Project CECP.pdf

Ras Az Zawr Aluminium Smelter Project Construction Environmental Control Plan 25457-0000-G01-GHX-0003 rev.002

Bechtel Confidential Contains Bechtel and its affiliated companies confidential and/or intellectual property which shall not be used, disclosed or

reproduced in any format by any non-Bechtel Party without Bechtel’s prior written permission. All rights reserved. Saudi Arabian Mining Company (Ma’aden) shall have an unconditional perpetual, royalty-free, freely sub-licensable and assignable license to use

such intellectual property for all purposes in connection with the Project.

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CONTENTS: KEY OBJECTIVES ..............................................................................................................1

1 INTRODUCTION..................................................................................................................9

2 GENERAL PROJECT INFORMATION .............................................................................10

2.1 Site Description.........................................................................................................10

2.2 Project Description....................................................................................................12

3 RESPONSIBILITIES..........................................................................................................14

3.1 Employer / Operator .................................................................................................14

3.2 Bechtel......................................................................................................................14 3.2.1 Project Manager............................................................................................14 3.2.2 Site Manager.................................................................................................15 3.2.3 Oversight Construction Camp Committee.....................................................15 3.2.4 Construction Environmental Coordinator ......................................................15 3.2.5 Project Environmental Lead ..........................................................................16 3.2.6 Contract Administrators.................................................................................17 3.2.7 Contract Supervisors.....................................................................................17

3.3 Contractors ...............................................................................................................18

4 ENVIRONMENTAL MANAGEMENT CONTROLS ...........................................................19

4.1 Environmental Awareness Training ..........................................................................19

4.2 Environmental Compliance Reviews, Coordination and Communication.................19

4.3 Environmental Compliance Inspection and Documentation .....................................20

5 ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES ............................21

5.1 Noise.........................................................................................................................21

5.2 Air Quality (Fugitive and Vehicular Emissions).........................................................21

5.3 Erosion and Sedimentation Control ..........................................................................21

5.4 Construction Storm Water Management ..................................................................21

5.5 Protection of Sensitive Resources............................................................................21

5.6 Unanticipated Discoveries ........................................................................................21 5.6.1 Archaeological and Cultural Resources ........................................................22 5.6.2 Existing Contamination .................................................................................22 5.6.3 Notification / Stop Work Process for Unanticipated Discoveries...................22





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5.7 Hazardous Waste and Materials Management.........................................................23

5.8 Spill Prevention and Response.................................................................................23

5.9 Solid Waste Management.........................................................................................23

5.10 Water Conservation ..................................................................................................23

5.11 Wildlife and Plant Protection.....................................................................................24

5.12 GHG Tracking...........................................................................................................25

6 EMERGENCY EVACUATION AND RESPONSE PLAN...................................................26





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Tables & Appendices

Table 1 - Acronyms ...................................................................................................................28

Table 2 –Saudi Environmental Organisations, Laws and Regulations ................................29

Appendix A Environmental Awareness Training ...................................................................31

1. ENVIRONMENTAL AWARENESS TRAINING PROGRAM......................... 32 1.1 Environmental Awareness Training For New Hires .............................33 1.2 Supervisor Environmental Training......................................................33 1.3 Environmental Management Training ..................................................34 1.4 Job Specific Training............................................................................34 1.5 “Toolbox” Training................................................................................34 1.6 Environmental Awareness Training Outline.........................................35

Appendix B Noise Abatement Plan .........................................................................................36

1. INTRODUCTION.......................................................................................... 37

2. DEFINITIONS .............................................................................................. 37

3. NOISE LIMITS ............................................................................................. 37

4. NOISE MONITORING.................................................................................. 38

5. NOISE MITIGATION .................................................................................... 38

Appendix C Fugitive Dust Control Plan ..................................................................................41

1. INTRODUCTION.......................................................................................... 42

2. RISK ASSESSMENT ................................................................................... 42

3. SOURCES ................................................................................................... 42

4. CONTROL MEASURES .............................................................................. 42

5. MONITORING.............................................................................................. 44

6. ADDITIONAL REQUIREMENTS.................................................................. 45

Appendix D Construction Erosion and Sediment Control and Stormwater Management Plan......................................................................................................................46

1. INTRODUCTION.......................................................................................... 47

2. GENERAL EROSION AND SEDIMENT CONTROL REQUIREMENTS...... 47 2.1 General Excavation and Stockpile Areas (Rough Grading & Surface

Preparation) .........................................................................................47 2.2 Structural Excavation (Sub-Surface)....................................................48 2.3 Exposed Slopes ...................................................................................48 2.4 Roads and Hardstand Areas................................................................48 2.5 Culverts and Ditches............................................................................49





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3.0 EROSION CONTROL BEST MANAGEMENT PRACTICES ...................... 49 3.1 Temporary Vegetation .........................................................................50 3.2 Runoff Control......................................................................................50 3.3 Grading ................................................................................................50 3.4 Drainage Ditches .................................................................................51 3.5 Check Dams ........................................................................................51 3.6 Slope Drains ........................................................................................51

4.0 SEDIMENT CONTROL ................................................................................ 51 4.1 Silt Fences ...........................................................................................52 4.2 Straws / Hay Bales...............................................................................52 4.3 Sediment Basins ..................................................................................52 4.4 Sediment Traps....................................................................................53 4.5 Flocculants...........................................................................................53 4.6 Permanent Vegetation .........................................................................53

5. STORMWATER MANAGEMENT................................................................. 55

6. MAINTENANCE OF CONTROL MEASURES ............................................. 56 6.1 Inspections...........................................................................................56 6.2 General Inspection Activities................................................................56 6.3 Specific Inspection Activities................................................................57 6.4 Inspection Reports ...............................................................................57

7. NON-STORM WATER DISCHARGES ........................................................ 57 7.1 Control of Other Potential Sources of Storm Water Pollution ..............57 7.2 Hazardous Waste Storage Areas ........................................................58

8. GROUND WATER ....................................................................................... 58

9. SURFACE WATER ...................................................................................... 59

Appendix E Hazardous Waste and Material Management...................................................61

1. INTRODUCTION.......................................................................................... 62

2. HAZARDOUS WASTE AND MATERIAL MANAGEMENT........................... 62 2. 1 Classification of Hazardous Material....................................................62 2.2 Hazardous Wastes and Hazardous and Non-Hazardous By-Products63 2.3 Material Approval .................................................................................63 2.4 Banned Materials .................................................................................64 2.5 Material Safety Data Sheet ..................................................................64 2.5 Workplace Hazardous Material Information Communication...............65 2.6 Inventory Control..................................................................................65 2.7 Hazardous Material and Hazardous Waste Handling and Storage .....65 2.8 Hazardous Material Management........................................................68 2.9 Hazardous Waste Transportation ........................................................69





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2.10 Inspection...........................................................................................70 2.11 Training ................................................................................................70

Appendix F Spill Prevention & Response Field Plan ..........................................................74

1. SPILL PRE-PLANNING AND PREVENTION............................................... 75 1.1 Responsibilities ....................................................................................75 1.2 General Requirements for Spill Prevention and Response .................77 1.3 Spill Kits ...............................................................................................77 1.4 Disposal Requirements........................................................................80 1.5 Contaminated Soil................................................................................80 1.6 Spill Response and Clean Up Procedures...........................................80 1.7 Notification and Reporting....................................................................82

Appendix G Waste Management Plan ..................................................................................84

1. INTRODUCTION.......................................................................................... 85

2. PURPOSE.................................................................................................... 85

3. DEFINITIONS .............................................................................................. 85

4. RESPONSIBILITIES .................................................................................... 86

5. ANTICIPATED WASTES ............................................................................. 88

6. GENERAL WASTE MINIMIZATION AND MANAGEMENT MEASURES.... 90 6.1 Anticipated By-products ......................................................................91 6.2 Contractors Requirements ...................................................................92 6.3 General Housekeeping ........................................................................92

7. INERT AND NON-HAZARDOUS WASTE MANAGEMENT......................... 92 7.1 Non-Hazardous Waste Collection........................................................92 7.2 Non-Hazardous Waste Labelling and Storage.....................................93 7.3 Inert Material ........................................................................................94 7.4 Reuse and Recycling ...........................................................................95

8. OTHER WASTE STREAMS ........................................................................ 95 8.1 Sanitary Wastewater Management......................................................95 8.2 Medical Waste Management ...............................................................98 8.3 Used Oil Management .........................................................................98

9. TRAINING .................................................................................................... 99

10. INSPECTION REQUIREMENTS ................................................................. 99

11. REPORTING AND RECORD KEEPING.................................................... 100

Appendix H Environmental Inspection Reporting ...............................................................104

1. ENVIRONMENTAL INSPECTIONS AND REPORTING............................ 105





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Appendix I GHG Tracking Procedure ....................................................................................108

1. INSTRUCTIONS ........................................................................................ 109



reproduced in any format by any non-Bechtel Party without Bechtel’s prior written permission. All rights reserved. Saudi Arabian Mining Company (Ma’aden) shall have an unconditional perpetual, royalty-free, freely sub-licensable and assignable

license to use such intellectual property for all purposes in connection with the Project.

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KEY OBJECTIVES

This Construction Environmental Control Plan (CECP) describes the environmental management program for Bechtel and the CONTRACTOR entities during construction of the Ras Az Zawr Aluminium Smelter Project. Bechtel is dedicated to sustainable environmental protection and “Zero Environmental Incidents” is the objective of every project.

The objectives of the Project are:

No adverse impacts to the local community from noise during construction i.e. 70dBA or less at the boundary of the site;

No adverse impacts to the local community from man made dusts arising at the site during construction;

No long-term adverse impacts to the environment within the site boundaries from spills of hazardous materials i.e. drips and spills to be cleaned up (all hydrocarbon impacted materials to be removed to hazardous waste storage pending possible remedial treatment;

To optimise conservation of resources by re-use, recycling and waste management.

To reuse water as much as possible. Evey liter recycled is one less liter treated or hauled from offsite.

As part of the project, Bechtel will manage and implement the environmental procedures contained in this plan during construction, up to completion of construction activities and removal of construction equipment and materials to ensure compliance with Project requirements. Each Contractor involved in construction will be provided relevant sections of this plan and required to comply fully with its contents.

Periodic reviews of this plan and its procedures will be performed to ensure the plan’s adequacy throughout the project duration. The CECP will be expanded and updated as necessary to match unique field conditions, new permit conditions, changes in Saudi Arabian laws, specialized construction methods, public expectations, and direction from regulatory agencies and the Saudi Arabian Mining Company (Ma’aden).





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1 INTRODUCTION Saudi Arabia Bechtel Co. (Bechtel) is the Project Manager for Ma’aden, (Employer), to manage engineering, procurement and the construction of the Ras Az Zawr Aluminium Smelter Project (“Project”).

The Construction Environmental Control Plan (CECP) describes the environmental management system that is being used during construction and pre-operation testing of the Project. This CECP includes detailed plans to be implemented by Bechtel to ensure that Contractors comply with the project and regulatory environmental requirements. This CECP does not address environmental compliance activities during operations or design engineering and licensing support activities.

The objectives of the CECP are to:

Define the project specific requirements from Saudi Arabian environmental laws, regulations (see Table 2), permit conditions, Employer environmental requirements, Ma’aden Environmental Impact Assessment (EIA), and other applicable documents relating to construction of the project;

Define the environmental related roles, responsibilities and actions for project personnel during project execution to maintain compliance with the environmental requirements and to address any potential emergency situation(s); and

Provide information on procedures for communicating, implementing, documenting and reviewing environmental compliance activities;

This CECP applies to the Aluminium smelter, port facilities related to the smelter, and associated works.





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2 GENERAL PROJECT INFORMATION

2.1 Site Description

The proposed Aluminium Project site will be located within a new industrial precinct on the Ras Az Zawr peninsula, situated on the Arabian Gulf coast, 65 km northwest of the industrial city of Jubail (130 km by road), a further 160 km northeast of Al Khobar and approximately 400 km northeast of Riyadh. The general location of the site is presented in Figures 2-1 and 2-2 below.

