants, pyrotechnics, initiating composition, or nuclear, biological or chemical material for use in military operations, including demolitions [AAP-6].

Neutralise The act of replacing safety devices such as pins or rods into an explosive item to prevent the fuse or igniter from functioning.

Note: It does not make an item completely safe as removal of the safety devices will immediately make the item active again.

Note: A mine is said to be neutralised when it has been rendered, by external means, incapable of firing on passage of a target, although it may remain dangerous to handle. [AAP-6]

Probability Impact Grid A diagram depicting the importance of a risk and which plots probability on the x-axis and impact on the y-axis

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Quality Assurance (QA) Part of quality management focused on providing confidence that quality requirements will be met [ISO 9000].

Note: The purpose of QA is to confirm that management practices and operational procedures for EOD are appropriate and will achieve the stated requirement in a safe, effective and efficient manner. Internal QA will be conducted by EOD organizations themselves; but, external inspections by an external monitoring body should also be conducted.

Quality Control (QC) Part of quality management focused on fulfilling quality requirements [ISO 9000].

Note: QC relates to the inspection of a finished product. The 'product' is safe cleared land.

Random Sampling The selection of samples by a process involving equal chances of selection of each item. Used as an objective or impartial means of selecting areas for test purposes.

Render Safe Procedure (RSP) The application of special EOD methods and tools to provide for the interruption of functions or separation of essential components to prevent an unacceptable detonation.

Remedial EOD Work EOD work completed by Project coordinated EOD resources when an item of UXO is discovered on the Project construction footprint after it has been released for construction.

Residual UXO Risk The risk from UXO that remains at a location when a Project releases an area to a contractor for construction or other activities.

Risk Estimate An appraisal of the UXO risk to a project or associated activity that identifies the hazards, assesses their impact and proposes response options.

Sampling A defined procedure whereby part or parts of an area of cleared land are taken, for testing, as a representation of the whole area.

Small Arms Ammunition (SAA) Ammunition with a calibre of less than 12,5 mm.

Note: Although potentially dangerous the risk posed is less than that posed by UXO.

Submunition Any munition that, to perform its task, separates from a parent munition. [AAP-6]

Technical Survey (TS)/ Investigation (TI) The detailed investigation of known or suspected UXO contaminated area identified during the planning phase employing visual techniques and equipment in order to gain a more detailed

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understanding of the type, level and extent of the UXO contamination within a specified area to a specified depth. Such areas may have been identified during the general mine action assessment or have been otherwise reported.

UneXploded Ordnance (UXO) Explosive ordnance that has been primed, fused, armed, or otherwise prepared for use or used. It may have been fired, dropped, placed, launched, or projected yet remains unexploded either through malfunction or design, or for any other reason.

Note: For the purpose of GP 04-80 & GP 04-81 the term includes all explosive ordnance, munitions or parts thereof that might be encountered, irrespective of whether it has been prepared for use or not.

UXO Risk Mitigation Strategy A systematic process for identifying and assessing the risk posed by UXO to personnel and projects in order to determine and implement the most appropriate and proportionate means of mitigation. It provides quantifiable assurance that land and seabed is fit for purpose.

War Grave Ship or aircraft containing human remains or individual bodies that are casualties of war.

4. Symbols and abbreviations

For the purpose of this GP, the following symbols and abbreviations apply:

ALARP As Low as Reasonably Practicable

BUL Business Unit Leader

CVP Capital Value Process (project management process)

DSP Decision Support Package

EIA Environmental Impact Assessment

ESIA Environmental and Social Impact Assessment

EOD Explosive Ordnance Disposal

FEL Front End Loading

HSSE Health, Safety, Security and Environmental

IMAS International Mine Action Standards

MRE Mine Risk Education

PIG Probability Impact Grid

PHSSER Project Health, Safety, Security and Environmental Review

QA/QC Quality Assurance/Quality Control

SPA Single Point of Accountability

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UXO Unexploded Ordnance

RMS Risk Mitigation Strategy

5. Application

5.1. General

a. This GP shall be applied to projects in which BP has a majority interest or has the project lead. This GP, or a demonstrably equivalent procedure, shall be applied to other projects in which BP has an interest.

b. A project is defined as any development comprising:

1. A new process plant, manufacturing installation, pipeline, and associated facilities.

2. A new Research and Development installation.

3. A major modification that cannot be satisfactorily reviewed using the site review procedures for plant modifications.

4. Decommissioning, restart after mothball, or turnaround of a process plant.

c. Each BU should appoint a person that has SPA for application of this GP. BUL should identify a leadership position as the SPA for the application of the UXO GP and local UXO related regulatory requirements. (For guidance, as HSSE leads on this subject, the role should be fulfilled by the BU or Project HSSE Manager after receiving relevant training).

d. Each BU, with the guidance of the SPA, should define its strategy for application of this GP. A part of that strategy should include a definition of the projects that fall outside of the realm of this GP that should be reviewed in accordance with an equivalent Site Technical Practice.

This recognizes that project management framework for smaller projects can differ between sites and provides an option for sites to develop a Site Technical Practice that consolidates or simplifies some of these guidelines.

e. Projects should apply the principles in this GP to ensure full understanding of UXO hazard potential so that the risks are effectively managed to deliver acceptable performance. Projects can decide on how best to apply the UXO RMS process to account for unique circumstances of the project. If the UXO RMS process is not to be fully applied, the project shall develop and clearly document, in a variance request, its rationale and describe how it will assure that the associated UXO risks are effectively managed.

5.2. Principles

The principles on which this GP is based can be found at Annex A. These principles should be used as a guide when interpreting the action required under this GP.

5.3. Schematic

5.3.1. General

A schematic of the UXO RMS can be found at Annex B. It divides the process into four phases. These phases are summarized as follows:

5.3.2. Phase one – planning

During the planning phase, the project needs to determine whether they have enough information to establish whether UXO poses a risk to the project. The project needs to establish with the local authorities where the various responsibilities and authorities for conducting EOD

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operations lie, and what permits are needed. The project needs to establish the modalities for quality management of EOD support services. This includes how accreditation (pre-qualification), QA monitoring, and QC inspection of all EOD contractors will be conducted. If a UXO risk has been established, the project needs to allocate resources to manage the issue. Finally, the project needs to commission an Initial Assessment to define the threat in more detail. The Initial Assessment needs to be developed as the Project’s options evolve. The work should determine whether the UXO threat can only be resolved by EOD operations being conducted.

Note “Accreditation” is an IMAS term. The first part of “accreditation”, called “organisational accreditation,” covers for what within BP is referred to as contractor “pre-qualification”. The second part is “operational accreditation” which ensures that EOD capability is ready to operate and is conducted on site.

