Industrial environmental control (IEC)

Industrial environmental control (IEC)

1. IEC organizational structure

1.1. OJSC “Surgutneftegas” is a vertically-integrated joint stock company,

which includes business units of main and auxiliary kinds of activity.

1.2. The head of the Company is Director General appointed by the

Board of Directors in compliance with the Charter of OJSC “Surgutneftegas”.

Business units, being parts of the Company, are headed by the first managers in

compliance with general powers of attorney and administrative duties.

1.3. Industrial environmental control is a part of general environmental

management, which is performed by the First Deputy Director General in

compliance with his administrative duties.

1.4. The two-level IEC is implemented in the Company, including control in

the sphere of waste management aimed at:

I level of control — control of adherence to the legislation requirements and

standards, local technological normative documents in the Company's business

units and contracting organizations.

II level of control — control of adherence to the requirements of

environmental legislation, license requirements and conditions by the Company's

business units and contracting organizations in the field waste management.

1.5. Industrial control in the sphere of waste management is carried out by:

I level — environmental protection services of the Company's business units

in compliance with annual industrial control schedule approved by the heads of

business units.

II level — specialists of the Company's Environmental Management and

Safety Division in compliance with annual industrial control schedule approved by

the First Deputy Director General of the Company.

1.6. The person responsible for organization and implementation of the

I level of control, including control in the sphere of waste management in a

business unit of the Company, is appointed by an order of a business unit head.

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1.7. The person responsible for organization and implementation of the II

level of control, including control in the sphere of waste management in a business

unit, is the Head of Environmental Management and Safety Division.

1.8. The industrial control in the sphere of waste management is carried out

on the basis of “Procedure of industrial control of waste management operations”

approved by authorized bodies, regulations of Environmental Management and

Safety Division, environmental protection department, waste management group,

environmental protection service of a business unit, administrative duties of

persons in charge mentioned in paragraphs 7.5, 7.6.

1.9. Facilities are subject to industrial environmental control if the

consequences of their activity lead to negative impact upon the environment:

- sources of pollutants emission into the atmosphere;

- sources of pollutants dumping into the environment;

- off gases cleaning systems;

I level of control

Environmental protection services

of business units

II level of control

Director General

First Deputy Director

General

Environmental Management and Safety

Division Head, Lyubov A. Malyshkina.

malyshkina_la@surgutneftegas.ru.

43 73 84, 43 73 85

Heads

of business units

Environmental Protection Department Head

Lyudmila L. Grigorchuk

grigorchuk_ll@surgutneftegas.ru, 43 73 47

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- sewage cleaning system;

- waste accumulation and disposal sites;

- equipment, units for waste use and decontamination;

- systems of prevention, localization and elimination of anthropogenic

accidents;

- environmental sites located within industrial sites, territory (water area)

of nature management and sanitary-hygienic zones.

1.10. The person responsible for permission of employees to work with

wastes of I - IV hazard class is the First Deputy Director General or an authorized

person of a business unit appointed by an order of a business unit head.

1.11. Employees permitted to I-IV hazard class waste management must

have the professional training proved by certificates enabling to work with wastes of

I-IV hazard class.

1.12. Preparation and formation of annual need in training of employees,

mentioned in paragraph 7.9 or planned to be permitted to the mentioned sphere is

carried out by the Human Resources Division of the Company in compliance with

local documents of the Company based on business units requests approved by

Environmental Management and Safety Division.

1.13. Training and learning courses mentioned in paragraph 7.9 are carried

out on account of cash resources of a business unit within allocated limits.

2. Types of IEC

2.1. The Company carries out industrial environmental control of the

following types:

office (documentary) audit, consisting in documentation testing of the facility

subject to control set by the environmental legislation and Federal Law No.174-FZ

without on-site visit;

inspectorial control, consisting in site survey;

ecoanalytical control, consisting in sampling and analysis of samples of

industrial discharges, sewages, accumulated wastes, their chemical analysis or

biotesting.

2.2. The control can be systematic and off-schedule.

3. IEC implementation

3.1. Implementation of control measures includes their planning and

preparation.

3.2. IEC can be systematic and off-schedule (for checkup of instructions

fulfillment, violations elimination orders and information about violation of legislation

requirements and administrative documents of the Company).

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3.3. Industrial control measures in the field of waste management can be

either special-purposed or a part of complex IEC measures including control of

adherence to the environmental legislation in whole.

3.4. Planning of IEC measures, including the ones in the field of waste

management are carried out in business units during the IV quarter of the year

previous to the year of inspection.