The entire Ras Az Zawr industrial facility (including allocation for a phosphate facility and downstream industries) covers an area of approximately 69 km2. The construction and operation of the proposed project, on the Ras Az Zawr Peninsula will directly impact on 50 km2 of land and up to 56 km2 of marine environment.

The Ras Az Zawr site is within the eastern region of Saudi Arabia bordering the Arabian Gulf, and located on a coastal plain which rises gradually inland towards the Summan plateau. This area lies within the arid subtropical desert belt. Precipitation occurs almost exclusively in winter and is highly variable in both volume and spatial occurrence.

There is no permanent or semi-permanent surface water within the Ras Az Zawr study area other than in the tidal areas or excavation works where the groundwater is exposed. Groundwater on the coastal strip is considered to be typically shallow and hypersaline.

Ras Az Zawr Peninsula lies within the arid subtropical desert belt. Due to the Asian Monsoon cycle the Arabian Gulf region generally experiences two distinct seasons – the winter monsoon (December to March) and the summer monsoon (May to September) with short transitional seasons in between.





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Figure 2-1 Ras Az Zawr Aluminium Project General Location Map





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Figure 2-2 Detailed Site Location Map

Ras Az Zawr Industrial Area Master Plan

2.2 Project Description

The aluminium smelter is part of a planned industrial complex to include port facilities, a natural gas-fired power station, a desalination plant, an alumina refinery, a phosphate plant and other downstream industries.





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Existing infrastructure at the Ras Az Zawr site is minimal and will therefore require the establishment of all infrastructure to support the project.

Figure 2-3 Facilities of The Integrated Aluminium Project

Ras Az Zawr Aluminium Integrated Aluminium Project - General Arrangement





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3 RESPONSIBILITIES All project personnel are responsible for ensuring that construction activities are performed in accordance with environmental requirements. All project personnel have the responsibility to report to their supervisor, or stop work, when unsafe conditions to the human health or the environment exist. The specific responsibilities of the Project entities and personnel are addressed below.

3.1 Employer / Operator

The new facility will be owned by Ma’aden. Generally, the Employer will be the primary entity responsible for liaising with environmental agency representatives.

The Employer is responsible for acquiring permits and providing required notifications to the regulatory agencies, as described in required construction/operations permits and Bechtel’s Scope of Work. If requested by the Employer, Bechtel will assist the Employer in these activities. The Employer shall provide copies of permit applications, permits and other relevant documentation to Bechtel as necessary.

3.2 Bechtel

Bechtel is responsible for the engineering, procurement, and construction management of the Ras Az Zawr Aluminium Smelter Project and port facilities related to the smelter as well as ensuring that all the work is performed in compliance with applicable environmental requirements during engineering, construction, and operation of ancillary facilities during construction.

Bechtel personnel are responsible for the management of Contractor activities and will conduct regular inspections to identify those activities that pose a potential threat to the environment and/or are not in compliance with Project environmental requirements.

The following sections describe the division of responsibilities of the Bechtel team.

3.2.1 Project Manager

The Project Manager (PM) is responsible for the execution of Bechtel’s contractual responsibilities, including:

Contacting Bechtel Environmental Services and Bechtel’s Legal Department (in accordance with Bechtel Legal Instruction 127) in the event that significant environmental issues (e.g., non routine agency investigations, permit violations, reportable incidents, enforcement actions) arise which cannot be resolved at the project level;

Adhering to environmental requirements contained in the prime contract and ensuring that Employer environmental documents and requirements are available for use in the development of the CECP.

Complying with applicable environmental laws and regulations, including Kingdom of Saudi Arabia Presidency of Meteorology and Environment and Royal Commission Regulations.





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3.2.2 Site Manager

The Site Manager (SM) is responsible for overall construction management of the Project in compliance with Project environmental requirements. The SM is responsible for ensuring that the requirements set forth in this CECP are implemented. Communication of site environmental issues or status of site environmental compliance activities with the Employer, or any other party, is the responsibility of the SM. The SM’s specific duties include:

Reviewing the CECP and providing comments to the Project Environmental Lead (PEL) and Construction Environmental Coordinator (CEC);

Overall responsibility for the effective implementation of the CECP during construction; and

Ensuring Contractors comply with Project environmental requirements as stated in this CECP.

Communication with Oversight Construction Camp Committee in order to deliver environmental concerns regarding the daily operation of the construction camp.

3.2.3 Oversight Construction Camp Committee The Oversight Construction Camp Committee consists of the construction camp stakeholders represented by i.e. the Owner, Bechtel and Contractors. The main responsibilities of this committee include: Oversee the proper operation of the camp in term of daily activity and their compliance with

CECP.

Ensure corrected measures are implemented for any environmental non-compliance.

3.2.4 Construction Environmental Coordinator

The Construction Environmental Coordinator (CEC) Bechtel’s representative responsible for providing environmental technical support onsite so that construction activities take place in compliance with the Project's environmental commitments. The CEC may be a dedicated role or a collateral duty of an onsite person. Other specific duties of the CEC include the following:

Assisting the construction team, including Contract Supervisors and Contractors, in implementing the CECP, environmental plans and procedures, and permit requirements;

Reviewing construction plans, procedures, and specifications for compliance with the CECP and Employer permits and Saudi laws and regulations;

Coordinating project construction environmental activities with site personnel and the Employer, as required;

Performing or overseeing the day-to-day environmental compliance tasks and activities on the construction site (e.g., waste management areas, erosion and sediment control, noise, fugitive air emissions);

Monitoring and inspecting construction activities for compliance with the CECP;





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Documenting environmental compliance of construction activities (e.g., daily inspection reports, record keeping, agency notifications) and any non-compliances, including follow-up with appropriate parties to implement corrective actions in a timely manner;

Bechtel CEC will manage the training program, though individual contractors are responsible to provide environmental training to their employees as well as maintain records of attendance. Bechtel will provide suggested training materials so the project has a consistent message for ES&H.

Ensuring that Material Safety Data Sheets (MSDSs) for all hazardous materials are received and made available to appropriate Project and / or Employer Emergency Services prior to the material being brought onsite;

Providing the Site Manager with monthly and quarterly reports, as required by the Initial Environmental Approval and the EIA;

Providing monthly GHG tracking data to the PEL including all electricity use, fuel use, waste generated/recycled and water use for Bechtel and the Contractors.

Verifying that Contractors maintain records related to the handling, storage, transportation, and disposal of non-hazardous and hazardous waste and used oil in accordance with the CECP;

Updating or coordinating the update of the CECP with the Project Environmental Lead (PEL) as needed (e.g., changes in work scope, new permits received or major modifications made);

Monitoring and inspecting construction camp activities for compliance with CECP in accordance with Oversight Construction Camp Committee. Documenting environmental compliance of construction camp activities and also any non-compliance. Providing the Site Manager with periodic reports based on the documentation mentioned above.

Developing subsequent revisions of the Project CECP and other environmental plans required for construction (e.g., dust control, noise abatement, spill prevention, waste management); and

Developing subsequent revisions of the environmental engineering compliance matrix to reflect expected impacts and mitigation measures during construction and operation of the smelter and facilities.

3.2.5 Project Environmental Lead

The Project Environmental Lead (PEL) is the Bechtel home office environmental representative from Corporate Environmental Services. The PEL is responsible for ongoing technical support during construction (as needed) with regards to the development, implementation and enhancement of the Project environmental compliance program.

The PEL’s duties include the following:

Reviewing documents that contain the Project’s environmental requirements and commitments (e.g., prime contract, Bechtel’s scope of work, Employer-provided environmental documents, permit/consent applications and issued permits/consents, Ras Az





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Zawr Aluminium Project (EIA) and developing a summary matrix of environmental requirements to track the status of the incorporation of environmental requirements and responsibilities into construction planning and execution;

Identifying any permits and other authorizations that have not been obtained, but are required prior to the initiation of construction;

Ensuring Bechtel’s project team, as well as other project personnel, are adequately informed of the environmental requirements, potential environmental impacts of construction activities, and of the mitigation measures/actions required to maintain compliance with the Project’s environmental requirements;

Developing Revision 0 of the Project CECP and other environmental plans required for construction (e.g., dust control, noise abatement, spill prevention, waste management and tracking environmental metrics);

Coordinating with the SM, ES&H and Engineering Managers to ensure the CEC is assigned in adequate time to support construction activities;

Providing technical assistance and support to the project during construction to include implementation of the CECP and other environmental requirements;

Providing technical assistance and support to the project CEC in implementing the site environmental compliance program and environmental awareness training;

3.2.6 Contract Administrators

The Contract Administrators are responsible for formation and administration of contracts in coordination with the SM, ES&H Manager, PEL, and CEC.

Tendering contracts which clearly communicate the applicable project environmental requirements and regulations;

Requiring contractors to submit specific information regarding their activities, which may impact the environment or involve the use or generation of hazardous materials, used oil, or wastes;

Obtaining input and approval from the ES&H Manager for specific Contractor Plans and Procedures required by this CECP;

Providing Contractors with applicable documents stating the environmental requirements (e.g., CECP), and that contractual provisions are included to emphasize Contractors’ responsibilities to comply with Project environmental requirements;

3.2.7 Contract Supervisors

The Contract Supervisors are responsible for management and execution of the contract and will ensure that it complies with the requirements of this CECP.





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3.3 Contractors

Contractors, and their agents, are responsible for knowing, understanding and meeting the environmental requirements associated with their scope of work. Contractors must be fully cognizant of, and responsible for, complying with the applicable environmental requirements, procedures, restrictions and guidance provided in this CECP. Contractors are required to cooperate fully in implementing applicable environmental procedures, and will be held contractually responsible for failing to do so.

Each Contractor shall provide designated personnel to conduct and document daily environmental compliance inspections. Contractors are also responsible for producing an Environmental Management Plan which sets out how they will show compliance with the environmental requirements.

Bechtel’s CEC is responsible, via the contract supervisor, for ensuring that Contractor’s comply with the CECP and provide documentation verifying that compliance inspections are performed.





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4 ENVIRONMENTAL MANAGEMENT CONTROLS The objectives of this CECP will be achieved through implementation of the following management controls:

Preparing the Summary Matrix of Environmental Requirements for Construction;

Ensuring environmental awareness training is delivered to the entire construction work force, including Contractors;

Periodic inspections of construction activities and related facilities (weekly inspections of hazardous material storage areas, waste treatment equipment, and waste disposal areas);

Periodic audits of onsite environmental processes being utilized to assess their adequacy with respect to reducing or eliminating the likelihood of occurrence of environmental non-compliance situations.

4.1 Environmental Awareness Training

Every Bechtel and Contractor employee must attend an Environmental Awareness (EA) Training session. The EA training is provided before construction personnel, including Contractor employees, are allowed to work onsite as part of the induction training which all receive. The EA training provided is based on the Project’s environmental requirements.

The EA training section of the site induction / orientation stresses personal responsibility and the importance of maintaining "environmental awareness" in the employee's everyday duties. Each Contractor is required to provide this training to their employees/staff and records must be maintained to show training attendance and completion.

In addition to the EA Training provided to manual labour, Project Environmental Management Training is provided to Bechtel and Contractor field management staff responsible for overseeing day-to-day compliance with applicable regulatory requirements and this CECP. The Project Construction Management training is provided by the CEC or another designated ES&H Representative and provides more detailed information regarding environmental compliance requirements.

One to one sessions are provided to Contractor’s ESH Manager / Representative, where needed, to discuss preparation of their Environmental Compliance Plan, control of hazardous materials and wastes, water conservation techniques, re-use of materials and recycling. Contractors are also able to discuss measures for environmental improvements at the contractor progress meetings.