5.3.3. Phase two – preparation

Phase two is about preparing the Project to conduct EOD Clearance operations. In order to do this, the project needs to contract EOD specialists to conduct Technical Investigation to determine the specific site and levels of UXO contamination. The aim of this work is to define more clearly the Clearance requirements. Having defined that there is an EOD risk, the Project needs to establish a package of education to alert every person on site as to the risk, and the correct course of action to be taken to mitigate those risks. During Preparation, the Project needs to establish the detailed EOD work required and determine through a pre-qualification process whether the contractor will be able to deliver what is required.

5.3.4. Phase three – clearance

Phase three is the conduct of the Clearance operation. This starts with ensuring that the EOD teams deployed to the site task can perform to the standards required within the contract. Phase three also covers the Quality Assurance process to ensure that the EOD work is being done to the standards required and that the destruction of any UXO found is being performed in the prescribed manner.

5.3.5. Phase four – post clearance evaluation

The Post Clearance Evaluation starts with the Quality Control process established (using the agreed sample size) to ensure that results required by the contract have been achieved. Once the quality levels have been met, then the project needs to receive the post-clearance land release certification specified in the contract. The Project also needs to conduct a Post Project review to collect lessons learned for the benefit of the wider BP. Any Lessons Learned need to be passed to the Functional SPA and any documentation needs to be archived. (As a general rule, the documentation should be handed over to the staff operating the facility).

5.4. Alignment of UXO RMS to capital value process

Annex C shows the alignment of the development of the UXO RMS to the CVP. This is based on any clearance operation being required just prior to construction during “Execute”. If seismic, drilling or any other explorations takes place early in a project and are thought to be at risk from UXO, then a limited EOD support operation may have to be mounted earlier than shown. In such cases, the same process will have to be adopted.

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6. Strategic options

6.1. General

In developing their UXO RMS, Business Unit or Project should consider their strategic options within a Risk Management Framework. In many cases, the strategic options would only be open to the Business Unit or Project if the issue was identified early enough in the project. This is consistent with the practice of FEL. It should be noted that a project team needs to take a holistic view of their project; they might still adopt different options for different sites within their project. The UXO RMS Strategic Options open are:

6.2. Do nothing

Often, there is no evidence to suggest that UXO is likely to become a relevant safety or schedule issue for the project. If the Project Manager has confidence that this is the case, then no further action needs to be taken. Before taking this option, a Project Manager needs to consider what action he would need to take should UXO be subsequently found during the construction or operation of the facility. For guidance on these actions see GP 04-81, clause 9.3.

6.3. UXO risk education

A desk study may indicate that while the particular project site might not be at risk from UXO, there may be a risk to project personnel from UXO contamination in the vicinity of the site. In these cases, the Project Manager may wish to ensure that personnel receive education on the risks they face and on the appropriate measures to be taken by the individual and the Project level. (It should be noted that IMAS refers to this activity as “Mine Risk Education”). This shall include the warning of other contractors as the potential risk on site the UXO may pose. Guidance on this subject can be found on the UXO RMS website.

6.4. Avoid contaminated sites

In circumstances that allow it, the Business Unit or Project may wish to consider the option of avoiding any area of significant UXO contamination by re-routing or re-siting the affected facility, if that option is feasible.

6.5. Re-engineer the solution

If re-routing or re-siting is not a viable option, the Business Unit or Project may consider alternative local engineering solutions such as redesigning the affected part of a facility to avoid UXO.

6.6. UXO clearance operations

6.6.1. UXO clearance options

a. The Project Manager should usually only consider UXO clearance operations as a final option. Under these circumstances, if the problem has been clearly identified, specialist EOD contractors should be contracted to conduct a clearance operation prior to other work starting on the site.

b. In other circumstances, such as on a site in which there is judged to be a low probability of encountering UXO (ALARP has been achieved), the Project Manager may decide that in order to manage the Residual Risk, rather than doing nothing, it would be more appropriate to have specialist EOD contractors “on call” to deal with UXO if they are encountered during the planned project activity. Here, he may wish to have an EOD team on site or based off-site but be able to deploy to site within a prescribed timeframe.

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6.6.2. Storage of UXO & final disposal

Project Managers need to be aware that while the preferred option from clearance operations is to dispose of the UXO as they are found, this may not always be possible. It may be the case that under national rules only national bodies have the authority to conduct the final disposal. In these circumstances, consideration should be given as to how the UXO should be stockpiled safely before final disposal. Consideration should also be given to the method, location, and timing of the final disposal operation and how this may effect the main project.

6.6.3. War graves

Project Managers also need to be aware that during EOD operations, there is the possibility of finding human remains in circumstances in which they could be classified as “War Graves”. If War Graves are found, liaison is usually required with the host nation and the participants in the conflict to ensure that any remains are handled in an appropriate and sympathetic manner.

6.6.4. Environmental consideration

Finally, Project Managers need to be aware that UXO may be considered to present an environmental hazard. These hazards include noise or the destructive effect if detonated; the UXO is also likely to contain material that is considered to be toxic to the environment and certain disposal techniques may produce byproducts that are considered to be unacceptable. Project Managers should ensure that they are aware of the environmental impact of their chosen course of action and that the necessary permits have been granted before they proceed.

7. UXO risk assessment

7.1. Conduct of assessments

UXO risk assessments should be started at the earliest possible opportunity and are most appropriately lead by suitably qualified and experienced personnel. The Business Unit or Project should consider engaging an external organization to conduct their risk assessment. The same organization should be used to facilitate a UXO Risk Management Workshop in order help the Project Manager identify strategic options.

7.2. Land use

a. Under IMAS, the aim of any Clearance operation is to remove all UXO from the contaminated area. A Project Manager needs to decide the level of confidence that they require to determine that this has been achieved. This decision should be based on the proposed Land Use. In this context, the term Land Use also refers to seabed.

b. Depending on the sensitivity of the Land Use they may be allocated a category between 1 and 3 (referred to as LU1, LU2 and LU3). Within IMAS, the example given for LU1 is “tracks and footpaths, and areas around wells, housing and schools” whereas LU3 would be “land of little agricultural use and poorly frequented”.

c. The LU category dictates the size of QC sample to be used to provide assurance that the Clearance operation has been effective. Selection of category LU1 means that the QC sample would be approximately double the size that taken if the areas had been categorised LU3. It is important to note that the LU categorisation does not indicate a difference in level of clearance or any compromise in the safety during the EOD operations, but rather a difference in level of confidence that the work has achieved the required standard. If no UXO is found during the QC sampling process using LU1, there is normally a 95% confidence that the specified quality of clearance has been achieved. If LU3 had been chosen, the corresponding confidence level would be 75%. (These percentages refer to the objective mathematical probability of achieving the required level of confidence).

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d. The higher the LU category chosen, the bigger the QC sample to be taken. The larger the sample taken, the greater the level of confidence the client has that all UXO has been successfully removed from a defined area. The disadvantage is that a bigger sample is more expensive and that the process takes longer to complete. However, the extra expense is marginal as:

1. Much of the cost associated with QC sampling is due to the mobilisation of personnel and equipment to site. [A doubling of sample size would not double the cost of QC sampling – as a rule of thumb it is likely to add between 10% and 20% to the cost of sampling].

