“CHECKLIST”

TECHNICAL AUDIT/MONITORING CHECKLIST FOR A PLUGGED, ABANDONED AND DECOMMISSIONED WELL

SITES
1. GENERAL INFORMATION:

1.1. Project Details

Date & Time of Inspection

Project Title

Name of
Operator/Licensee

Nature of Field o Onshore

Offshore

1.2. Location

Physical Address

Region

County

Sub County

GPS Coordinates
1.3. Stakeholder Consultation

Stakeholder Contact Details comments

SNo Thematic area Area of interest/ Auditors to investigate. Finding/Observation

.

01 Land 1. Establish the current land ownership of the

ownership and decommissioned site.
the current land 2. Find out the current land use of the decommissioned
use site and the neighborhood
3. Presence of environmentally and ecologically sensitive
areas around the decommissioned site
4. Establish whether the decommissioned site was
 handed over to land owners officially

02 Soil and 1. Establish the current status of the top soil at the
Groundwater decommissioned site. Is it still compacted? Where was
the source of soil that was used to backfill?
2. Any evidence of ground cover or natural regeneration?
3. Establish whether there is residual hydrocarbons or
chemicals from drilling operations seeping into the soil
or ground water
4. Check for any leftover chemicals used in the drilling
and plugging processes that might contaminate the
environment.
5. Conduct soil and water quality testing in the area
around the well.
6. If the gas is leaking, identify where the gas is leaking
from — whether it is from the wellhead, casing, or
underground migration to the surface
7. Confirm the composition of the gas if being released
(e.g., methane, hydrogen sulfide, or volatile organic
compounds) through sampling and analysis to
understand the risks it poses.
8. Inspect the surrounding area for visible signs of gas
seepage (bubbling, dead vegetation, or soil
disturbance) and confirm if gas is migrating beyond
the wellhead.
9. Examine the surrounding soil and vegetation for signs
 of gas-related contamination, such as dead plants or
altered soil conditions, which can indicate widespread
leakage.
10. Through desktop or existing hydrogeological studies,
establish the depth of the water table around the
decommissioned site.
11. Is the site leveled and contoured for drainage and
erosion control and revegetated?
12. Soil seed bank confirmation (Collect soil for control
germination)

03 Well Integrity 1. Confirm the well was properly sealed with cement and
and Plugging casing.
2. Check for surface signs of erosion, sinkholes, or
subsidence at the well site.
3. Assess structural integrity of casing, checking for
corrosion or mechanical failure.
4. Verify well cement plug conditions, ensuring no
degradation or improper placement.
5. Review plugging records, ensuring adherence to
industry standards.
6. Conduct pressure testing to detect potential leaks.
7. Validate cement bond logs and casing evaluation logs
for proper sealing.

04 Air Quality 1. Establish if there is any pungent, offensive and foul

 Concerns smell at the decommissioned well site
2. Gas buildup: Check for any residual gases trapped
underground that could potentially escape through
poorly plugged wells.
3. Evaluate the concentration of gases (particularly
methane) in the air around the well. Methane in high
concentrations poses a significant fire or explosion
hazard.
4. If the well contains hydrogen sulfide (a toxic and
flammable gas), check for H₂S levels. Even small leaks
can be deadly and require immediate safety precaution
5. Confirm whether the well area is cordoned off and
access is restricted to prevent harm to people and
animals.

05 Surface and 1. Water contamination: Investigate the surrounding

Subsurface bodies of water for signs of contamination.
Water Impact 2. Salinity intrusion: Check for any saltwater intrusion
into freshwater aquifers that may have occurred
during drilling operations.
3. Evidence of flooding or surface run off channels or rain
water stagnation
4. Confirm the availability of an existing observational
and monitoring well

06 Ecological 1. Inspect the surrounding area for signs of ecological

 Impact disruption, such as damaged vegetation, reduced
biodiversity, or disturbed animal habitats.
2. Is the nearby vegetation evenly distributed?
3. Is the vegetation showing any sign of stress or
inhibition?
4. Establish if the tree species or vegetation around the
decommissioned site are compatible with the
surrounding species or habitat.
5. Given the proximity to the Indian Ocean, check for any
potential contamination affecting nearby marine life,
coral reefs, or mangrove ecosystems.