4.2 Environmental Compliance Reviews, Coordination and Communication

Environmental compliance will be discussed during weekly contract meetings. These meetings are conducted with site project personnel, including the CEC and SM or their delegates, and lead Contractor representatives. The Employer attends as required. During these meetings, Bechtel, Contractors and Employer, discuss and resolve issues related to maintaining and ensuring environmental compliance during the planning and execution of current and future





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construction activities. These meetings will be held more frequently if construction activities warrant.

4.3 Environmental Compliance Inspection and Documentation

The CEC (or designee1) shall conduct weekly field inspections of construction activities at the Project site and the port facilities, as well as the construction Village conditions, respectively, to confirm that site remains in compliance with all applicable permit conditions, contractual obligations, and laws and regulations.

Periodic Environmental Inspection Reports (EIR) for the construction camp and construction sites at the smelter and port are used to document the results of each inspection and describe any issues requiring corrective actions. EIRs are held on file for viewing by the Employer (avoids duplication and increased use of paper), EIRs shall be scanned and stored electronically. Corrective actions are agreed during the inspection and this information is presented at the weekly contractor meetings. Outstanding actions are raised in these meetings and tracked.

The CEC maintains records of environmental corrective action remedies that have been actioned and those that are still to be completed using the EIRs and minutes of Contractor performance review meetings. These records also document positive evidence of compliance with requirements (see Appendix H).

The CEC is responsible for working with the ES&H Manager, Site Manager, General Superintendents, Contract Supervisors and the Contract Administrators to complete corrective actions in a timely manner. Those items not resolved appropriately will be documented in action reports and held over for discussion and resolution at either the Project’s weekly status meeting, or contractor weekly progress meetings as well as scheduled EHS Committee Meetings.

1 Normally the ESH Supervisor or Coordinator associated with that area of the site or particular Contractor





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5 ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES

5.1 Noise

Contractors performing noise generating activities (e.g., earth moving, use of power tools and heavy equipment) shall review, understand, and implement noise control strategies in compliance with the Noise Abatement Plan (Appendix B) requirements.

5.2 Air Quality (Fugitive and Vehicular Emissions)

To control and minimise emissions generated during construction, Bechtel and Contractors will comply with the conditions outlined in the Project Fugitive Dust Control Plan (Appendix C) and equipment / vehicle maintenance and operation requirements. Air emissions associated with light and heavy vehicle operation and generators will also be reported in accordance with Appendix C.

5.3 Erosion and Sedimentation Control

Erosion and sediment control measures are described in the Construction Erosion and Sedimentation Control & Storm Water Management Plan contained in Appendix D.

5.4 Construction Storm Water Management

Specific storm water management measures to be implemented during construction are described in the Erosion and Sedimentation Control & Storm water Management Plan contained in Appendix D. In addition, Appendix D describes BMPs for controlling non-storm water discharge, including ground and surface water.

5.5 Protection of Sensitive Resources

The Project site is located in an arid desert region that has sparse vegetation. Erosion and sediment control and storm water management measurements will be implemented as described in Appendix D to prevent and/or minimise any impacts to the surrounding region.

5.6 Unanticipated Discoveries

Unexpected discoveries have been found on the Ras Az Zawr project site. Special awareness and safety procedure is required which is provided in following sections. Extensive traversing of the project area has not found or identified any sites of cultural or archaeological significance. The project area is located around significant topographical features or landmarks such as hilltops, rock outcrops, natural amphitheatres, waterways or areas with specific vistas that may have functioned as lookouts or meeting places.

A headland, directly to the east of the proposed project site at Ras Az Zawr, is subject to ongoing coastal processes as demonstrated by the collapse of the rock face on all sides. Whilst the exposed rock has been subject to graffiti, there was no evidence of any cultural or other activities. This site will be outside the proposed project boundary and will not be directly affected by construction or operational activities.





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5.6.1 Archaeological and Cultural Resources

The Project is not expected to encounter archaeological artefacts and cultural resources in the project area during construction, since none have been identified at the site to date. However, should archaeological or cultural resources be encountered during construction activities, the procedure outlined in Section 5.6.3 must be followed. In addition, the Employer, Bechtel and its Contractors must ensure compliance with all applicable laws and regulations should such an event occur.

5.6.2 Existing Contamination

Contamination from oil spills of the first Gulf War have been recorded along the western shores of the Arabian Gulf, and locally at the Port site, now largely incorporated within regularly worked beach sands.

Apart from minor concentrations in iron (Fe) (0.11 mg/L and 0.21 mg/L) and zinc (Zn), no significant indication of metals contamination was recorded within the water column at Ras Az Zawr.

Should Contractors encounter materials with known or suspected contamination, due to colour, odour, or other characteristics, work in the area adjacent to the materials should stop immediately and the unanticipated discovery procedure identified below (Section 5.6.3) should be followed.

5.6.3 Notification / Stop Work Process for Unanticipated Discoveries

If an unknown material is encountered during construction activity (e.g., excavation, clearing), the activity will be halted. The area should be evacuated completely and restricted. The site ES&H manager and CEC will be notified who will inform following persons:

Ma’aden’s Company Safety and Security Manager

Aluminium Project EHS Director

Documentation of the cause of the work stoppage will take place; and notification of Bechtel site management and the Employer will occur on determining that there is just cause. Work in that specific area may only resume after specific authorization from the SM or ES&H Manager.

If potentially contaminated material (e.g., unusual odour, coloration) were to be encountered, work is to immediately stop in the vicinity of the contamination and the ES&H Manager and CEC notified by the Supervisor. In the event that the ES&H Manager or CEC is unavailable, the SM is to be notified. The same procedure which mentioned about for discovery of unknown material should be followed in this case. The contaminated area will be investigated by authorized people to determine the nature of the contamination and to assess if worker safety or environmental impacts will occur if excavation continues. Once the Supervisor notifies the ES&H Manager or the CEC, that person will notify the PM and the SM. The Employer will be responsible for characterizing the potentially contaminated material and to remove the substance, if hazardous to the workers or the environment according to Saudi requirements. Once the area has been cleaned up, The Employer will notify the SM in writing and the SM will





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authorize work to re-commence. Work in that specific area may only resume after specific authorization from the SM or ES&H Manager.

5.7 Hazardous Waste and Materials Management

Contractors shall manage all hazardous substances and petroleum products, hereafter termed hazardous materials, in accordance with the requirements specified in the Hazardous Material Management and Spill Prevention and Response Plan (Appendix E) in order to minimise the potential for threats to human health and the environment.

5.8 Spill Prevention and Response

Each Contractor shall submit a Spill Prevention and Response Plan to the ES&H Manager for approval (this forms part of the Environmental Compliance Plan submitted by all contractors). The Spill Prevention and Response Plan provided by the Contractor shall, at a minimum, fulfil the requirements set forth in the Spill Prevention and Response Plan presented as Appendix F.

5.9 Solid Waste Management

Contractors shall manage (e.g., handle, store, transport, dispose) hazardous and non-hazardous wastes they generate during construction in accordance with the requirements specified in the Waste Management Procedure (Appendix G), Saudi laws and regulations applicable to waste management. Main Solid Waste Contractor shall supply waste receptacles that are properly labelled or colour-coded to maintain their work area in a clean and tidy state. No wastes shall be disposed, through burning, on site without specific approval from the ES&H department2. A detailed solid waste management plan is provided as Appendix G.

5.10 Water Conservation

To promote water conservation, New Employee Orientation must include education regarding water conservation. Other training includes Toolbox Talks on water conservation and hydration during the summer months, reporting of leaks, re-use of treated sewage effluents or construction water for wetting down and other uses such as irrigation. Posters and signs will be placed in the Village and elsewhere onsite to promote water conservation measures.

Water use reduction measures will be implemented onsite where practical and include dual flush toilets (if available), urinals with push flush / low water volume usage, and front loading washing machines in the Village laundry. On the construction site, formwork ‘nappies’ will be encouraged to retain curing water for complex shaped structures and Hessian with plastic sheets as a top layer will be encouraged in other applications to reduce evaporation losses.

Bechtel will also identify further opportunities for reusing and recycling water at the site wherever possible. These include the replacement of potable water used for dust suppression and re-using hydrostatic test waters for several applications.

2 Controlled burning of wood is required as part of Cathode Sealing Operations i.e. initial conditioning of ladles.





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5.11 Wildlife and Plant Protection

The south-eastern edge of the Ras Az Zawr peninsula forms the northern marine boundary of the Jubail Marine Wildlife Sanctuary (JMWS), which covers an area of more than 2,000 km2, as shown in Figure 5-1 below, and includes two shallow bays, the stretch of coastline between Abu Ali and Ras Az Zawr and five coral islands. In particular, these coral reef islands are the most important in the Arabian Gulf as they contain the highest species diversity with over 50 identified species

Given the proximity of the JMWS to the project site, several diverse habitats for wildlife exist in the Ras Az Zawr area. However, only five species of turtles are listed as being Threatened Animals by the International Union for Conservation of Nature (IUCN) Red List, 2000.

The main plant communities within the JMWS and Ras Az Zawr Peninsula are associated with fore dunes, sabkhas (hypersaline, intermediate, coastal) and calcareous dunes (mid-slope, ridgeline). None of these communities contain threatened or endangered species as listed in the IUCN Red List, 2006.

Bechtel shall impose a ban on all wildlife and plant harvesting at the project sites for all project personnel, contractors and visitors, and impose substantial penalties on violators. Bechtel will also ensure that personnel and contractors are contractually bound to a hunting, trespassing and collecting ban.





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Figure 5-1 Jubail Marine Wildlife Sanctuary (JMWS)

5.12 GHG Tracking

As part of the Bechtel GHG tracking program, Bechtel and the Contractors will track and record their monthly use of the following metrics:

Electricity use – All electricity consumed for construction activities on site will be recorded and reported in kWh.

Fuel use – All fuel used for equipment, machinery, vehicles, generators, etc. will be reported including Diesel, LPG, Petrol/Gasoline, and any other fuels and reported in liters or gallons.

Waste generated and recycled – All waste streams will be tracked, recorded and reported in kg by total waste generated and recycled.

Water use – Total water use will be reported.

A detailed GHG Tracking Procedure is provided in Appendix I.





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6 EMERGENCY EVACUATION AND RESPONSE PLAN Bechtel is responsible for managing emergency situations in accordance with the Emergency Evacuation and Response Plan written for the Project. Spill response procedures are contained within Appendix E of this CECP.





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TABLES & APPENDICES





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Table 1 - Acronyms

ANSI American National Standards Institute

CAL Corrective Action Log

CAS Chemical Abstract Services

CEC Construction Environmental Coordinator

CECP Construction Environmental Control Plan

EA Environmental Awareness

EIA Environmental Impact Assessment

EIR Environmental Inspection Report

ES&H Environmental, Safety and Health

GHG Greenhouse Gases

HDPE High Density Polyethylene

ISO International Standardization Organization

IUCN International Union for Conservation of Nature

JHA Job Hazard Analysis

JMWS Jubail Marine Wildlife Sanctuary

MSDS Material Safety Data Sheet

NCWCD National Commission for Wildlife Conservation and Development

PEL Project Environmental Lead

PFE Project Field Engineer

PM Project Manager

PME Presidency of Meteorology and Environment

PPE Personal Protective Equipment

SIA Social Impact Assessment

SM Site Manager

STP Sewage Treatment Plant

TSE Treated Sewage Effluent





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Table 2 –Saudi Environmental Organisations, Laws and Regulations

The table below lists a number of Saudi Ministries that are responsible for various environmental regulation, laws and compliance on the project. While some organizations play a larger role than others in environmental management, all laws and regulations of each Ministry must be adhered to. They are:

Ministry Main Responsibility Responsibility in relation to

Project

Presidency of Meteorology and Environment (PME)

Environmental protection at national level

All environmental permits; proposing environmental laws and regulations; assessment and evaluation of pollution levels; planning and managing environmental risks and dealing with environmental emergencies

Royal Commission Regulations

Environmental Protection for Royal Commission Properties

Upon approval environmental permits, assessment and evaluation of pollution levels are under Royal Commission cover.