2. Should UXO still be found during construction, the cost of Schedule delays would dwarf the costs of the extra QC effort.

e. Projects should therefore sub-categorise their site by the sensitivity of its use; the more valuable the asset, the more hazardous the substances on that site or the larger the number of people at risk, then the more sensitive is the Land Use. If there is a national mine action authority, the project must determine whether a national policy has been established and whether it applies to the project’s activities. If no level is specified, the highest confidence level, LU1, should be the default setting. It would not be considered unreasonable therefore if a project were to allocate a category of LU1 to all of its construction areas and not attempt to differentiate between lands of differing sensitivity.

7.3. General assessment

a. The General UXO Assessment is the rolling process by which a comprehensive UXO Risk dossier is developed. It contains all reports of suspected UXO contamination and articulates the potential quantities and types of explosive hazards that may be present. This is created in order to assess the scale and impact of the UXO problem likely to be faced by the Project.

b. A rolling General Assessment should initially be developed and used by Business Unit Leader and then passed on to the Project Manager and finally on to the Operating Manager.

c. The General Assessment includes an Early Assessment, Initial Assessments, Technical Investigations, and UXO Risk Workshops.

1. An Early Assessment is a superficial desk study, prepared to support the ALERT workshop. The aim of the Early Assessment to determine whether there is sufficient evidence of military-related activity in the area of concern to justify the production of an Initial Assessment.

2. The Initial Assessment may be a single or series of Desk Studies. These studies gather historical evidence of activities that may have resulted in UXO contamination. The widest range of data should be sourced, gathered, collated, evaluated, and analysed to determine the level and types of military related activities that have taken place on the project site and in the surrounding areas. Ideally, this should start as early as possible. This may be prior to “Appraise” (during “Access”) by the development cells within a Business Unit and be updated and continually enhanced as necessary by the Project Manager, up to “Sanction” and beyond.

3. Should the Business Unit or Project determine from the Initial Assessment that a more detailed understanding of the local situation is required, he could initiate a Technical Investigation. This would involve a detailed physical investigation of the site using visual and technical (equipment) search techniques of a percentage of the site in order to provide more accurate data on what UXO may be present. While this may happen before sanction, it is more likely to be geared around or occur before “enabling” work conducted on the site.

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4. During all Stages of the CVP, there is a need to review the UXO General Assessment to determine whether any new information has come to light which affects the Business Unit or Project’s assessment of the UXO risk to his project. “Risk Workshops” should be used to determine the probability of UXO contamination and consequence that may have on the project.

7.4. Environment assessment

The first indications of possible UXO contamination should be picked up during the ESIA process. This would usually be conducted during Access Phase. If UXO contamination is suspected, it would be recorded as an identified project risk and the ESIA would recommend that further, more detailed assessments be done. The ESIA would be developed throughout the life of the project under the auspice of the Environmental Stewardship Operating Practice, the progress of which would be reviewed during the PHSSER.

Note The GP for Environmental Stewardship Operating Practice is to be rolled out in late 2005.

7.5. ALERT

ALERT is the process by which a project’s business risks are captured in terms of their potential financial impact on the project. The ALERT workshop is currently scheduled to take place ¼ to 1/3 of the way through the Appraise phase (it should be noted that this may be changed to 1/3 of the way through the Select phase). It is the responsibility of the Business Unit Leader to initiate the ALERT process. Any potential risk to the project from UXO should be captured within category “C06 Safety & Security of Personnel incl. UXO”. This risk category covers “The plans in place, together with the degree of associated costs, for the safety & security of our staff working in countries where there is a perceived threat to their well being. This should include separate consideration where the perceived threat is different at “working sites” to cities (e.g., Columbia). Specific consideration should be given to the threat posed by UXO. The aim, at this stage, is to identify whether there is sufficient evidence of military related activity within the geographical area of concern to warrant the production of an Initial Assessment. In order to make this judgement, an Early Assessment needs to have been conducted. The Early Assessment should also consult any group that may have already been on the ground in the areas of concern; these might include Survey, Drilling, or Environmental teams. The Business Unit HSSE manager’s advice should be sought on both the production of any Early Assessment and the appropriate input to ALERT.

7.6. Initial assessment

Projects need to be aware that, as a general rule, most academic or national archives have 30 working days turnaround time for information requests and that academic archives also close during holiday periods. Project therefore needs to plan these factors into any tasking to produce an IA and recognise that any report that is required in less than 60 days may be based on partial research data.

7.6.1. Evidence of military-related activity

Desk studies should seek to determine whether evidence can be found of Military-related Activities that could have caused UXO contamination of the area of interest. The primary concern of any study is to determine the quantity and types of UXO that may be found within defined geographical boundaries. If relevant, the failure rate of each type of UXO needs to be determined under the conditions pertaining to the location in question. Military-related Activities could include:

a. Warlike (warfare or insurgency) operations.

b. Military training areas.

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c. Depots or stockpile of munitions.

d. Munitions manufacturing sites.

e. Munitions dumping or other disposal areas.

7.6.2. Sources of evidence

a. The Initial Assessment information needs to be collected from any appropriate and accessible source. Sources may range from the following:

1. National achieves of the combatant or host nations.

2. Academic institutions.

3. Open source literature (libraries, newspapers and magazines, or the internet).

4. Local contacts and non-governmental organisations.

b. Within the host nation, the information normally resides with the Ministry of the Interior or Armed Forces. It should be noted that these organizations may:

1. Be reluctant to provide information.

2. Be unaware of the full extent of the UXO contamination.

3. View UXO as a legacy of conflict that should not be advertised in order to avoid deterring potential investors in the region.

4. Have a limited indigenous capability to deal with UXO.

c. During the time when the information gathered is collated and assessed, the data needs to be graded according to its perceived reliability. This grading should take into account the credibility of the source and the perceived accuracy and completeness of the data. This grading should enable the recipients of the Initial Assessment to determine the weight that should be given to the presented data within the decision making process.

d. The information gathered should help the analyst to determine the:

1. Types of UXO that may be found.

2. Area(s) in which UXO may be found including the depth.

3. Quantities used or stored within the prescribed area.

4. Failure rate of UXO within the theatre of operations where it is relevant to a munitions type in order to determine the likely numbers of UXO contamination present by type.

7.6.3. Reports

a. Business Units or Projects need to be able to assess the validity of any report on the UXO contamination issue for their site. They should consider whether:

1. The information refers specifically to the Project site or just to the general region.

2. The assessment has covered the full history of the area or has concentrated only on the main or most obvious events.

3. The full range of military activity that has taken place in the area has been revealed or just the most obvious.

4. The assessment has included a good sample of sources and whether the sources have been assessed for their credibility.