3.5. The person responsible for IEC in a business unit develops the

inspectorial control schedule of the Company's business unit (schedule of II level of

control), which is approved by a business unit head.

3.6. The person responsible for industrial control implementation in the field

of waste management in a business unit develops the following schedules:

schedule of natural environment monitoring in the territory of possible

negative impact of waste accumulation sites, which is approved by a business unit

head and sent to the Environment Management and Safety Division until August, 1;

schedule of inspectorial control (I level of control), which is approved by a

business unit head and sent to the Environment Management and Safety Division

until November, 1.

3.7. The person responsible for industrial control in the field of overall waste

management in the Company:

organizes the analysis of natural environment monitoring around landfills for

municipal and industrial waste, including landfills for oil sludge recycle against the

requirements of the present standard and project documentation;

organizes the development of the inspectorial control schedule of the

Company's business units (II level of control) and its concurrence, approval and

filing to the Company's business units until December, 10.

4. Inspectorial control procedure

4.1. Systematic inspectorial control is carried out in compliance with the

approved control plans (schedules), off-schedule inspectorial control is carried out

in compliance with an administrative document.

4.2. The person responsible for signing the administrative document to

carry out the inspectorial control (examination) is the First Deputy Director General.

4.3. The person responsible for overall inspectorial control in the Company

is the Environmental Management and Safety Division Head, for inspectorial control

in a business unit — its head or a person appointed to be responsible for

inspectorial control in a business unit by a business unit head.

4.4. Types of administrative documents for inspectorial control realization

are order, instruction, approved control schedule, directed in accordance with the

procedure established in the Company.

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4.5. Inspectorial control is carried out by:

I level: the person responsible for conduct of control appointed from among

specialists of environmental or production services of business units;

II level: the person responsible for conduct of control appointed from among

specialists of Environmental Management and Safety Division.

4.6. The procedure of organization and conduct of inspectorial control:

analysis of the previous inspections results;

determining production facilities, transport and materials that need to be

inspected;

determining the necessity of involving of other services and business units

specialists, including ecoanalytical laboratories;

information about timing of the inspection;

drawing up of control results and control report in compliance with

SТО 34.0-2013;

control of detected violations elimination.

5. Ecoanalytical control procedure

5.1. If ecoanalytical study is necessary in the process of inspectorial control

the following business units are involved in compliance with inspectorial control

schedule:

I level: LHAI TSNIPR of OGPD of the Company accredited for more than

30 ecological parameters (in the territory of the Republic of Sakha (Yakutia) and

Irkutskaya Oblast — PIL of OGPD “Talakanneft” accredited for 283 parameters,

including 24 radiological ones);

II level: TSBL IEVTS of OJSC “Surgutneftegas” accredited for performing the

analysis and radiation survey of 707 parameters, including 365 ecological ones.

5.2. Ecoanalytical control and biotesting of waste samples are carried out in

TSBL IEVTS of OJSC “Surgutneftegas”, Surgut derpartment laboratory of

FBU “TSLATI in the Ural Federal District” of KhMAO-Yugra, accredited for

performing of such type of works based on the bilateral contract.

5.3. Ecoanalytical control of the natural environment around landfills for

municipal solid and industrial waste is carried out by TSBL IEVTS of

OJSC “Surgutneftegas” and the subsidiaries of Federal budget health care

organization in compliance with the requirements of paragraph 9.6 of the present

standard.

5.4. The procedure of organization and conduct of ecoanalytical control

during inspectorial control:

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the necessity of involving of ecoanalytical laboratories specialists during

inspectorial control is determined by the person responsible for the inspection

conduct;

information about timing of the inspection, list of natural environments,

defined indicators;

collection of natural environments samples and drawing up of collection

report;

studies and drawing up of the results;

presentation of the ecoanalitical control results to the person responsible for

the control conduct.

6. Drawing up of the IEC results

6.1. The control report on the results of IEC is drawn up in compliance with

the requirements of STO 34.0-2013. It contains the information on:

compliance of inspected facilities with the requirements of natural

environment legislation, ecological safety and organization standards;

compliance with the requirements of the legislation in the sphere of waste

management, ecological, sanitary-epidemiological rules and guidelines of waste

management set by “Procedure for the industrial control in the field of waste

management in OJSC “Surgutneftegas”, instructions of waste management,

PNOOLR;

suggestions of implementation of necessary measures and works and dates

of their performance.

6.2. In case of drawing up of the results of inspectorial control, which is

performed along with ecoanalytical control, the note about conjoint ecoanalytical

control is to be made in the report; sample collection and studies results reports (or

copies with sign of the service, in which the original documents are kept) are to be

filed to the control report.