National Commission for Wildlife Conservation and Development (NCWCD)

Ecological balance, and bio-diversity; conservation of environmental and natural resources

Preservation of terrestrial and marine wildlife, with particular oversight on project impact on JMWS

Deputy Ministry for Mineral Resources

Implementing the provisions of the Mining Code and Regulations

Fee collection, provides licenses for water usage within concession

Ministry of Agriculture implement government economic plans and programs concerned with agriculture in the Kingdom

Maintaining pasture, forestry, animal resources and fisheries

Ministry of Water and Electricity

Water resources, sanitation systems and electric power

Ensuring proper disposal of sanitary waste and water conservation programs on site

Ministry of Petroleum and Mineral Resources

Administration, development and exploitation of the Kingdom's oil, gas and mineral resources

TBD





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Ministry of Municipal and Rural Affairs

City and town planning, and the development and maintenance of the basic infrastructure, such as roads, town cleaning and hygiene

Primarily responsible for waste management of project site and transportation of materials to site

Ministry of Health Responsible for the supervision of health care and hospitals in both the public and private sectors in Saudi Arabia

Management of medical waste generated from project

Ministry of Culture and Information

Provides information and news to the public

Environmental awareness Villageaigns; setting standards and specifications for environmental protection and pollution control.





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Appendix A Environmental Awareness Training





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1. ENVIRONMENTAL AWARENESS TRAINING PROGRAM Environmental awareness training is mandatory for all employees working at Ras Az Zawr and will be performed by ES&H staff as part of new-employee orientation for all manual and non-manual employees and contractor personnel. In addition to awareness training, supervisors, managers and personnel performing certain work activities may be required to receive more detailed training to emphasize the specific environmental hazards associated with specific work activities (e.g., grading, excavating, vehicle refuelling, dust control, paints/coatings application). Advanced training will include a presentation highlighting general and site-specific environmental issues, mitigation practices, management strategies, laws, and permit conditions. Refresher training will be held by the CEC annually to ensure that Ma’aden Project site personnel are informed of updated permit requirements and lessons learned.

Environmental training will stress the importance of maintaining "environmental awareness" in the employee's everyday duties. The regulatory basis for environmental requirements, communication and administrative procedures related to compliance, inspection and monitoring, and practical mitigation measures will be explained.

The training will cover environmentally sensitive areas within and adjacent to the project alignment. Other topics such as wildlife, air quality, water quality and erosion control, protection of cultural resources, noise and vibration control, solid waste handling/disposal, practices for hazardous substance/waste handling, and mitigation of community concerns will be addressed as appropriate to the group. The presentation will be followed by a question and answer period. Attendance at the training will be recorded on a training roster, maintained by the CEC.

Separate and focused training will occur for project groups or specialists, such as design, engineering, construction planners & schedulers, when appropriate and as deemed necessary by the CEC. In that way, broad participation and accountability for incorporating environmental controls will be extended throughout the organization.

Formal training sessions will be supplemented by informal “toolbox” sessions that will be conducted in the “field” to emphasize new requirements or reinforce previously presented information e.g. practical use of spill kits and spill prevention / control measures etc. The CEC & other ES&H personnel will give these talks, as appropriate for the particular work site and especially at the time of mobilization. When environmental personnel are on work sites, opportunities for mentoring construction personnel will be taken whenever possible.

The CEC will prepare topic guidelines for construction personnel to facilitate ongoing training and awareness. These guidelines may describe subjects such as spill prevention, protection of cultural resources, erosion control, and dust control. The CEC will prepare these guideline sheets for Construction as work proceeds, to help highlight environmental topics and problem-prevention based on field events and “lessons learned.” Guideline sheets and examples of “best practices” and “lessons learned” will be posted in field offices.

The CEC will prepare Environmental Compliance Plans/maps showing the locations of any protected / out of bounds areas including watercourses, wetlands, wildlife, floodplains, and





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sensitive receptors (noise, vibration) as identified in the Project Environmental Impact Assessment.

1.1 Environmental Awareness Training For New Hires

Environmental awareness training is part of the construction Ma’aden New Employee Orientation that all employees must complete prior to being allowed to work at Ras Az Zawr. Contractors are responsible for providing training to their employees and must keep records of completion and attendance. Those who successfully complete the new-hire orientation will be given a decal sticker to be placed on their hard hat. Individuals without a sticker will not be allowed to work on the project until it has been verified that they have completed the training. The training must be a multi-lingual, illustrated, and covers the following points:

Environmental expectations, laws and regulation governing environmental performance;

The Project’s environmental policy and process for maximizing environmental performance;

Project workers’ roles and responsibilities in protecting the environment and meeting environmental objectives;

Recognition and communication of potential environmental hazards (e.g., unanticipated discoveries, spills, erosion control, hazardous materials, dust control);

Water conservation awareness; Management of all waste types (hazardous and non-hazardous) including the need for waste

minimization, segregation, reuse, and recycling;

Management of hazardous materials, storage, labelling and disposal;

Refuelling and spill prevention and response requirements;

Project’s environmental organization and roles and responsibilities of key personnel.

1.2 Supervisor Environmental Training

In addition to new-hire training, all Field Superintendants and Area Managers including Contractors will require Supervisor Environmental Training to emphasize their responsibilities; CEC will determine who requires this type of training. This training will aid them in recognizing and responding to environmental incidents and ensuring they understand the requirements well enough to explain to their subordinates. Supervisor Environmental Training will emphasize:

Waste management requirements including hazardous and non-hazardous wastes; Management of excess cement and cement truck rinsing requirements; Refuelling and spill prevention and response requirements; Storm water, erosion and sediment control requirements and mitigation measures; Dust control requirements and mitigation measures; Noise Control; Unanticipated discovery requirements; and Emergency response and notification requirements.





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In addition to the topics discussed above, Safety training will include Job Hazard Analysis (JHA) Training, as specified in Core Process (CP) 105, STARRT and JHA Process. This training shall emphasize the importance of considering environmental issues as part of the JHA process.

1.3 Environmental Management Training

In addition, to the training specified above, the PEL or CEC will develop a management training program for Bechtel’s management team. The goal of the training is to:

Describe management’s responsibility for environmental performance;

Provide an overview of project’s environmental requirements (regulatory, permit, EIA, and/or contractual);

Describe project management tools (CECP, ECP); and

Provide an overview of project-specific requirements.

Environmental Management Training will be provided to management personnel, as required, throughout the duration of the project or upon request from the management team.

1.4 Job Specific Training

As required, or appropriate, job specific training will be provided to personnel that perform tasks that actually or potentially cause environmental impacts. This training covers the potential environmental impacts and the associated protection / mitigation measures (spill prevention), workers’ roles and responsibilities, and emergency response requirements (spill clean up and reporting). Potential candidates for job-specific training may include those personnel involved with the following activities:

Equipment maintenance and repair; Refuelling, fuel handling, and spill response; Installing / maintaining erosion and sediment controls; Painters; Earthworks (e.g., clearing, grading, trenching); and Maintaining hazardous and non-hazardous material and waste storage areas.

1.5 “Toolbox” Training

To reinforce the Project’s environmental requirements, informal ”toolbox” training sessions shall be given routinely emphasizing environmentally sensitive issues expected to be encountered during the day’s work activities, reinforcing requirements after noncompliance incidents and discussing any changes in Project’s environmental policies or procedures.

Typical topics for toolbox sessions include the topics discussed during the New-Hire Orientation or Job Specific Training Sessions. Toolbox topics for environmental issues are provided on the intranet for internal use and are also available for contractors.





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1.6 Environmental Awareness Training Outline

The following is a list of awareness training on Kitimat Modernization Project:

Craft: Environmental Introduction; Waste Management; By-product Management; Hazard Management; Spill Plan, prevention and control

On-boarding: Environmental Introduction; Waste Management; By-product Management; Hazard Management; Environmental Orientation; Spill Plan; Housekeeping

Supervisors: Waste Management; By-product Management; Environmental Leadership; Spill Management





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Appendix B Noise Abatement Plan





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1. INTRODUCTION Contractors shall implement mitigation measures to limit noise levels and control nuisance noise that could affect sensitive receptors during construction. The tolerance of construction noise is expected to vary by location, as a function of construction activity, proximity to sensitive receptors, and line-of-sight between construction and receptors. Mitigation measures shall be tailored for each new phase of construction to match location-specific conditions. Consideration shall be given not only to offsite receptor but also in the location and noise mitigation associated with the construction Village. Noise monitoring, personal protective equipment requirements and mitigation measures related to workers’ health and safety are prescribed in the Project S&H Execution Plan.

2. DEFINITIONS Definitions associated with construction noise/vibration include the following:

dB(A) – A unit for measuring the volume of normal sound pressure.

Decibel – A unit for measuring the volume of sound pressure perceived by the human ear.

Micropascal – A unit for measuring sound pressure.

Equivalent Continuous A Weighed Sound Level – A sound pressure level representing the same energy as that of a fluctuating noise considered over a period of time symbol Leq, T, Unit dB re. 20 micropascals.

Public Noise – Sounds generated from external sources and affecting the quality of life of people in their daily life.

3. NOISE LIMITS Below are World Bank guidelines on ambient noise which provide general environmental guidelines for the purposes of being utilized as industry sector guidelines.

Leq (1-hr), dB(A) Receptor

Day (0700 to 2200) Night (2200 to 0700)

Residential, Institution, Educational 55 45

Industrial, Commercial 70 70

Maximum Allowable Noise Level

L10 dB(A) Plant Activity – Max Noise Level dB(A) in one meter 50 m 100 m 200 m 400 m

Crane 104 62 56 50 44

Backhoe 106 64 58 52 46

Bulldozer 112 70 64 58 52

Compressor 100 58 52 46 49





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Concrete Pump 100 67 61 55 49

Dump Truck 113 71 65 59 53

Water Tanker 71 65 59 53

Compactor 110 68 62 56 50

Concrete Saw 76 70 64 58

Paver 113 71 65 59 53

Rock Breaker 76 70 64 58 Predicted Plant Item Noise Levels

Notes:

1. For tonal and impulse noises, the values above should be adjusted by 5 dB(A). For the combined tonal and impulse character, the adjustment shall be 7 dB(A)

2. Hours (final hours TBD): Workdays – daytime (A): After 7 a.m. up to 6 p.m. Workdays – evenings (B): After 6 p.m. up to 11 p.m. Holidays and nights (C): After 11 p.m. up to 7 a.m.

4. Road traffic includes motorized traffic in cities, on motorways, local ways, etc.

4. NOISE MONITORING During construction, Bechtel will monitor and record noise levels as needed whilst construction activities are taking place. If there are no identified sensitive receptors (people or wildlife) monitoring will simply be by inspection without any devices or data. Should sensitive receptors exist, monitoring will include, but not be limited to, night time noise monitoring and during Friday’s or Public Holidays. Data and observations on those activities will be recorded for future reference if complaints occur.

The necessity, location and frequency of noise monitoring will be determined once the site layout has been finalized.

5. NOISE MITIGATION The first steps in managing nuisance noise shall be the identification of potential sources of noise and vibration. Works Contractors are required to consider risks of exposure to noise and vibration associated with their work activities, and where such activities present a risk of nuisance noise to residents of the Ras Az Zawr construction camp and/or other sensitive receptors, to consider risks and mitigation strategies in their Job Hazard Analyses prior to undertaking work.

The risk assessment component of the JHA shall:

Identify the major factors that will affect noise and vibration impacts at sensitive locations;





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Determine the frequency of the noise occurring and the significance of their consequences;

Develop appropriate management strategies and assign clear accountability for implementation.