5. The report has clearly separated researched facts from assessment and assumption.

6. Facts have been properly referenced to enable them to be more readily verified.

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b. The Initial Assessment should indicate whether UXO is likely to be an issue for the project sites. This should not determine whether the area has had a problem, but whether, in the future, each project site is likely to be affected by any UXO contamination. This assessment should assign to future project work areas UXO risk categories depending on the level of perceived risk. This might be indicated by using a scale of 1 to 10, or it could be articulated as “will, may, might, unlikely, or will not” be affected. For ease of communication, these categories could be colour-coded. The project manager needs to agree the categories most appropriate to the project. An example of a coloured categorisation is as follows:

1. GREEN – evidence suggests that UXO hazards are unlikely to be encountered on this part of the project.

2. YELLOW – while evidence exists of a general UXO contamination problem in the geographical area of the project this should not present a risk to a specific project activity. The risk assessment needs to be kept under review.

3. AMBER – evidence exists of a general UXO contamination problem in the geographical area of the project that could present a threat to specific project activity. Options to mitigate the UXO risk need to be considered.

4. RED – evidence exists of UXO contamination in a specific project area that presents a risk to project activity. Action needs to be taken to mitigate the UXO risk.

7.6.4. UXO risk evaluation format

The format for an UXO Risk Evaluation can be found at on the UXO RMS Website.

7.7. Technical investigation

7.7.1. General

IMAS refers to this subject as Technical Survey. However, as the term “survey” is understood within the Oil & Gas industry to have a specific meaning, this GP uses the term Technical Investigation.

7.7.2. Purpose of technical investigation

The purpose of the Technical Investigation is to determine, through on-site investigation, the numbers, sizes, types, and possible location of potential UXO contamination on the project site through the collection of objective (scientifically repeatable) data. The data is collected using both visual and technical (equipment-based) search techniques.

7.7.3. Conduct of technical investigations

a. If the Initial Assessment indicates the probability of UXO contamination occurring on the project site, the Project Manager should use Technical Investigation to confirm the level of contamination within specific bounded areas. For ease of management, large project sites could be divided into “task sites”. In turn, large task sites may be sub-divided into more manageable ‘lots’ of land or seabed.

b. Technical Investigation should be conducted by trained and equipped teams whose working practices are tested, monitored, and inspected for quality, in order to provide objective information on the risk from UXO on a particular Task Site.

c. Technical Investigation involves conducting 100% visual search of the prescribed area for UXO and UXO indicators. Offshore, the equivalent of the visual search is usually conducted with high frequency side scan sonar. Indicators include, but are not limited to, shell casings, shrapnel, craters, mine sinkers, and other bits of military detritus. Typically, in a location where UXO is expected, there are more indicators than visible or easily located items of UXO.

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d. The visual search is followed by Representative Sampling. Representative Sampling uses specialist instrument search down to a depth appropriate to the planned construction activity plus a safety margin. IMAS gives that safety margin as 0,5 m (2 ft). For instance, if footings are being constructed 4,0 m (13 ft) below existing ground level, the technical investigation would be conducted to a depth of 4,5 m (15 ft) in the location of the footings; whereas, if an area was to be used for a laydown with only surface levelling, the technical investigation may be conducted down to 0,5 m (2 ft). Projects should determine their own safety margin depending on:

1. The accuracy to which construction activity will be performed.

2. The types of activity and its ability to generate influences that might disturb any UXO in the vicinity.

3. The types of UXO that may be present.

e. The level of Representative Sampling is typically conducted at 12, 8 or 4% of the area being investigated depending on the UXO risk level that has been determined by the Initial Assessment and agreed with the Project Manager. It is the process by which the identification of items of UXO, or indicators, triggers full clearance of specific areas. It provides an overall level of confidence in excess of 99,5% that a correct determination will be made as to which specific areas are contaminated with UXO and which, therefore, need to be cleared.

f. Locations where visual and sonar search or any other instruments indicate the possible presence of UXO should be physically excavated as required in order to confirm that it is an item of UXO; this method enables a precise record of the site, including the footprint of the contamination, to be established.

g. Representative Sampling should provide the Project Manager with information on which areas of the Project are contaminated with UXO. In certain circumstances, the Project Manager may decide that, before he authorises a UXO Clearance Operation, he wants to have a better understanding of what needs to be cleared from the site. In certain cases, he may ask for a 100% coverage using detection instruments to be conducted in which each item of UXO is located and marked but not otherwise disturbed. This would enable the Project Manager to have a clearer idea of what the full Clearance operation would cost. A 100% instrument search is only likely to be appropriate if a limited number of large items of UXO are likely to be found at depth.

h. If UXO, or UXO contamination indicators, are identified on the site, full Clearance should be conducted if they cannot be avoided or a solution re-engineered. Irrespective of the requirement for Clearance, the objective information gained during Technical Investigation provides an increased understanding of the overall UXO situation and should be continuously used to develop the General Assessment.

7.7.4. Technical investigation – offshore considerations

Offshore Technical Investigation is predominately conducted using a combination of high frequency side scan sonar (> 500 kHz), visual search (if high frequency side scan sonar can not be used) and magnetometer in order to identify items that could potentially be UXO. This could be conducted by a competent non-EOD contractor monitored by appropriate Geophysical and EOD BP Representatives who will lead on the data analysis. If the area of potential UXO contamination identified cannot be avoided, there is a requirement to investigate each potential item of UXO detected by the sensors in order to confirm or discredit it as UXO. ROV or EOD divers monitored by a BP EOD Representative complete this identification process.

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7.8. UXO risk workshops

7.8.1. General

a. UXO Risk Workshops may be held at a number of points during the CVP process once a risk has been identified. Workshops may be considered as follows:

1. Prior to the deployment, any personnel on to the ground during Access, Appraise, and Select. The aim of the workshop would be to ensure those deploying were aware of the risk and that appropriate mitigation plans were in place.

2. Following the Early Assessment, conducted for ALERT, a workshop may be needed to consider the scope of the Initial Assessment required and the modalities that need to be adopted (Phase One).

3. Once the project has developed its options during Select, Workshop should be conducted to determine whether any TI is required prior to the Project going firm on its favoured option. The outcome would be to inform the Select process on any relocation or reengineering options open to the project (Phase Two).

4. Should earlier work determine that Clearance (Phase Three) is required during preparatory work or during the main Execute phase, a workshop should be used to confirm that the Project UXO risks have been fully identified and that the mitigation planned is appropriate.

5. If EOD work has been conducted on site, a workshop shall be conducted, before the Construction PHSSER. This workshop (Phase Four) is to determine whether the quality of the EOD work is to a standard that the level of risk on site can be considered to be ALARP.

b. The aim of the Workshops should be to help the Business Unit or Project to come to a conclusion as to how the perceived UXO risk is likely to affect their project. These Workshops should review the action taken so far and the up to date risk assessment data in order to determine the appropriate next step.

c. The Workshop should be a facilitated session with representatives of all disciplines concerned within the Project groups in attendance. The project team should define the types of construction activity planned and their location and then consider which potential types of UXO may be encountered by each activity.