6.3. Control of suggestions and prescriptions fulfillment is carried out by the

person, who made them, without preliminary notification of the inspected one.

Control of suggestions and prescriptions fulfillment is carried out every month, the

results are reported at monthly summing-up meeting.

6.4. IEC results are subject to accounting, analysis and summarizing aimed

at further use in implementation of industrial control in the field of waste

management.

6.5. The results of detected violations analysis are announced at the

monthly council of business units heads under the chairmanship of

Director General or any other nearest meeting, at which the issues of adherence to

the environmental legislation are considered.

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7. Control of license requirements in the field of waste management

7.1. In compliance with the Federal Law No.99-FZ “On production and

consumption waste” as of 24.06.98 (hereinafter — the Law No.99-FZ) the activity of

the Company on waste decontamination and disposal with the use of buildings,

installations, technical solutions, equipment and other facilities owned by the

Company as a property or on any other legal grounds is subject to licensing.

7.2. Licensing control of the activity on waste decontamination and disposal

is carried out in compliance with the Law No.294-FZ accounting for the

specifications set by the Law No.99-FZ and Government Decree No.255 as of

28.03.2012.

7.3. Licensing requirements when performing activities in the field of waste

management, which are subject to licensing:

buildings, installations, technical solutions, equipment and other facilities

owned by the Company as a property or on any other legal grounds used for waste

decontamination and disposal;

professional training of the Company's personnel engaged in waste

management, which gives the right to work with wastes of I-IV hazard class, proved

by certificates;

an official responsible for permission of employees to the work with wastes;

the system of industrial control in the field of waste management;

the results of environment condition and pollution level monitoring in the

territories of waste disposal facilities and within their impact upon the environment

in compliance with article 12, paragraph 3 of the Law No.89-FZ.

7.4. Failure to fulfill the requirements stated in paragraph 8.3 as well as

actions entailed occurrence of threat to life, health of people, animals, plants,

environment, cultural heritage sites (historical and cultural monuments) of the

peoples of the Russian Federation as well as threat of anthropogenic emergency

situations or human losses or infliction of grievous bodily injury, average bodily

injury to two or more persons, infliction of injury to animals, plants, the environment,

cultural heritage sites (historical and cultural monuments) of the peoples of the

Russian Federation, threat of anthropogenic emergency situations, infringement

upon rights, legitimate interests of people, threat of the country defense and safety

are the gross violation of license requirements.

7.5. Gross violation of license requirements can entail imposing

administrative responsibility on the Company and, consequently, suspension of the

license for decontamination and disposal of wastes of I-IV hazard class by licensing

authority.

7.6. Licensing authority (Rosprirodnadzor) carries out office audits and offschedule

on-site inspections without an agreement with prosecutor's office in

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accordance with the established procedure with regard to an applicant for the

license or a licensee applied for reissuing of the license.

7.7. Licensing authority carries out office audits, systematic inspections and

off-schedule on-site inspections regarding a licensee.

7.8. Systematic inspection of licensee is carried out in compliance with

annual systematic inspections schedule developed in accordance with the

established order and approved by the licensing authority.

7.9. Grounds for inclusion of a licensee systematic inspection to the annual

systematic inspections schedule are as follows:

expiry of one year since the day of the decision of concession or reissuing of

the license;

expiry of three years since the day of the last systematic inspection of a

licensee.

7.10. Off-schedule on-site inspection of a licensee is carried out on the

following grounds:

expiration of time given to a licensee to fulfill prescriptions to eliminate

violations of license requirements by the license authority;

receipt by the licensing authority of the applications, requests of people

including self-employed entrepreneurs, legal entities, information from public and

local authorities and media about major violations of license requirements by a

licensee;

expiry of time of license suspension in compliance with paragraphs 2 and 3 of

the article 20 of the Federal law No.99-FZ “On licensing of certain kinds of activity”

as of 04.05.2011;

application of the licensee for off-schedule on-site inspection to ascertain a

fact of early fulfillment of prescription made by the licensing authority;

order (directive), issued by the licensing authority in compliance with

assignment of the President of the Russian Federation or the Government of the

Russian Federation.

7.11. Off-schedule on-site inspections are carried out without an agreement

with the prosecutor's office, except for inspection of crude violation of license

requirements by a licensee.

7.12. Off-schedule on-site inspection of crude violation of license

requirements by a licensee approved by the prosecutor's office in accordance with

the established procedure is justified to be carried out by the licensing authority

without prior notification of a licensee.