The CEC is responsible for ensuring that all complaints are tracked, monitored and reported to the Employer. A discussion of any complaints and responses / mitigation measures followed will be incorporated into the EHS Committee Meetings.

To the extent feasible, specific mitigation measures and construction methods will be adjusted to address concerns; however, noise levels may approach, or exceed Project noise limits during certain construction activities.

The following mitigation measures may be implemented as appropriate:

Selecting equipment and methods that limit the generation of unnecessary noise (Unnecessary noise is defined as noise above 85 dB(A). Personal hearing protection is required for employees exposed to noise levels above 85 dB(A).

Accounting for noise sensitive receptors during the design phase, particularly in siting lay-down areas, parking areas, and stockpile areas and siting areas away from sensitive receptors if possible.

All the noise equipment must have ID and be labelled.

Scheduling of work to minimise duration and limit night-time and early morning impacts.

Conducting toolbox talks and site-specific personnel training emphasizing potential impacts to adjacent sensitive receptors as well as proper equipment maintenance to minimise excessive noise.

Use of temporary noise barriers and enclosures to limit impacts to noise sensitive receptors.

Ensuring proper silencers / mufflers are installed, equipment maintenance is being performed, and ensuring modifications are not performed that will increase the noise emitted.

Ensuring vehicles are equipped with horns or other signalling devises that are sufficiently loud to serve as a danger warning device but do not produce unnecessarily loud or harsh noise.

Routing of truck traffic and heavy equipment to avoid impacts to sensitive receptors.

Obeying speed limits.

Provide workers and visitors with hearing protection in high noise areas where noise levels cannot be reduced.

Substitution of the noise or vibration source, which can include:

o Implementing different (quieter) work techniques or changing the plant to one that is quieter;

o Isolation or segregation of the noise or vibration source, which can include:





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o Maximizing distances between noise sources and receptors or directing most of the noise in other directions by orienting the sources;

o Partially or totally enclosing noisy machinery with soundproofing or barriers.

o Using vibration suppression to isolate vibrating machine parts and pipes.

o Using engineering controls such as baffle plates, exhaust silencers, etc for noisy air emissions.

o Fitting sound absorbing materials to ceilings and walls of noisy rooms.

o Site noisy equipment behind barriers or mounds;

o Scheduling the intermittent use of noisy equipment for least sensitive times if possible;

o Running education and training for staff and contractors on the effects of noise and on the procedures in place to reduce noise





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Appendix C Fugitive Dust Control Plan





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1. INTRODUCTION The purpose of this plan is to minimise the quantities of dust generated during construction.

2. RISK ASSESSMENT The first steps in managing fugitive dust shall be the identification of potential sources of dust and particulate emissions. Works Contractors are required to identify potential sources associated with their work activities and to consider risks and mitigation strategies in their Job Hazard Analyses prior to undertaking work.

The risk assessment component of the JHA shall:

Identify the major factors & sources contributing to dust and particulate generation at sensitive locations;

Determine the frequency of the noise occurring and the significance of their consequences;

Develop appropriate dust and particulate management strategies and assign clear accountability for implementation.

3. SOURCES Listed below are the specific activities that have the potential to generate fugitive dust during the course of construction.

Vehicular / equipment traffic on site and on unpaved roads.

Performance of earthwork (e.g., clearing, grading, excavating) as necessary for development of the site, constructing access roadways, laydown and parking areas and re-contouring area during reinstatement.

Construction of erosion / sediment control structures to include drainage swales and sediment traps / ponds.

Screening of soil for padding and possible crushing / washing of rock to make gravel.

Handling, loading and transport of loose materials.

Uncovered storage and stockpiles of bulk materials.

Wind erosion of soils.

4. CONTROL MEASURES A number of fugitive dust control measures may be employed to minimise dust generation and avoid off-site impacts. The most appropriate will depend on site-specific circumstances and available resources. The primary method of dust control will be through prevention (e.g., covering loads, minimizing material handling especially during strong winds, limiting traffic on unsealed areas, reducing traffic speeds) and application of water suppression measures. Environmental inspections and visual monitoring will be conducted to ensure dust control measures are implemented. Table C-1 summarizes the other potential sources of fugitive dust and possible mitigation measures.





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It is important to note that use of water for dust suppression should be controlled such that the amount applied to road and trucks does not exceed the amounts required, and consequently cause excessive runoff and erosion.

Table C-1: Potential Dust Sources and Potential Mitigation Measures

SOURCE OF DUST/PARTICLES

MITIGATION MEASURES

Haul Routes (Paved) and Site Access Points

Where possible, roads will be paved to reduce dust generation. Street sweepers, spray trucks with brushes and / or personnel with hand equipment (e.g., shovels, bristle brooms) will be used to maintain roadways and access points free of material that may accumulate from construction traffic and generate dust.

Speed limits will be strictly enforced at 30 kph or lower onsite.

Wind Erosion Construction activities that generate significant amounts of fugitive dust may be postponed if sustained windy conditions occur. Water or Treated Sewage Effluent (TSE) will be applied at regular intervals to control dust. During windy conditions, water will be applied more frequently.

Parking/Lay-Down Areas Parking areas may be paved or covered with compacted gravel.

Water or TSE will be routinely applied on areas that are not capped with gravel or paved to control dust.

Speed limits will be strictly enforced at 30 kph or lower onsite.

If practical, site parking/lay-down areas will be placed in optimal locations with protection from wind, or down-wind of sensitive receptors (e.g., plant buildings).

Unpaved Roads and Disturbed Areas

Water or TSE will be applied to road surfaces, as required, during active operation. Vehicles will adhere to a maximum 30 km/h speed limit onsite. High volume traffic areas will be paved or gravelled to mitigate the generation of fugitive dust.

Site Access Points Rock or asphalt cover will be placed to knock loose dirt/debris from vehicles tires and undercarriage at points where site access intersects public roads. If this method is insufficient, vehicles may be washed prior to the vehicle leaving the site. Wash water will be properly managed to control sediment resulting from wash activities.

Haul Trucks All trucks transporting soil, loose aggregate, and/or other dust generating materials to and from the site shall have their loads covered to minimise dust generation.

Haul truck traffic will be limited to authorized routes and designated entrance and exit points to the site.

Asphalt or gravel cover will be placed on regularly travelled areas. Roadways will be regularly maintained (e.g., swept, cleaned). If gravel is used, roadways will be maintained through re-grading and re-application of gravel as needed.





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SOURCE OF DUST/PARTICLES

MITIGATION MEASURES

Soil Handling and Material Storage Piles

The drop height will be minimised when loading or unloading material.

The frequency of material/soil handling will be reduced to minimise the frequency of stockpile disturbance. Material will be watered prior to and during disturbing activities such as loading of trucks to minimise the generation of dust.

Soil stockpile height will be kept as low as possible to reduce wind effects.

Piles may be compacted or covered with tarps or dust suppressants (e.g. magnesium chloride or suitable polymers) if stockpiles are to be left for over 28 days after pile is formed; if windy conditions result in visible dust impacts offsite, water will be routinely applied to prevent dust.

Drilling, cutting, ripping Water or TSE shall be used where appropriate, to minimise dust generation.

Screening / Crushing Plants

Water or TSE may be used on screening / crushing plants to control the generation and spread of dust, if this type of operation is carried out at the construction site.

External dust or seeds All construction vehicles should be washed down to remove any contaminated sand or seeds of weed species prior to coming onto the construction site.

Truck Fuel Combustion Use of modern with adequate pollution devices.

Use of appropriate fuels, including low sulphur diesel and unleaded petrol in accordance with manufacturer’s instructions.

Minimize the unnecessary idling and operation of earthwork and construction machinery, including efficiency of trip times and reduction of double handling through appropriate placement of stockpiles, haul roads, works depot and work areas.

Paint Odour and Emissions Ensure paint and solvents use is carried out in an appropriate manner to minimize volatile emissions.

5. MONITORING Subjective monitoring will be undertaken from the start of construction activities onsite in order to provide an overview of dust levels across the site. This subjective monitoring is undertaken by all contractors onsite who may give rise to dust emissions during their normal work activities.

Quantitative dust monitoring, if required, is expected to start once a suitable dust monitor has been purchased.

Equipment with excessive visual emissions should be given defect notices and take put of service until repaired and approved for redeployment by CEC and Site Supervisor. Weekly visual checks shall be performed by CEC or his representative regarding to smoky emissions from vehicles and vessels.





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All complaints from the public regarding fugitive dust or mud and dirt carryover on the public road will be documented by the Bechtel Construction Environmental Coordinator and shall be reported to SM. Contractors shall be responsible for immediately responding to complaint to assure close out

6. ADDITIONAL REQUIREMENTS Contractors are required to submit an on-site material stockpiling and storage procedure that ensures the minimization of dust resulting from material handling operations. Bechtel shall approve the procedure prior to the Contractor performing any material handling operations at the site. The procedure shall establish the locations where materials will be stockpiled and stored to ensure that they are constructed away from sensitive receptors (e.g., Arabian Gulf) and drainage pathways. Specific measures for erosion and sediment control are covered in the next Appendix.

In addition, disturbed areas will be rehabilitated and / or covered as soon as possible. If necessary, construction activities that generate excessive amounts of dust will be suspended.





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Appendix D Construction Erosion and Sediment Control and

Stormwater Management Plan





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1. INTRODUCTION Erosion and sediment control and storm water management measures are provided to minimise the impact of sediment reaching the drainage system during construction activities and to implement the mitigation measures identified in the Ras Az Zawr Aluminium Smelter EIA.

During the northern hemisphere winter, central Asia undergoes a period of cooling, and high pressure systems develop, resulting in cool air flows over the Arabian Gulf region. During this time, the temperature can descend to almost 0°C and there are strong winds with occasional rain and thunderstorms. However, the long-term average annual rainfall in the area is approximately 80 mm.

2. GENERAL EROSION AND SEDIMENT CONTROL REQUIREMENTS The Project is being built on a coastal plain which rises gradually inland towards the Summan plateau. There is no permanent or semi permanent surface water within the Ras Az Zawr study area other than in the tidal areas or excavation works where the groundwater is exposed. Instead, storm water can collect within Sabkhas from localized rainfall. This water can pond for several days or weeks, subject to the amount of rainfall, duration and time of year. The dominant evaporation rate quickly reduces the duration of ponding, leaving saturated soil conditions until the surface crusts re-establish.

The measures listed in this Field Instruction should be considered by Contractors on a case by case basis based on a risk assessment of work activities. On a general rule the extent of of disturbance on site and particularly for Sabkha fore-dunes shall be minimal.

Storm water management and erosion and sediment control are required in all project areas affected by construction and under the control of Bechtel Contractors.

The following sections describe general actions that may be utilised:

2.1 General Excavation and Stockpile Areas (Rough Grading & Surface Preparation)

Soil excavation and stockpiling create disturbed areas that are easily eroded during rainfall events. The following erosion and sediment control strategies should be planned for each excavation and stockpiling activity.

Prior to starting construction activity:

Divert runoff from upslope areas around and away from the disturbed area. Install a temporary sediment basin at the low point of the disturbed area using hay bales of

check dams, as appropriate. Construct swales to direct runoff towards the sediment basin. Install silt fences, or bale barriers with silt fences, around the downstream perimeter of the

disturbed area. During and after construction activities:





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Intercept runoff from the disturbed area and direct it towards a temporary sediment basin or sediment trap using grading, swales, ditches or bale barriers.

Grade and stabilise the surface of the disturbed areas as soon as possible. Avoid placing any stockpile material in a channel or flow path.

2.2 Structural Excavation (Sub-Surface) Structural excavation for foundations and utilities may encounter groundwater or create depressions which fill with surface water requiring evacuation. Water removed from excavations must be treated prior to disposal.

Water removed from excavations may be channelled to storm water sedimentation ponds or treated locally to remove sediment and suspended materials.