7.8.2. Participation

Participation of the workshop should promote a single perspective within the project of the UXO risk and the mitigation required. The workshop should be facilitated by an EOD consultant and stakeholders should be invited to attend. Participation may therefore vary through the life of a project. The following functions with the Project should be represented:

1. Representative from each site within the project.

2. Representatives of each discipline.

3. HSSE.

4. Survey/Exploration.

5. Drilling.

7.8.3. Risk identification

a. In line with IMAS, UXO only constitutes a risk if it poses an unacceptable hazard to a particular project activity; for instance, a small item of UXO may be a hazard to men working unprotected, whereas the same type of UXO would not be considered to be a hazard to offshore dredging or piling operations.

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b. A subject matter expert should explain the nature of UXO considered potentially present on the Project footprint and the possible effect of UXO on those activities. This data should then be used to populate a matrix to show what type of UXO should be considered a hazard to each type of project activities and therefore where UXO presents a risk to the project. An example of the matrix can be found at Annex D.

c. The project shall identify any evidence that would help them to determine whether any action has already taken place that might mitigate any potential UXO risk.

7.8.4. Quantitative Analysis

a. The risks identified shall be modelled for their probability and judged against the risk acceptability criteria set down at GP 48-50.

b. Where assumptions are made about any factor in the model, a sensitivity analysis shall be conducted. The sensitivity analysis should identify a range of possible values for each factor and the model should be rerun using those values. Should any value change the potential recommendation, the project should consider conducting further research in order to determine the value to be used.

7.8.5. Risk assessment and response

a. The output from the Risk Identification should be compared with the likely pathways that could link a hazard with an activity and therefore present a risk. This is used to assess what would be the most significant or likely UXO hazard to affect each construction activity. The resultant risks should then be assessed in terms of their effects on the Project Business Risk and their potential Harm to People. An example of a PIG (also referred to as a Risk Matrix) can be found at Annex E.

b. The risk shall be monetized.

c. For the activities found to be at risk by Risk Estimation, a range of operational risk mitigation options shall be considered across the construction footprint. These options should be part of a graduated response that escalates in cost and time.

d. Recommended risk mitigation actions for each at risk activity should be summarised on a chart; an example can be found at Annex F.

7.8.6. Risk of explosive event

7.8.6.1. General

In general, items of UXO may explode for two main reasons:

a. They may function as designed, or

b. They may malfunction.

7.8.6.2. Risk from UXO “functioning as designed”

For the UXO to function as designed, the firing train (electrical or mechanical) needs to be in place, the power supply required still needs to be viable, and any self-sterilising feature needs to have malfunctioned. Some UXO are designed with anti-handling devices and other booby-traps that are designed to injure those interfering with the device.

7.8.6.3. Risk from UXO malfunctioning

The EOD industry perception is that there is a substantial risk of a UXO exploding if it is disturbed; this is supported by empirical data. There are many reasons for this, but they are generally due to some form of malfunction within the UXO. Reasons might include:

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1. Explosives break down, especially those used in detonators and boosters. They can become more sensitive with time so that even a minor shock might cause them to explode.

2. A mechanical hang-up (in which something within the initiation mechanics has stopped part way through the initiation process) is released by some external stimulus.

3. Internal component corrosion that generates conditions within the UXO that may make it very sensitive to external stimulus.

7.8.7. Safety distances

If an item of UXO has exploded, it is often not possible to determine whether it has functioned as designed or whether it has malfunctioned. Therefore, when planning EOD operations, safety distances are based on the weapon’s effect rather than probability of an explosion. Best practice dictates that it would be negligent to assume that an item of UXO would not detonate if it is disturbed in any way. Safe practice is considered to be keeping people or vulnerable material outside the explosive effects range of any known or suspected UXO until the appropriate risk mitigation strategy has been implemented and the risk is deemed to be ALARP.

7.8.8. Operational options

The following range of operational options should be considered by the project team:

a. Initiating or enhancing further UXO Risk Awareness Education.

b. Conducting further Technical Investigation to define the UXO problem more specifically. This may be up to and including the location and identification of specific items to determine whether they represent a UXO hazard. (This later phase may not be required if the General Assessment has provided sufficient evidence that a Clearance operation is required).

c. Mark and avoid known sites of UXO contamination; informing and educating personnel.

d. Avoid sites of UXO contamination by re-siting BP activity, if possible.

e. Build protective works in order to reduce the potential hazard from UXO.

f. Make arrangements for EOD Teams to be on-call in order to provide close support to construction activity and react quickly to UXO incidents.

g. Deployment of EOD Close support teams to provide immediate EOD response to a perceived potential threat or the discovery of UXO.

h. Conduct EOD clearance to remove a UXO hazard from the area of concern to a location where the project and its personnel are no longer considered to be at risk.

i. Conduct Disposal operations to reduce a UXO to a condition in which it, or its component parts, no longer present a hazard of any type. (This should by preference be run simultaneously with the Clearance operation).

8. UXO RMS development

8.1. General

a. For the purpose of this GP, the UXO RMS model is geared around UXO clearance operations taking place just before the start of construction work. Business Units or Projects need to note that this may not always be the case. Localised UXO clearance may be required at any stage of a new venture or project starting with Exploration and Drilling operations.

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b. The potential impact of UXO may vary greatly from project to project. The strategy adopted for a particular project should acknowledge the specific issues that are faced by the project team. In these cases, the responsible person needs to adapt the UXO RMS model accordingly. While this GP links a particular UXO RMS activity to a stage of the CVP, this is not to suggest that the activity cannot be done at a different stage for a specific project, provided that the full scope of UXO RMS is addressed and the project has the approval of the appropriate engineering authority and positive agreement by the Business Unit, Project Manager, and CVP Gatekeeper.

c. If UXO is determined to be an issue for the Project, the developing UXO RMS should be formally reviewed to ensure it is in line with the central needs of the Project. As a Health and Safety issue, the timings of these reviews should be related to the HSSE planning process within the CVP (see GP 48-1). It would, therefore, be expected that, if appropriate, the UXO RMS would be reviewed as part of the PHSSER. In outline, the UXO RMS should be developed as follows:

1. During the Access Phase, the objective of the UXO RMS would be to ensure that individuals conducting exploration or drilling operations are not injured by UXO. This would be the responsibility of the local Business Unit.

2. During CVP stage Appraise, an Initial Assessment should be conducted to determine whether the quantity and type of UXO present are significant enough to affect the shape of the business strategy.

3. During Select and Define, the general assessment should be developed to enable the Project Manager to determine the most appropriate strategic options available. If the project covers a wide span of terrain, different options may be appropriate on the different task sites.

4. The period around Sanction and in the early stages of Execute is likely to be the most intense period for the UXO RMS. The key here is to ensure that the EOD programme has a minimal impact on the construction programme.

