Managing Spills & Releases

Denbury’s environmental responsibility strategy starts with preventing spills and releases and having measures in place to respond to incidents or other emergencies if they do occur. Our environmental policies and measurement of our HSE performance form the foundation of our management of spills and releases. We also focus on spill prevention in all aspects of our operations, and we have put emergency preparedness and emergency response programs in place in order to respond to any incidents that may occur.

ENVIRONMENTAL POLICIES & PERFORMANCE

Denbury seeks to continuously improve our HSE performance by focusing on training and preparedness with established measurement systems to monitor our results. Denbury has a long-standing commitment to setting and achieving high standards for protecting the environment. To accomplish our goals, we focus on the safety of our employees, implement high standards of environmental stewardship and ethical conduct, and work proactively to be a good corporate citizen by aligning our interests with those of our neighbors.

We are committed to eliminating all environmental incidents in our operations. Our commitment begins with our leadership and extends to our employees and contractors. Everyone is empowered and expected to work safely and protect the environment by recognizing and proactively addressing potential hazards and stopping any job they believe to be unsafe or which poses an environmental threat. The success of our HSE programs hinges on a commitment from our senior management and awareness, training and actions of our employees.

We track performance indicators designed to measure progress towards our environmental goals including spill prevention and regulatory compliance. These metrics are monitored and reported to the Board and all employees to reinforce their importance. The compensation of all Denbury employees is partially tied to the achievement of these goals to further reinforce the importance of safety in everything we do.

It is Denbury’s policy to conduct business in a manner that respects the environment, as well as the health, safety and security of its stakeholders.

General guiding principles for the Company, its employees and contractors:

  • Implement and maintain an HSE management system to achieve the objectives outlined in our HSE Policy.
  • Comply with all applicable HSE laws, rules and regulations, not just because it is legally required, but also because we believe it is the responsible way to conduct our business.
  • Educate and train employees and contractors to provide them with the knowledge, skills, and understanding to perform their responsibilities and duties at the highest level and maintain a safe, secure and healthy work environment.
  • Continue to minimize the impact of our business activities on the environment by implementing economically feasible projects that promote energy efficiency and use natural resources effectively.
  • Achieve continuous HSE improvement and compliance by setting HSE leading and lagging performance targets annually, auditing assets and business practices, reviewing results and regularly reporting our performance.
  • Routinely review and verify performance with audits, evaluations and other quality assurance and quality control methods.
  • Identify and assess potential risks, hazards and threats to people, the environment, and our assets, and implement reasonable and practicable actions to eliminate, mitigate, or manage these risks.
  • Empower and expect employees and contractors of the Company to immediately “Stop Work” without fear of reprisal when an unsafe condition or act is observed which could affect the safety of personnel and/or the environment and to report noncompliance or unsafe conditions and take immediate action to prevent injuries or environmental incidents.
  • Work proactively with stakeholders to develop and advance effective approaches to health, safety, security and environmental protection.
  • Provide resources necessary to manage and communicate our HSE commitment, expectations and accountability in the same manner as any other critical business function.

Compliance with our HSE Policy and working safely are conditions of employment for all employees of the Company, as well as for contractors to work with the Company. Every Denbury employee is expected to take personal responsibility to understand and comply with our HSE Policy.

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THE ENVIRONMENTAL PARTNERSHIP

In 2018, Denbury became a participant in the American Petroleum Institute’s The Environmental Partnership. The Environmental Partnership is comprised of 65 U.S. oil and natural gas companies who are committed to continuously improving the oil and natural gas industry’s environmental performance. The Environmental Partnership’s key focus is furthering action to reduce the oil and natural gas industry’s air emissions, including methane, GHG and Volatile Organic Compounds (“VOC”), associated with oil and natural gas production. As part of our membership in The Environmental Partnership, Denbury is committed to implementing and phasing into our operations certain leak detection and repair programs, and we track and annually report the results of these programs to The Environmental Partnership.

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SPILL PREVENTION EFFORTS

Denbury’s HSE policy emphasizes spill prevention and minimization with a focus on sound design and engineering standards to prevent spills from occurring.

Our operations are somewhat unique because the fields we operate often contain wellbores drilled, and subsequently plugged and abandoned, decades ago by prior operators. The CO2 EOR process involves injecting CO2 back into mature reservoirs to mobilize stranded oil. Therefore, it is important for the previously plugged and abandoned wells to maintain well integrity. To help ensure that all wellbores in a field are appropriately secured, we have developed an internal review process in order to evaluate wells. Wells that need additional work are designated for repair to help ensure their integrity. Denbury has experienced engineering teams that focus on this review program.

In an effort to learn from every opportunity, we encourage and support incident reporting at all levels. By studying the root cause of actual events, near misses and close calls, we can work towards removing and/or mitigating the circumstances that might have led to the unwanted event. Any identified corrective actions are implemented to prevent similar occurrences.

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CORPORATE LDAR PROGRAM - THERMOGRAPHY PROGRAM

Denbury has instituted a thermography program in response to Leak Detection and Reporting (“LDAR”) regulations and to aid in emissions monitoring across our operations. While the program’s main focus is to support compliance with LDAR standards, Denbury has also exploited these new capabilities to utilize Optical Gas Imagery (“OGI”) (infrared cameras that visualize leaks that are invisible to the human eye) to help with maintenance and reliability of our equipment. The use of OGI in normal operations allows operators to visualize and repair methane and VOC leaks more completely company-wide which is a benefit to federal and state air quality standards. In addition, greater prevention of leaks and facility upsets minimizes the loss of fluids further conserving natural resources.

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CORPORATE COMPLIANCE INSPECTION AND VERIFICATION

Denbury core values include operating in compliance and doing what is right. To achieve these goals, internal corporate inspection programs allow Denbury to carry out our values. Compliance with emissions, air quality and greenhouse gas standards is attained in part with the implementation of emission compliance inspections programs. These field inspection and corrective action implementation programs are supported by internal environmental scientists and engineers, specialized commercial software, company-wide training and Denbury leadership’s commitment to providing the corporate resources necessary to make these programs functional. Denbury has conceptualized, developed and implemented an emission compliance program in our northern region of operations, and we have initiated the implementation of this practice across our operations.

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EMERGENCY RESPONSE PLAN

The Denbury Control Center is where we remotely monitor functionality of our CO2 pipeline networks 24/7.

At Denbury, we focus on prevention of incidents through our project designs, planning, implementation and execution. However, we also remain prepared to respond quickly and effectively to an incident.

Denbury has a company-wide Emergency Response Plan that covers various types of emergencies, including spill response, well-control events, natural disasters, fire and pandemics. Emergency Response Plans, Facility Response Plans, Spill Prevention Control and Countermeasure Plans are employed at our field locations, where applicable. Emergency response procedures are routinely communicated through orientations, drills, exercises and routine training meetings.

Denbury also has staff trained and experienced in emergency response procedures. We manage all incidents using the National Incident Management System (“NIMS”) and the Incident Command System (“ICS”). Each year, key employees are trained in ICS to be prepared to respond to any incident. Our first priorities in any incident are the safety of our personnel and the public and the protection of the environment.

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