2.3 Exposed Slopes Structural excavation for foundations and utilities may encounter groundwater or create depressions which fill with surface water requiring evacuation. Water removed from excavations must be treated prior to disposal.

Intercept runoff from areas upstream of the slope and divert around the slope or to slope drains.

Construct slope drains, either open channels lined with geotextile and riprap, or pipes. Where required, place check dams across open channel drains to dissipate energy and stabilise the lining.

Place riprap aprons at the outlet of the slope drain to dissipate the flow energy. Install a collector drain at the base of the slope to convey flow from the slope drains towards

the nearest watercourse or storm water drain. Stabilise the surface of the slope using appropriate slope protection measures. Monitor direct runoff from the face of the slope during rainfall events. Install silt fences at the

base of the slope, if required. Depending on drainage patterns, install bale barriers in conjunction with silt fences to direct runoff from the slope surface towards a sediment trap. Keep sediment laden runoff from the slope face separate from the runoff from areas upstream of the slope.

Inspect the slopes after heavy rain, and repair any gullies that have been eroded into the slope. Intercept and divert upslope runoff to avoid concentrating runoff flow down the slope.

2.4 Roads and Hardstand Areas Roads and hardstand areas may be an ongoing source of sediment in runoff, and hence drainage and sediment control measures need to be implemented. Some general guidelines are provided here, and each area needs to be assessed on a case-by-case basis, and monitored as to the effectiveness of measures implemented. Sediment control actions for road and hardstand areas include:





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Engineer roads to drain by out-sloping and use of rolling dips. Install swales or drainage ditches along roads and hardstand areas, to minimise uncontrolled

runoff flowing over exposed slopes and embankments. Convey runoff collected from road or hardstand areas down slopes in riprap lined channels

or pipes, to avoid eroding the slope Install sediment traps at regular intervals inside drainage ditches, and always before

discharge into natural streams. Ensure road and service crossings of coastal Sabkha have adequate capacity for culverts

and drainage.

2.5 Culverts and Ditches Roads and hardstand areas may be an ongoing source of sediment in runoff, and hence drainage and sediment control measures need to be implemented. Some general guidelines are provided here, and each area needs to be assessed on a case-by-case basis, and monitored as to the effectiveness of measures implemented. Sediment control actions for road and hardstand areas include:

Install riprap aprons at the outlets of culverts and ditches to dissipate the flow energy and prevent erosion.

Line ditches with geo-textile or riprap to prevent erosion, where required. Where ditches, gulleys or streams flow adjacent to disturbed areas (excavation or

stockpiles), then place silt fences to intercept sediment laden flow. Do not place any excavated material inside or immediately adjacent to ditches, gulleys or

streams. Allow at least a 2 m-wide buffer between any excavated material and a silt fence placed alongside of the ditch or stream.

Monitor ditches, gulleys and streams for erosion and accumulation of sediment. Place erosion protection (such as lining or check dams) where significant erosion is observed. Remove any accumulated sediment, and identify and address the source of this sediment.

Where ditches convey sediment laden flow, install sediment traps or sediment basins at convenient locations, where these facilities can be maintained.

Install check dams on ditches steeper than 5% to dissipate flow energy and limit channel erosion.

3.0 EROSION CONTROL BEST MANAGEMENT PRACTICES The plan is designed to prevent on site sediments, carried by storm water runoff, from entering the Arabian Gulf. Erosion control consists of measures to prevent wind or water erosion of soil and may involve installing & maintaining physical barriers on the soil surface (such as vegetation or rock) and/or the use of temporary structures such as silt fences, hay bales and/or bio-swales. In all cases the intent is to interrupt surface flow to reduce velocity, allow settlement of suspended materials and control surface flow to prevent unmanaged losses to sensitive receptors.





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The following sections describe Best Management Practices that may be employed by Contractors on Ras Az Zawr Project:

3.1 Temporary Vegetation Temporary vegetation is an effective way for erosion and sedimentation control for to an area affected by construction activities. Where required, Vegetation shall be completed by an experienced contractor. One effective method of temporary vegetation is hydroseeding which can be used on the Ras az Zawr project.

The surfaces of steep exposed slopes require protection against erosion by rain falling directly on the face of the slope. Use of temporary and permanent vegetation (see below) is the preferred method of slope protection. However, if it is not possible to establish temporary vegetation (as a result of a non-growing land/climate or slope conditions) then the slope must be protected with artificial or mechanical measures such as geotextile, jute mesh, gravel, riprap, turf, or mulch. The selection of the appropriate slope protection methods must be adapted to site and seasonal conditions.

Vegetation stabilisation shall occur as soon as possible after disturbance, but in no case more than 14 days after the construction activity has ceased. An exception to this requirement is for when construction activity will resume on that portion of the site within 21 days.

3.2 Runoff Control Works Contractors shall manage surface runoff from storm water. All construction areas should be graded to assure appropriate drainage and areas of concentrated flow armoured against erosion by vegetation, rock, or other means, including:

Check dams (constructed of rock, bales, sandbags, or other methods) may be necessary in channels to dissipate the energy of flowing water and secondarily trap sediment.

Crown ditches may be required at the tops of slopes to divert water from the slope face.

Roads on slopes will require some type of letdown structures to properly drain, and this water should be controlled to the bottom of the slope.

Almost all steep slopes with terraces or water bars will require a collection system in some places to concentrate the flow and direct it through a designed system to a lower elevation.

Prior to performing any earthwork the work area should be carefully examined and the routes selected and prepared where storm runoff can flow.

Further examples of runoff control measures include the following:

3.3 Grading Surfaces of disturbed areas shall be graded and swales constructed to confine runoff and to prevent it from entering nearby streams or undisturbed areas. Where sediment basins or





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sediment traps are installed, grading and swales shall be used to direct runoff towards the inlet of the basins or traps.

In addition, final grading of disturbed areas shall be conducted along the contours of the site rather than up and down the slope, where possible. This will slow the velocity of runoff, encourage infiltration of runoff, and reduce the formation of eroded gullies. Grading in this manner also helps establishment of vegetation after seeding has taken place.

3.4 Drainage Ditches Ditches shall be used to direct runoff towards the inlet to the sediment basins in a controlled manner. All ditches shall be lined, if necessary, to prevent erosion. The temporary ditches the project site should be designed for the peak discharge according to the design criteria provided in the “Storm Water Drainage Philosophy and Hydrological/Hydraulic Design Criteria”, Doc No. 25457-0000-3DR-K04-0001.

3.5 Check Dams For ditches with channel slopes greater than 5%, riprap or similar check dams shall be placed in the ditch to slow the velocity and dissipate the energy of the flow. Check dams shall have a low spot (V-shaped notch), to serve as an outlet for the water; it may be necessary to armour the area of outflow to prevent scouring. The check dams shall be placed at intervals such that the elevation of the top of the downstream check dam shall be equal to the elevation of the bottom of the outlet of the next check dam upstream. The minimum height of the check dam shall be 0.3 m with 3 horizontal to 1 vertical side slopes on both the upstream and downstream slopes. Typical details for a check dam shall be included in contract exhibits for Works Contractor use.

3.6 Slope Drains Temporary slope drains are pipes or lined channels that transport runoff down cut or fill slopes in a controlled manner to avoid erosion and gully formation on the slope. Slope drains described herein are temporary measures that shall be utilised until permanent drainage structures are installed. Generally, vegetation growing on the slope is not sufficient to allow removal of slope drains. A more permanent system for managing the runoff from areas above the slope is required.

For long cross-slope lengths, multiple slope drains are required, installed at regular intervals. Slope drains are installed in conjunction with berms, swales and ditches on the top of the slope to guide runoff towards the inlet of the drain. Typical details for slope drains shall be included in contract exhibits for Works Contractor use.

4.0 SEDIMENT CONTROL Sediment control is the last line of defence to protect water quality. Some areas with proper erosion control and runoff control may not need sediment control measures depending upon the





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slope, runoff pattern and soil type. The following sediment control measures will be used on the Kitimat project:

4.1 Silt Fences Perimeter silt fences shall be installed around the downstream perimeter of any areas where excavation or stockpiling is occurring. Silt fences shall be installed in such a way that any potential erosion is captured by the barrier. Perimeter silt fencing shall only be removed once the area it is controlling is permanently stabilized or another control measure has been provided for in the area in question.

Silt fencing shall be placed such that, where possible, it is parallel to contours preventing the ponding of water along the fence. The fence is to be constructed of 600 mm to 750 mm high permeable geo-fabric with adequate tensile properties, tied to steel bars (25 mm dia.) or wooden posts (50mm x 50mm) at 1,500 mm intervals. The bars should be driven/drilled into soil/gravel/rock as necessary to support the fence. The top of steel bars is to be bent over by 180 degrees or protected by re-bar caps. In some locations, the silt fencing may be attached to chain link fences.

Typical details for silt fences shall be included in contract exhibits for Works Contractor use. Silt fences shall be inspected regularly and built up sediment removed from the fences.

4.2 Straws / Hay Bales Straw/Hay bale barriers shall be used in conjunction with silt fences in areas where silt fences alone provide insufficient sediment control, to direct runoff as required, and to form sediment traps. In certain cases, such as hard or frozen ground bales may be used in place of silt fence. The bales shall be constructed parallel to the silt fence and downslope of the silt fence so that they provide support for silt fence. To the extent possible, site flows will be directed towards any bale barriers as sheet flows and not concentrated ditch flows. Only tightly packed bales with strong wire or twine ties should be used.

Bales shall be periodically inspected. Bales that have deteriorated or breached shall be replaced. Discarded bales can be broken open and spread anywhere mulch is needed provided it does not present a housekeeping risk and the baling wire/twine should be properly disposed of. Sediment build-up behind bales shall be removed regularly.

Typical details for straw/hay bale installation shall be included in contract exhibits for Works Contractor use.

4.3 Sediment Basins A series of two ponds, a first flush and a retention / sedimentation pond will be utilized during construction and operation to intercept sediment laden runoff from the site and prevent sediments from entering adjacent waters during storm water conditions. Wadis adjacent to the site are only filled with water during storm water conditions. The site will be graded to direct water to the sedimentation pond. The Project proposes to re-use the water from the ponds for irrigation.





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The ponds will be designed to handle a maximum of a 24 hour, 10 yr storm, which represents 53 mm of rainfall. Additionally, the sedimentation / retention pond will be cleaned approximately every 4 months, if needed, or more often if conditions warrant more frequent cleaning. Water will either be reused for irrigation (preferred option) or discharged where volumes exceed practical usage onsite.

Table D-1 lists the applicable standards for treated wastewater for irrigation or groundwetting purposes.

4.4 Sediment Traps Sediment traps are smaller versions of sediment basins, used to trap coarse sediment from areas of small scale construction activity and generally without a concrete outlet structure. Sediment traps should always be used in conjunction with other erosion and sediment control measures and may require frequent maintenance to remove accumulated sediment.

Sediment traps can be constructed from riprap check dams, with the upstream slope of the dam lined with fine gravel and/or geotextile material to reduce the permeability of the dam and form an upstream pool for sediment settling. Alternatively, sediment traps can be constructed from gabions with geotextile lining, bale barriers, bales overlain by gravel and rock, or sand bags.

It should be noted that sediment traps do not need to be completely impermeable. In fact, some filtration through the dam is desirable, as it will allow the trap to drain and collected sediment to dry out. However, the dam should be sufficiently impermeable so that a pond is formed behind the dam even during low runoff events.

Sediment traps should be inspected and cleaned regularly. Any damage to the trap should be repaired as soon as possible to avoid failure of the check dam forming the trap.

Sediment traps are placed at convenient locations where access for maintenance is available, but attempts should be made to place the trap as close to a disturbed area as possible. Sizing of sediment traps is based on the space available. Sediment trap performance should be monitored to ensure it is providing adequate sediment control. If significant sediment discharge from the trap is observed, then the size (surface area of pool) should be increased.