5. If UXO has been an issue, it can never be assumed that the site is 100% clear. Post Clearance, the Project Manager and, subsequently, the Operations Manager, need to ensure that they consider the potential disruption that UXO might cause follow on operations up to and including the de-commissioning of the site. This is referred to as “Managing Residual Risk”.

d. If an EOD contractor is required to support the Project in any capacity, this should be considered to be an EOD Programme.

e. The principle behind the UXO RMS is that at each stage of the CVP, the risks to personnel, the Project, and BP’s reputation posed by UXO are considered to enable timely action to be taken. This is to ensure that the UXO risk should cause the minimal adverse impact on the overall project.

8.2. “Access” phase

8.2.1. Objective

To ensure that no BP personnel or contractors are put at unnecessary risk by entering areas of UXO contamination without being aware of the risks and having the appropriate mitigation in place.

8.2.2. Actions

a. During the Access Phase, the major UXO RMS consideration should be the safety of personnel on the ground. An initial assessment should be conducted and, in extreme cases, EOD support may be needed. This responsibility of managing this risk, therefore, falls to the relevant Business Unit.

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b. The Business Unit should collate any UXO risk assessments done by or on behalf of their survey, drilling, or environmental teams, or any other activity that has taken place on the proposed project site.

8.2.3. Formal review

There is no formal review process done at this stage of the project.

8.3. CVP appraise stage

8.3.1. Objective

a. To confirm that any UXO risk that could affect the viability of the potential project has been identified and that the information required to assess risks, liabilities, regulatory compliance, and adverse impacts have been correctly specified.

b. To confirm that an adequate risk management plan is in place for development in sensitive areas.

8.3.2. Actions

During the Appraise Stage, the UXO RMS should be focused on determining whether the level and type of potential UXO contamination is such that it could threaten the strategic business option under consideration. The following should be considered:

a. Determine whether any UXO related activity took place during the Access Phase. If so, review that activity for lessons learnt.

b. Conduct an Early Assessment for the Project to support the ALERT workshop, building on any work done during the Access Phase.

c. Conduct a UXO RMS Workshop to assess the likely impact of UXO on the project. If no evidence of UXO has been found, this may be done in-house; if evidence of UXO is found, the Business Unit Leader should consider using a Subject Matter Expert to facilitate the workshop.

8.3.3. Review

The UXO RMS should be reviewed as part of the Appraise PHSSER.

8.4. CVP select & define stages

8.4.1. Objective

a. To confirm with the Host Nation where responsibilities and authority lie for EOD operations. This should include any permits needed and whether the Nation Authority has an EOD contractor Accreditation scheme. The detail may need to determine that appropriate arrangements are in place for the temporary storage and final disposal of UXO that has been cleared from the project site.

b. To confirm the modality and standards for safety and quality management that is expected of EOD contractors supporting the project.

c. To confirm that any UXO risks relating to the characteristics of the full lifecycle of the project and the nature of the location have been identified.

d. To confirm that an adequate UXO RMS (including the objective evaluation of the site through Technical Investigation) has been established.

e. To verify that UXO studies, including specialist reviews have been satisfactorily addressed and followed up.

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f. To verify that resources and training for UXO RMS management have been established for identified individuals.

g. To confirm UXO RMS (including any UXO Clearance operation necessary prior to the start of construction) is in place prior to the commencement of construction.

h. To confirm that the on-site workforce receives appropriate MRE training.

8.4.2. Actions

a. During the Select and Defines stages, the UXO RMS should be focused on refining the UXO General Assessment. This may consist of producing more detailed work to elaborate on the Initial Assessment and Technical Investigation. The aim of the Technical Investigation would be to determine the boundaries of the UXO contamination and then to conduct more detailed ground work to determine the type and level of contamination and, in the case of large munitions, their possible location. The aim of this work would be to enable the project team to develop a clear understanding of the EOD support that they require.

b. In putting together their RMS, the Project Team needs to consider the following issues:

1. To enable the project manager to exploit all the options open to him, a key component of any UXO RMS is the Contracting Strategy. As the EOD contractor base is small and the industry is immature, the Contracting Strategy needs to be developed ahead of the perceived need for contractor support to ensure that contractors of the right quality are available if required.

2. Development of Media strategy and plan.

3. Consider insurance issues.

4. Environmental Impact planning (EIA, ESIA).

5. Guidelines on the selection of Contractors and contracts.

6. Projects often begin their enabling activities before Sanction. This activity may require EOD support operations up to and including Clearance. If Clearance is not required for enabling work, its timing may span Sanction depending on whether the clearance is required to be completed prior to any construction work or whether the Project Manager is content for it to be completed just before the scheduled start of construction. The first option may have “up-front” cost implications; whereas, the later may risk schedule delay should the clearance fall behind schedule.

7. If the project may be delayed by the discovery of UXO, where the responsibility for the resulting costs lie.

8. If UXO is deemed to be a potential risk, ensure all concerned are made aware of the risk to themselves and understand the appropriate measure to mitigate the risk.

9. In the planning of EOD Clearance operations, the project team needs to consider local laws and the national authorities who may prescribe who is to conduct this task. In these circumstances, the project team should focus on the quality systems that ensure the EOD work is completed to the prescribed standard.

10. If an EOD Clearance operation is required, this should include both the clearance and disposal of all items of UXO. The areas undergoing clearance and depth need to be defined to meet the Project engineering requirement.

11. Ensure that best practice is adopted for work done within the UXO programme. Guidelines for running a UXO programme can be found in GP 04-81. International Standards require that the quality of EOD work is validated (QA & QC) both internally within the EOD contractor and by an external independent third party

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representing BP. It is through this mechanism that the Project Team gains assurance that the work is done to the required standard and that the land is fit for purpose.

12. Should Disposal not run concurrent with the location and removal of UXO, the Project Manager needs to consider the temporary safe storage of UXO items. The policy for the Safe Storage of UXO needs to articulate the rules for storage. The Project Manager needs to make clear which standards (national or international best practice) are to be used and in what specific circumstances it is an acceptable risk to store fused UXO. The project team needs to review constantly the safety and security of these storage sites. This should consider the responsibilities, probability, and consequence of there being an accident involving the storage site.

13. Wherever there is UXO, there is also the possibility of finding unmarked War Graves. Issues arise involving the competing nationalities and cultural practices for dealing with War Graves. Planning needs to take into account the sensitivities and national considerations of all parties when dealing with these matters.

14. How Lessons Learnt during the process are captured and used to continually improve the UXO RMS.

15. HSSE recording and reporting mechanisms.

8.4.3. Formal reviews

The UXO RMS should be reviewed as part of both the Select and Pre-Sanction PHSSERs. The Project Manager should consider the following requirements when reviewing the outcome of the PHSSERs.

a. Should Technical Investigations of the site be required, then an EOD programme has to be initiated between the Select and Pre-Sanction PHSSER.

b. In extreme circumstances, clearance operations may also be required before the Pre-Sanction PHSSER is conducted.