07 Waste 1. Ensure drilling muds, cuttings, and other waste were

Management properly disposed of.
2. Verify hazardous material disposal methods.
3. Check for compliance with waste tracking records.
4. Confirm removal or remediation of contaminated
equipment and non-native materials.
5. Assess whether bioremediation or soil treatment was
implemented.

08 Regulatory 1. Verify that the well closure and decommissioning

Compliance adhered to local and national regulations set by NEMA
and other relevant bodies
2. Confirm whether Decommissioning certificate was
issued by NEMA
 3. Establish if Environmental Audit was undertaken , if
yes, a copy to be shared for review.

09 Community 1. Verify that the site is properly fenced and marked to

Health and prevent unauthorized access.
Safety 2. Assess the site's proximity to residential or commercial
areas.
3. Evaluate the risk of contamination to local water
sources and agriculture.
4. Confirm whether facilities and infrastructure were
handed over to the local community.
5. Review community engagement records, ensuring
affected residents were informed of site risks.
6. Establish whether a compensation mechanism exists
for impacted communities.
7. Assess history of reported incidents around the site.

10 Site 1. Establish whether the site was restored to its original

Reclamation/res condition or to a stable state, including re-vegetation
toration and contouring of the land.
2. Evaluate if there are provisions in place for long-term
monitoring of the site for any potential environmental
hazards
3. Verify provisions for long-term monitoring.

11 Public 1. Ensure Meetings, hearings, or reports are conducted to address

community concerns.
 Participation 2. Ensure Regular updates to the public on project progress, risks,
and timelines.

12 Mapping Ensure that all relevant stakeholders (e.g., regulatory bodies, local
Stakeholders communities, landowners, environmental groups, and contractors)
are accurately identified.

Assess the effectiveness of stakeholder engagement strategies,

including consultation meetings, communication plans, and
grievance redress mechanisms.

3. Verify that concerns and inputs from stakeholders are

documented and incorporated into the decommissioning
process

13 Land 1. Confirm land title deeds, lease agreements, and property

boundaries to determine rightful ownership.
Lease/Documen
tation Review lease expiration terms, renewal clauses, and transfer
conditions.

1. Ensure adherence to government regulations on land use,

reclamation, and environmental responsibilities.

4. Confirm agreements on land handover to the owner or

government.

14 Budget and Verify that sufficient funding is allocated for all phases of
decommissioning, including well plugging, site restoration, and long-term
Funding
monitoring.

Ensure budget transparency and proper financial reporting to prevent

 cost overruns or mismanagement.

Assess the availability of financial assurance mechanisms (e.g., bonds,

decommissioning funds, or insurance) to cover unforeseen expenses.
Top of Form

Bottom of Form

5.

15 Cultural Identification of culturally significant sites (e.g., indigenous lands,

historical artifacts, sacred sites).
Heritage
Ensure Compliance with heritage preservation laws and regulations.

5. Verify Engagement with archaeologists and cultural heritage

experts to assess potential risks.

16 Legal Ensure that all decommissioning activities align with the Petroleum
Compliance Act No. 2 of 2019, Kenya Law.

Verify that the operator has established a decommissioning fund, as

required by the Act, to cover future plugging, abandonment, and
decommissioning costs.

Review all submitted documentation, including decommissioning plans,

environmental impact assessments, and compliance reports, to ensure
they meet the stipulations set forth in the Act.

6.
17 ESMP

Ensure compliance with soil stabilization, vegetation replanting,

and habitat restoration requirements.

Verify proper handling, transportation, and disposal of hazardous

and non-hazardous materials.

Assess measures for preventing groundwater contamination and

minimizing emissions.

Ensure mitigation of impacts on local flora, fauna, and ecosystems.

Confirm that local communities, indigenous groups, and other

stakeholders were consulted.

Assess compliance with occupational health and public safety

regulations.

Evaluate compensation plans for affected communities and

employment transition plans for displaced workers.

Verify adherence to safeguards for culturally or historically

significant sites.

Ensure compliance with environmental and social impact

assessment (ESIA) requirements.

7. Confirm the existence of measures for handling spills,

accidents, and unforeseen environmental/social risks.
18 HSE of Workers

Verify availability and proper use of PPE (helmets, gloves,

respirators, fire-resistant clothing, etc.).