4.5 Flocculants Chemical flocculants may be used in runoff ditches and sediment basins to increase the rate of settling of suspended sediment. Several commercial products are available, including materials derived from shellfish shells that are not harmful to fish and wildlife; note that some chemicals used in water treatment plants, such as alum, should not generally be used where it may drain into natural waterways.

4.6 Permanent Vegetation When construction in a particular area is completed and final grading is established, the permanent vegetation shall be established. The grading, soil profile, and vegetation for these areas shall be in accordance with the site storm water management plan. Permanent





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vegetation species will be limited to indigenous species and fluoride resistant species to the extent practical.

Table D-1 lists the applicable standards for treated wastewater for irrigation or groundwetting purposes.

Table D-1

Wastewater Standards (maximum allowed limits mg/l unless otherwise stated)

Parameter Maximum concentration

Physical characteristics

Floating material Nil

TSS 10

pH (SU) 6.0–8.5

Oil and grease Absent

Chemical characteristics–organic

BOD5 10

Turbidity (NTU) 5

FOG Nil

Phenol 0.002

Turbidity (NTU) 1.0

Coliform (count/100ml) 2.2

Hydrogen ion (-) 6.0-8.4

Chemical characteristics

Al 5

As 0.1

Be 0.1

B 0.5

Ba 1

Cd 0.01

Cl2 0.2

Cr 0.1

Co 0.05

Cu 0.4





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CN 0.05

F 1

Fe 2

Pb 0.1

Ag 0.5

Li 0.07

Mn 0.2

Hg 0.001

Mo 0.01

Ni 0.2

Se 0.02

Va 0.1

Zn 2

NO3 10

Cl 100

SO4 600

NH3 5

Microbiological characteristics

TTCC (MPN/100 mL) 2.2

Living intestinal nematodes (no/litre) 1

BOD5 40

TSS 40

TDS 2000

TTCC (MPN/100 mL) 1000

Living intestinal nematodes (no/litre) 1

Phenol 0.002

Source: 1) Treated Wastewater and Reuse Bylaw No. 42, 2000, 2) Guidelines for water reuse manual, US Environmental Protection Agency, 1992 (EPA/625/R-92/004).

5. STORMWATER MANAGEMENT





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Storm water management measures will be incorporated at the site to collect the runoff from the developed areas, to provide water quality treatment to the runoff, and to maintain pre-development peak discharges.

For construction purposes, the site will be graded and will utilize drainage channels to the first flush and retention ponds to prevent water from reaching the Arabian Gulf. Reuse and testing of the runoff will take place prior to reuse to ensure compliance with Saudi treated wastewater standards, as described in Section 4.2, above.

6. MAINTENANCE OF CONTROL MEASURES All erosion and sediment control measures identified in this plan will be maintained in effective operating condition. The CEC will be responsible for ensuring that any ineffective pollution control practices or structures identified during site inspections will be corrected before the next anticipated storm event, or as necessary to maintain the continued effectiveness of storm water control. If it is determined that maintenance or correction of practices before the next storm event is impracticable, then the corrective action will be scheduled and accomplished as soon as practicable.

6.1 Inspections

Inspection of the sedimentation control measures will be performed by the CEC or designated representative. This will verify and document that construction activities are conducted in compliance with the environmental requirements identified in permits, authorizations, environmental design reviews.

Storm water control measure inspections will be conducted at least once every seven (7) calendar days during regular inspections and within 24 hours of the end of a storm event of 13 mm or greater. Inspections conducted after rainfall events will be recorded in the designated Storm water Inspection Report. The CEC will continually evaluate work practices and direct immediate changes where there is a potential for environmental contamination.

When necessary, stop work orders will be issued if a contractor’s activities are: not in accordance with the applicable environmental requirements; adversely impacting the environment or will result in an adverse impact to the environment if the construction activity continues. If such construction activities are observed, the PFE or ES&H Manager will take appropriate action and immediately notify the respective Contract Supervisor and Contract Administrator. This construction activity will not be allowed to resume until corrective actions are implemented and proper approvals are obtained.

6.2 General Inspection Activities

Field inspection of construction activities for compliance with environmental permits and project environmental procedures.

Identification of action items needed to resolve environmental concerns observed during inspection.

Documentation of environmental inspection activities.





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Reporting on the status of construction environmental compliance.

6.3 Specific Inspection Activities

The following items are typical of the things that should be inspected daily, as appropriate during the construction cycle:

Condition of silt fences and other erosion controls. Condition of drainage ditches and waterways associated with construction. Proper storage and handling of on-site wastes (hazardous and non-hazardous wastes). Equipment used and maintenance logs.

6.4 Inspection Reports

Environmental field inspection activities will be documented on standard forms to provide consistency in reporting. The CEC is responsible for the logging, filing, and timely submittal of the environmental documentation to the Site Manager. A Storm Water Inspection Report is provided as Exhibit D-1 of this plan.

7. NON-STORM WATER DISCHARGES The following sources of non-storm water discharge are generally authorized:

Discharges from fire-fighting activities; Fire hydrant flushing; Wash waters used in vehicle washing (passed through an oil/water separator); Waters used to control dust; Building wash downs (no detergents); Non-contaminated pavement wash waters (i.e., spills/leaks of hazardous substances have

not occurred OR have been completely removed prior to washing taking place); Air conditioning condensate; or Foundation and footing drains which are not contaminated.

7.1 Control of Other Potential Sources of Storm Water Pollution

The following sections describe the control measures used during construction to prevent and/or minimise the potential contamination of storm water from sources of pollution onsite. Details regarding the maintenance and operation of the non-hazardous/hazardous waste storage areas can be found elsewhere in this CECP.

Construction Wastes

Construction waste storage during construction is temporary with waste stored primarily within a variety of containers (e.g. skips, waste bins etc.). Waste in closed containers will not readily come into contact with any storm water pooling onsite.

Sanitary Wastes

Initially, sewerage on the project will be stored and collected from septic tanks before being treated by a temporary, onsite sewage treatment plant. The solid waste will be transferred to an





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approved wastewater treatment facility, in Jubail. Leachfields shall not be considered due to the proximity of groundwater to the surface.

Hazardous Substance Storage Areas

The amount of hazardous substances present at the site will be minimised as described in Appendix F. Hazardous substance storage areas will be pre-approved by the PME or Royal Commission and need to meet HCIS requirements and will be designed and maintained to prevent and / or minimise any contact with storm water. Containers of hazardous substances must be kept closed at all times except when filling or dispensing product.

Vehicle Maintenance / Refuelling Areas

Minor vehicle maintenance and refuelling will be performed only in designated areas approved by the CEC. The designated areas will be located away from storm water drainage pathways and at least fifteen (15) meters from any water courses to minimise the potential for storm water pollution. The central refuelling area will be set on an impervious surface and the tanks shall have secondary containment. Other requirements are incorporated as needed, to ensure compliance with the permit obtained from the Saudi authorities.

Persons performing maintenance activities are required to ensure they have access to spill cleanup materials prior to beginning maintenance activities. In addition, all site personnel will be trained and be informed that in the event hazardous substances are spilled onto the ground, they are to immediately contact their Supervisor and respond in accordance with the approved Spill Response procedure. All contaminated fluids resulting from routine maintenance (e.g., engine oil, hydraulic fluids, antifreeze) will be collected in sealed, marked containers and transferred to the appropriate hazardous waste storage area for temporary storage prior to recycling or disposal off site at a licensed facility.

7.2 Hazardous Waste Storage Areas The Project will have designated a central hazardous waste storage area for the storage of containerized hazardous wastes generated during the course of construction activities. Workplace temporary hazardous waste storage areas will managed by each Contractor e.g. oily soils produced during clean up of drips, and wastes will be regularly transported to the central hazardous waste store. The project waste management contractor is responsible for transferring the waste from the working places to the main site project site and to the provisioned landfill off-site.

All containers of hazardous waste must be kept closed at all times except when filling. All wastes placed in the central hazardous waste store must be cleared through the CEC or the responsible Contractor designee.

As described in Appendices E and F, all approved hazardous waste storage areas will comply with applicable Saudi regulations.

8. GROUND WATER





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To address the potential impacts to groundwater, the following mitigation measures are recommended.

Drainage, surface runoff and groundwater management

In the event that groundwater is intercepted during excavation works, the water should be pumped from the excavation pit and discharged to settling basins to recharge to groundwater or evaporate;

Control potential pollutants at the point of infiltration.

Chemical management

Maintain spill response and cleanup equipment close to construction and storage areas; A manifest for all stored liquids, container volumes and supporting Material Safety Data

Sheets (MSDS) should be kept in an accessible and protected location in the bunded area and in a central location on site (such as the site office);

Store fuels, oils and chemicals in concrete lined and bunded areas, which are designed to contain 110% of the total volume the bunded area is designed to store;

Refuelling, vehicle washing and vehicle and plant maintenance areas to be located within designated bunded areas; and

Establish programs for routine checking of machinery to ensure there is no oil, fuel or other liquids leaking from earthworks equipment.

9. SURFACE WATER To address the potential impacts to surface water, the following mitigation measures are recommended.

Stockpile and dust management

Minimise the disturbance of land surfaces including defining site roads and access tracks and minimise the movement of vehicles and construction plant on unsealed areas;

Locate stockpiles on flat areas, away from drainage flow paths; Limit the height and slope of stockpiles to minimise erosion of unconsolidated materials

during rainfall events;

Chemical management

Chemical, fuel and waste storage areas shall be concrete lined and surrounded by bunding with capacity to retain 110% of its contents.





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Exhibit D-1 - STORMWATER CONSTRUCTION INSPECTION REPORT Ras Az Zawr Aluminium Project

INSPECTOR: _________________________ Date: _________ Time: __________ SIGNATURE:________________________________

General Site Observations Compliance Remarks w/ Responsible Party

Bechtel/Contractors Accept- able

Action Required

Site Boundaries

Site Entrance & Road

Overall Housekeeping

Erosion Controls Onsite

Perimeter

Laydown Areas

Drainages

Site Discharge

Sed. Basin

Work Areas-Misc.

Site Trash Containers

Hazardous Material Storage Areas

Waste Accumulation Area

Equipment Leaks

Equipment Maintenance

Fuelling Area

Dust Control

Other:

Additional Comments:

Reviewed by_________________________ Date __________________ Site Manager





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Appendix E Hazardous Waste and Material Management


Bechtel Confidential Contains Bechtel and its affiliated companies confidential and/or intellectual property which shall not be used, disclosed or reproduced in any

format by any non-Bechtel Party without Bechtel’s prior written permission. All rights reserved. Saudi Arabian Mining Company (Ma’aden) shall have an unconditional perpetual, royalty-free, freely sub-licensable and assignable license to use such intellectual property for all purposes in

connection with the Project.

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1. INTRODUCTION This Hazardous Waste and Material Management and Spill Prevention and Response Plan will be used during construction. The purposes of this plan are to:

Provide guidance for managing and use of hazardous substances and petroleum products to protect workers and the public, and to prevent releases to the environment;

Describe procedures for responding to incidents involving such releases; and

Demonstrate compliance with applicable contractual and regulatory requirements governing spill prevention, spill response, and notification.

Each Contractor will have one person designated per work area and shift who will be responsible for coordinating spill prevention and response activities.

2. HAZARDOUS WASTE AND MATERIAL MANAGEMENT

2. 1 Classification of Hazardous Material Hazardous materials may broadly be defined as any substance or article (solid, liquid or gas) that poses a threat to human health and/or the environment. Typically, hazardous materials are toxic, corrosive, flammable, explosive or radioactive. Included are a wide variety of man-made (i.e., synthetic) and naturally occurring substances. When misused or mismanaged, they can adversely affect the environment and our health and safety.