8.5. CVP execute

8.5.1. Objective

a. To confirm that UXO General Assessment is up to date and the lessons leant in the previous stage have been fully incorporated.

b. To confirm that the on-site workforce is receiving appropriate MRE training.

c. To confirm that the UXO RMS is being implemented effectively.

d. To confirm that the residual risk from UXO to the project (including stored UXO) and individuals is understood, and is managed appropriately, including promulgation of instructions on the action to be taken should UXO be discovered unexpectedly are in place and understood.

e. To confirm EOD support is available in a timely and cost effective manner when required.

f. To ensure that non-EOD contractors are given advice on mitigating any possible UXO risk to their personnel and activities.

8.5.2. Actions

a. During the Execute stage, the UXO RMS focus should be on:

1. Personnel Safety.

2. The execution of continuing Clearance operations.

3. The reaction to the discovery of, or incidents involving, UXO.

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4. The timely and cost effective availability of EOD contractor support.

5. The safe and secure storage and disposal of UXO found during Clearance operations.

b. The guidance that may be made available to non-EOD contractors involved in the project concerning risk mitigation measures taken by BP and their own recommended actions and responsibilities can be found in GP 04-81. This includes guidance on the action to be taken in the event of encountering UXO anywhere in the project site or locality.

8.5.3. Formal review

a. During the Execute stage, the Project Manager has three formal opportunities to review the development of his UXO RMS. These are the “Detailed Engineering”, “Construction” and “Pre-startup” PHSSERs. At the “Detailed Engineering” PHSSER, the key issue is likely to be whether EOD clearance operations have been concluded safely. From then on the issue should be to ensure that the residual UXO risk problem is managed safely and effectively.

b. The number and timing of PHSSERs during the Execute Stage is determined by construction issues and the introduction of hazardous materials to the site. If appropriate, the UXO RMS should be considered during these reviews.

8.6. CVP operate

8.6.1. Objective

Besides managing the residual risk, the operations manager should be aware of how the potential UXO risk may change during the life of the project due to environmental changes and when modification or demolition of the facility is considered.

8.6.2. Actions

During the Operate Stage the UXO RMS main focus is likely to be managing the residual risk: see GP 04-81. This may include the security and disposal of stored UXO previously cleared from the site or offshore and maintenance activity to monitor their status and condition.

8.6.3. Formal review

The final PHSSER is conducted 12 months after Commissioning. This is to review the safe operation of the facility and lessons learnt. Managing the residual UXO risk may also need to be considered.

9. UXO RMS management

9.1. GP maintenance

The Functional SPA responsibility for developing and maintaining this GP is the Team Leader HSE, EPTG Sunbury. His responsibilities are to ensure:

a. The GP is reviewed (quarterly), is kept up-to-date and reflects commercial EOD Best Practice.

b. The website is reviewed (quarterly) and is kept up-to-date.

c. Those projects receive advice on commercial EOD Best Practice.

d. If project deviates from Best Practice, that the reasoning is sound.

e. The EOD contractor accreditation is conducted to a uniformly high standard throughout BP.

f. Subject Matter Experts are available to PHSSER team leaders as required.

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9.2. GP implementation

The Operational SPA for implementing this GP is with the Business Unit until a Project Manager/Director is nominated; the responsibility finally would be passed to the Operations Manager. The Business Unit is responsible for initiating the UXO RMS during Access or Appraise, whichever is deemed to be appropriate. The responsibility would normally be delegated to the HSSE manager who requires the following competencies:

a. Be able to perform a leadership role.

b. Have received a HSSE UXO Management Awareness Briefing.

c. Know the UXO network of contacts within BP.

10. Training

a. The training available to enable managers and HSSE staff to develop a viable UXO RMS can be found on the UXO RMS Website.

b. Lessons learnt should be entered into the Projects and Engineering Shared Learning System.

c. For instant notifications for new validated shared learnings individuals should fill an interest Profile in the Projects and Engineering Shared Learning System.

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Annex A (Informative)

UXO RMS Principles

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Annex B (Normative)

Schematic of the UXO RMS

Start Project General Assessment –Early Assessment (to support ALERT)

then Commission the In itial Assessment

Develop EOD Contracting Strategy

Estab lish modality for the Organisational Accred itation

and Operational Accreditation of EOD Contractors

Estab lish modality for the QA (monitoring) & QC (inspection) of

EOD Contractors

Prepare handover DocumentationConduct Post-Pro ject Review

Inspection of Cleared Land by sampling (Quality Control)

Detection , removal &destruction of all UXO hazards

Monitoring and Inspections (Quality Assurance)

Field inspections to confirm operational accred itation during mobilisation

Estab lish EOD funding

Specify the clearance requirements and responsibilities

Organizational Accreditation

Technical Inspection – Collect data to enable clearance requirement to be defined , including areas

to be cleared and the dep th of clearance

Prioritise areas to be assessed for UXO

Gather data for UXO RMSEstablish National Authority and Project

responsibilities fo r EOD includingStandards to be used – default IMAS

Start to Develop a UXO RMS Process

D o cu men tat io n sen t to ag reed d ep o sito ry

Lesso n s Learn t p assed to U XO R MS O w n er

Clearance

Preparation

Planning

Develop the General Assessment (Review & refine Initial Assessment as

scope of p ro ject develops)

On-site Technical Investigation to estab lish hard data on th reat level

–• Div ide area in to Lots and • Assess Risk at each Lot

• Agreed Sample Size for the p ro ject (at 4 ,8 or 12%)

UXO Risk Education for other workers

on the site

Contractual Agreement for Clearance

Contractual Agreement fo r Technical Investigation

22 M ar 05

Sample Size prescribed

Post-Clearance Evaluation

“ Safe and Effect ive /Efficient

operat ions through process quality”

Modified IMAS Schematic

Additional explanation of

actions

Legend

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Annex C (Normative)

Alignment of UXO RMS to CVP

InceptionSite

Restored

Ex p lo ratio n Tea m

Drill in g Team

Pro ject Ma na g er Opera tio ns Ma na g er

HSSE Plan s

O n -Site Su p erv iso rs

G en eral On -Sit e S taff

SELECTSelect the preferred project option

DEFINEFinalize project Scope, cos t and s chedule and get

the project funded

EXECUTEProduce an operating as s et cons is tent with

s cope, cos t and a schedule

OPERATEEvaluate as s et to ens ure performance to s pecifications and maximum return to the

s hareholders .