Ensure workers are trained in hazard recognition, emergency

response, and confined space entry.

Review Job Safety Analysis (JSA) and hazard control measures for
high-risk activities.

Ensure compliance with procedures for chemical handling,

transportation, and disposal.

Inspect fire suppression systems, gas monitoring devices, and

ignition source control.

Verify permits for hot work, confined space entry, and heavy lifting
operations.

Confirm availability of evacuation plans, spill response procedures, and

medical emergency protocols.

Ensure on-site presence of first aid kits, emergency medical

personnel, and ambulance services.

Check documentation of past incidents, root cause analysis, and

corrective action implementation.

8. Review frequency and effectiveness of safety meetings,

toolbox talks, and emergency drills.
19 Water and Air Verify proper well sealing and plugging to prevent leaks or migration of
fluids.
Sampling
Assess compliance with regulations for wastewater treatment,
reinjection, or disposal.

Verify that sediment and erosion control measures are in place to

prevent runoff contamination

Review adherence to local, national, and international air quality

regulations.

9. Assess air monitoring data for compliance with

permissible exposure limit

20 Post - 10. Verification of land reclamation efforts, including soil

Decommissione stabilization, re-vegetation, and erosion control.
d Plan 11. Assessment of water and air quality monitoring results to
confirm no residual contamination.

Compliance with environmental regulations and submission of

post-decommissioning environmental impact assessments (EIA).

12. Establishment of a monitoring program for groundwater

contamination, gas emissions, and land subsidence.

21 GRM Ensure the GRM is easily accessible to affected communities,

workers, and other stakeholders.

Verify that clear procedures are in place for submitting, tracking,

 and resolving grievances.

Assess the effectiveness of communication channels (e.g.,

hotlines, online platforms, in-person offices).

Review the timeliness and fairness of grievance resolution,

ensuring compliance with legal and regulatory frameworks.

Evaluate documentation of past grievances, including resolution

outcomes and corrective actions taken.

13. Confirm the presence of an appeal mechanism for

unresolved or escalated disputes.

21 Emergency Verify the existence and adequacy of an Emergency Response

Preparedness Plan (ERP) covering potential hazards such as gas leaks, well
blowouts, chemical spills, and fire incidents.
Plan
Assess the availability and functionality of emergency
equipment (e.g., fire suppression systems, spill containment kits,
personal protective equipment).

Ensure emergency drills and training are conducted regularly for

workers and response teams.

14. Confirm the presence of evacuation procedures,

emergency contacts, and coordination protocols with
local authorities and first responders.

22 Project Affect Verify that fair compensation has been provided to affected
Persons
 individuals for land use, displacement, or economic losses.

Assess the effectiveness of livelihood restoration programs, such

as job training, alternative employment, or financial support.

15. Ensure stakeholder engagement and grievance redress

mechanisms (GRM) are in place to address concerns and
disputes.

23 Harzadous Verify that hazardous materials (e.g., drilling fluids, chemicals,

Material contaminated soil) are properly identified, labeled, and stored
according to regulations.

Ensure safe disposal methods are used, including certified waste

disposal facilities or treatment processes.

16. Assess compliance with hazardous material transport

regulations and spill prevention measures.

24 Timelines for Verify that plugging, abandonment, and decommissioning

Decommissioni activities are completed within the approved timelines.
ng Ensure compliance with regulatory deadlines for well closure, site
restoration, and environmental monitoring.

17. Assess the impact of delays and mitigation measures to

prevent cost overruns and non-compliance penalties.

25 Actively Ensure that decommissioning activities follow regulatory

Decommissione guidelines, industry standards, and environmental best
practices.
d Site
Verify that well plugging, equipment removal, and site
 restoration are conducted safely and effectively.

18. Assess ongoing health, safety, and environmental (HSE)

measures to protect workers and surrounding communities.

26 Infrastructure Verify that wells, pipelines, tanks, and other infrastructure are
Removal Plan removed according to safety and environmental regulations.

Ensure proper segregation, recycling, or disposal of materials to

minimize environmental impact.

19. Assess compliance with site restoration requirements after

infrastructure removal.

27 Biodiversity of 1. Conduct surveys on vegetation, tree cover, and

the site wildlife presence.

2. Assess species habitat conditions near the

decommissioned site.

1.4. Comments
1.5. Recommendations