APPRAISEDetermine project feas ibility and alignment

with bus ines s s trategy[Agree fundamental viability and options ]

ACCES SDetermine the potential value & delivery

s chedule for new bus ines s opportunities after accounting for access cos t & as s ociated ris ks

A pp raisal Plan (ru n at Segmen t Lev el)

M ajor Project Leaderappointed

7 M ar 05

Busin ess D ev e lo pment M a na g er

Appra ise Se lect Pre-Sa nctio n D eta i led Eng ine ering P re-Sta rtup Opera tePHSSER s C o nstructio n

EOD Ope ra tio ns

Co n stru ctio n Co n tracto rs

Planning

Operations on Site

ALERT

Sanction

HSE M angerappointed

?

EO D Co n trac tin g Stra teg y

UXO Man ag in g R esid u al R isk

UX O Risk A sses smen t B ased o n Desk S tu d ies UXO Tech n ica l In v estig at io n

UX O Cle aran ce

"Min e R isk Ed u ca tio n ”

U XO D isp o sal/ D estru ct io n

Environment Social Impact As s es s ment

En ab lin g Wo rk s

UXO R MS

Agree the Project (with

res ervations )

Agree the B udget

(“confirm the pres umption”)

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Annex D (Informative)

Typical Risk Analysis – Hazard Identification

Minimum Calibre of UXO Constituting a Hazardous Item

Construction Activity Ammo up to

12,5 mm

Ammo 12,5 mm

to 30 mm

Ammo 30 mm

and above

100 lb Bomb

250 lb Bomb

500 lb Bomb

1 000 lb Bomb

Sea Mines

2 000 lb

Remarks

Land Survey No Yes Yes Yes Yes Yes Yes NA Land Earthworks - manual

No Yes Yes Yes Yes Yes Yes NA

Land Earthworks – mechanical

No No Yes Yes Yes Yes Yes NA

Land Piling No No Yes Yes Yes Yes Yes NA Land Clearing – (grubbing)

No No Yes Yes Yes Yes Yes NA

Land Tree Cutting No No No Yes Yes Yes Yes NA Bach LCT landing No No Yes Yes Yes Yes Yes Yes Beach Piling No No Yes Yes Yes Yes Yes Yes Beach Dredging No No No Yes Yes Yes Yes Yes Beach HDD No No Yes Yes Yes Yes Yes NA At start of

drilling only

Near/ Offshore Piling No No No Yes Yes Yes Yes Yes Near/ Offshore Anchoring

No No No Yes Yes Yes Yes Yes

Near/ Offshore/ Dredging

No No No Yes Yes Yes Yes Yes

Near/ Offshore Trenching

No No No Yes Yes Yes Yes Yes

Near/ Offshore Rock Dump

No No No Yes Yes Yes Yes Yes

Near/ Offshore Diving No Yes Yes Yes Yes Yes Yes Yes Near/ Offshore Pipe Laying

No No No Yes Yes Yes Yes Yes

Near/ Offshore Spudding

No No No Yes Yes Yes Yes Yes

Near/ Offshore Survey Refraction

No No No Yes Yes Yes Yes Yes

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Annex E (Informative)

Project UXO Hazard Analysis Risk Matrix

Very Low Low Medium High Very High

Project Business

Risk

Harm to people 1 2 3 4 5

Greater than $20m

More than 1 fatility A k q l n d

Greater than $10m 1 fatility B r h e c

Greater than $5m Serious Injury C a b o f i

Greater than $1m

Days off work / Greater than

$1mD g j m s

Less than $1m

First Aid / Less than

$1mE p

CONSEQUENCE

PROBABILITY

Construction Activity Location Hazard

a Land Survey LNG Onshore / Beach 30 mm S

b Land Earthworks - manual LNG Onshore / Beach 30 mm S

c Land Earthworks - mechanical LNG Onshore / Beach 1 000 lb Bomb S

d Land Piling LNG Onshore / Beach 1 000 lb Bomb S

e Land Clearing – (grubbing) LNG Onshore 500 lb Bomb S

f Land Tree Cutting LNG Onshore 30 mm S

g Beach LCT landing Beach 30 mm S

h Beach Piling Beach / LNG Nearshore 500 lb Bomb S

i Beach Dredging Beach / LNG Nearshore 30 mm S

j Beach HDD LNG Onshore 1 000 lb Bomb B

k Near/Offshore Piling LNG Nearshore / Offshore Sea Mine S/B

l Near/Offshore Anchoring LNG Nearshore / Offshore Sea Mine S/B

m Near/Offshore Dredging LNG Nearshore 30 mm S

n Near/Offshore Trenching Offshore Sea Mine S/B

o Near/Offshore Rock Dump Offshore Sea Mine B

p Near/Offshore Diving Offshore 30 mm S

q Near/Offshore Pipe Laying Offshore Sea Mine B

r Near/Offshore Spudding Offshore Sea Mine B

s Near/Offshore Survey Refraction Offshore Sea Mine B S – Risk determined by Safety B - Business

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Annex F (Informative)

Project UXO Risk Mitigation Recommendations

Risk Mitigation Options Construction Activity

Risk Category UXO Risk

Education/ Awareness

EOD Close Support One

EOD Technician with detector

Un-identified Object (UO)

Survey (offshore activity)

Technical Investigation (Sampling Survey to

confirm extent of UXO contamination)

Land Piling High Yes Yes NA Land Earthworks - mechanical

High Yes Yes NA

Near/Offshore Anchoring

High Yes NA Yes Only if coincides with UO and cannot be realigned

Near/Offshore Trenching

High Yes NA Yes Only if coincides with UO and cannot be realigned

Land Clearing - (grubbing)

High Yes Yes NA

Near/Offshore Piling

Medium Yes NA Some Done Only if coincides with UO and cannot be realigned

Beach Piling Medium Yes Yes Some Done Beach Dredging Medium Yes Yes Some Done Land Tree Cutting

Medium Yes Yes NA

Near/Offshore Pipe Laying

Medium Yes NA Yes Only if coincides with UO and cannot be realigned

Offshore Spudding

Medium Yes NA Yes Only if coincides with UO and cannot be realigned

Land Survey Low Yes Tolerable NA Land Earthworks – manual

Low Yes Tolerable NA

Near/Offshore Rock Dump

Low Yes NA Yes

Beach LCT landing

Low Yes Tolerable NA

Beach HDD Low Yes Tolerable NA Near Shore Dredging

Low Yes NA Done Only if coincides with UO and cannot be realigned

Near/Offshore Survey Refraction

Low Yes NA Yes

Offshore Diving Low Yes NA Yes

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Bibliography

[1] Getting HSSE Right, A Guide for BP Managers - http://hse.bpweb.bp.com/ghser/default.asp

[2] BP Capital Value Process - http://cvp.bpweb.bp.com/cvp/index.htm

[3] BP Environmental and Social Impact Management Process

[4] Getting HSSE Right for Projects - http://projects.bpweb.bp.com/hse/index.htm

[5] Engineering Technical Practices - http://technical_practices.bpweb.bp.com/

[6] Getting Security Right - http://gbcweb.bpweb.bp.com/BPSecurity/

[7] International Mine Action Standards (IMAS) - http://www.mineactionstandards.org/imas.htm