Typical hazardous materials that may be used or generated onsite during the course of construction include, but are not limited to:

Gasoline/diesel fuel and oils (including hydraulic oils);

Oil filters;

Solvents and thinners;

Acid

Batteries;

Corrosive agents (e.g., battery acid);

Paints/coatings (toxic or flammable);

Resins and glues/adhesives;

Concentrated detergents, disinfectants and cleaners

Coolants in air conditioners, water coolers or refrigerators

Construction chemicals (where these contain toxic or flammable components);

Welding Fuel gases e.g. acetylene, L.P.G.;





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Filters from welding vacuums that may contain heavy metals (including hexavalent chromium)

Batteries (dry cell and car batteries) Light bulbs containing mercury (fluorescent) and ballasts

Coolants in air conditioners, water coolers, or refrigerators

Medical waste

Welding rods

Ramming paste

Wall insulation

Oil contaminated soil and used oil

Welding ignition sources;

Tires;

Radiation Devices (used exclusively by the NDT contractor) – NDT contractor will be required to comply with all the applicable requirements specified in the Saudi Ministerial Decision MD 149/97 (Regulations for the Control and Management of Radioactive Materials).

Any materials classified in terms of their MSDS

2.2 Hazardous Wastes and Hazardous and Non-Hazardous By-Products

Hazardous by-products may be generated by the use of hazardous materials during construction operations which require special treatment and handling prior to disposal. Typical hazardous wastes generated from construction activities include, but are not limited to:

Residual paints, coatings, adhesives

Spent solvents

Contaminated material or soil from spills of hazardous substances

Infectious wastes (bio hazard contaminated)

Works Contractors shall consider the potential for generating or encountering potentially hazardous materials during the course of their Works in advance of commencing construction and ensure that resources are available to manage hazardous materials in accordance with this Field Instruction in advance.

2.3 Material Approval

Within 60 days after contract award or, in any case, 2 weeks prior to bringing a hazardous material onsite, Contractors shall request in writing approval from Bechtel to use the material. The Contractors must complete and submit the ‘Ras Az Zawr Hazardous Material Evaluation Form’ included as Appendix E-1 for approval by the Bechtel ES&H Manager and the Construction Environmental Coordinator.





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The Bechtel ES&H Manager and the CEC shall review the works contractor’s submission and if acceptable for use on the Ras Az Zawr Project, shall return an electronic copy of the approved form to the works contractor ES&H representative for information and record.

Materials or chemicals that have not been agreed to using the system described above may not be brought or used onsite prior to approval.

All material acceptance forms must be accompanied by the correct manufacturers Material Safety Data Sheet as described in Section 2.5 below.

2.4 Banned Materials

The Ras Az Zawr Project has developed a list of banned materials which may not be brought to site under any circumstances. A full list of banned materials is available in the Project Specification for Banned Materials, Doc. No.25457-000-3PS-HCHH-0001.

2.5 Material Safety Data Sheet

A Material Safety Data Sheet is a technical bulletin that provides specific hazard information, safe handling information, and emergency procedures for a controlled product. Since MSDS contain detailed health and safety information specific to a controlled product, it should be used as a key source of information for developing training programs and safe work procedures.

Works Contractors shall:

Ensure copies of MSDSs for hazardous substances brought to site are available to all employees and contractors in hard copy form and maintained in a register.

Provide training in the location and use of MSDS sheets.

Ensure that when hazardous materials are required as part of the scope of work that the following information is discussed during pre-task briefings or STARRT meetings:

Locations of MSDS sheets;

Specific acute risks associated with hazardous materials to be used;

Locations of first aid facilities and the identity and contact details of the first aid provider

The safe use of hazardous materials;

Any restrictions or limitations associated with the hazardous material i.e. no smoking nearby;

The safe storage, handling & disposal of hazardous waste materials and containers.





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2.5 Workplace Hazardous Material Information Communication

Hazardous materials shall be labelled properly according to the accepted international standards such as (Ex. OSHA, WHMIS, etc), Contractors must ensure that this information is recorded and retained and is available for use by workers in the same way as MSDS information.

2.6 Inventory Control

Contractors shall be responsible for establishing and maintaining appropriate controls and protocols for dispensing and tracking the use of hazardous materials.

Contractors shall maintain a strict and recorded inventory and quantity tracking of all hazardous materials, which are used and stored on site. Works Contractors may use the form included in Appendix E-2.

Contractors may use an alternative format, provided it includes the information described in Appendix E-2 as a minimum.

Contractors shall be required to complete an inventory check against quantities of hazardous material on a monthly basis and retain copies of completed inventory records for inspection by CEC.

The inventory should contain the following minimum information for all materials:

Amount of material and units;

Supply date;

Storage location;

Common and/or trade name of material;

Manufacturer;

Stock item number;

Hazard details (e.g. hazardous/non-hazardous, risk and safety precautions etc.);

Date when register last updated (‘audit’ date).

2.7 Hazardous Material and Hazardous Waste Handling and Storage

Hazardous waste, including used oil, storage areas will be designed, constructed and maintained in accordance with guidelines set out by the Saudi PME and also those used by Bechtel on projects worldwide (see below).

Hazardous wastes and used oil will only be stored in areas designed to ensure non-compatible wastes are segregated and located in designated areas to optimize control. Hazardous waste storage areas must be approved by the PME prior to any wastes being generated. Storage areas will:





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Be sized appropriately to store anticipated containers with sufficient space between drums to permit the required visual inspection and allow access for emergency response;

Be signed to ensure proper segregation;

Be secured (e.g., barricaded or fenced and locked) to keep unauthorized personnel or animals out of the area;

Have barriers or other means to keep equipment, and vehicles from entering;

Be covered to keep out rainwater (when appropriate);

Be sized appropriately to store anticipated waste with sufficient space between drums to permit the required visual inspection;

Be signed to identify the hazard (e.g., Flammable - No Smoking or Open Flame within 15 meters, Hazardous Waste). Signs will be written in English, Arabic and/or any other appropriate languages;

Containers of material without a label shall be treated as hazardous waste until the material has been identified and proven to be non-hazardous. Containers of unknown material assumed to be hazardous will be labelled “UNKNOWN SUBSTANCE – Do not use.”

Be provided with secondary containment (e.g., soil berm with a high density polyethylene (HDPE) liner or manufactured secondary containment system) designed to contain 110 % of the total volume of the container (when only one container is located in the bermed area) or 25% of the total volume of all containers which could be stored in that area and equipped with a manual valve (or equivalent means as necessary) to allow for the release of clean, uncontaminated, storm water (oil or petroleum residue in rainfall contained in the storage area must be separated from the water prior to disposal of the water);

Be equipped with fire extinguisher(s); and

Be located away from existing drainage paths to offsite areas to prevent accidental spills from reaching sensitive areas;

Maintenance waste (e.g., batteries, waste oils, oily rags) generated in work areas will be temporarily stored in appropriate hazardous waste storage containers until the waste can be transported to the approved hazardous waste storage area. Under no conditions will hazardous waste be stored at work areas without being stored in a bunded / contained area.

Areas will be managed to ensure:

Only authorized personnel access the area;

MSDS, as well as inspection records and transportation documents, are available at the storage area;

Sufficient space is be maintained between drums/containers to allow access during emergency response situations; and





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Incompatible materials are segregated from each other.

Containers used to store hazardous wastes in the storage area shall meet the following criteria:

Be in “good” condition with no visible defects that could result in leaking or spilling of wastes;

Liquid wastes or sludge shall be stored in leak-proof sealed containers;

Non-liquid wastes may be stored in containers with removable tops; and,

Be kept upright and closed at all times unless adding or removing contents.

Containers shall be clearly labelled with the following information, in English, Arabic and/or other appropriate languages, at all times:

“HAZARDOUS WASTE” or “WASTE OIL FOR DISPOSAL”

Name of the Waste (e.g., waste oil, solvents)

The CEC shall conduct visual inspections of all waste containers in the storage area, at least weekly, to monitor the type and volumes of waste contained in the area and to ensure there are no releases of hazardous wastes to the environment in accordance with the Spill Prevention and Response Plan (Appendix E).

A written record of inspections shall be maintained to document the date, type and amount of wastes deposited in the storage area. Only authorized Project personnel shall have access to hazardous waste storage areas.

Additionally, all fuel storage, refuelling and wash down areas will be equipped with an oil-water separator. Clean waters will be discharged to the sedimentation pond for reuse and oily residues will be disposed of to an authorized disposal / treatment site.

Copies of these inspections will be documented in the project’s EIR forms and will be provided to the Employer on a monthly basis.

Finally, all contractors engaged in transportation, storage and disposal of industrial hazardous wastes must receive certification from the PME and RC.

All hazardous material storage tanks and containers, including those for used oil, will be compatible with the materials to be stored within them.

Storage tanks and containers located onsite may not be reused or refilled with hazardous materials different from those originally held in the tank or container.

To minimize the possibility of inadvertent mixing of incompatible materials during handling, incompatible materials will be segregated (e.g., by using distance or physical barrier) in storage areas. Hazardous materials shall be stored separately from hazardous wastes.

Satellite Accumulation Areas (SAA) for hazardous waste may be established by Contractors provided they meet all applicable requirements as specified within this Field Instruction.





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Works Contractors shall designate trained persons as being responsible for managing hazardous waste SAA prior to its removal from site.

Waste accumulated in SAA shall be managed in accordance with this Field Instruction until it can be removed to a centralized hazardous by-product storage area and/or made ready for removal by a licensed hazardous by-product handling company.

Materials shall only be used in accordance with the manufactures’ directions, the product Material Safety Data Sheet (MSDS) recommendations and the approved Hazardous Material Evaluation Form.

Hazardous materials (not including petroleum products which are addressed below) shall be located in designated areas to optimize control. Storage areas will be constructed, or purchased, prior to bringing any hazardous material or fuel onsite.

The Contractor shall follow all the “Hazardous Material Storage and Handling Regulations” provided by Royal Commission in section 4.3 of Royal Commission environmental regulations and also in the Ras Az Zawr Environmental Design Criteria, Doc. No. 25457-0000-H04-HCHH-0001.

2.8 Hazardous Material Management

Works Contractors shall establish a formal Hazardous Materials Management Field Instruction which must address the following management elements:

The specific requirements of the Hazardous Waste Regulations as they pertain to the works contractor’s scope of work.

Roles and responsibilities – These must clearly define responsibilities for staff to ensure the requirements of this field instruction are complied with and are communicated to Works contractor staff, new hires and subcontractors;

Training requirements including:





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induction,

ongoing task specific training,

revised roles and new initiatives;

the employed person's duties and responsibilities,

use of personnel protective equipment,

fire and explosion response procedures,

spill response procedures,

communications and alarm systems (where applicable),

use of abatement and cleanup equipment,

shut down operations (where applicable), and

hazards of all hazardous waste managed at the facility,

Management controls including:

descriptions of inventories,

supervision of SAA,

management of waste disposal contractors

Inspections;

Storage & security management;

Emergency response measures;

Describe a systematic auditing procedure for significant aspects of hazardous materials management at site in order to verify its adequacy and performance.

2.9 Hazardous Waste Transportation

Bechtel shall ensure contractors managing hazardous wastes only transport these materials to an approved hazardous waste disposal site, which must be approved and certified by the PME and Royal Commission. If the municipal hazardous waste disposal site is not yet available for disposal of solids and sludges, then hazardous wastes must be stored onsite in an approved area until permission is granted by the Saudi PME and Royal Commission for disposal offsite. Approval must be obtained from the Saudi PME and Royal Commission prior to generating any wastes on the Project site. The CEC will verify that all documentation is in place prior to approving final disposition of the hazardous waste. An approved hazardous waste hauler will be selected and waste will be transported in accordance with the following rules:





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Hazardous waste shall be securely packed and labelled to ensure the waste can be transported safely to the approved disposal site without risk to those handling the waste or to the environment;

Hazardous waste shall only be loaded within a hazardous waste storage area or unloaded at the final waste disposal location;

Contractors shall maintain documented records of disposal methods; and

The CEC shall ensure that the waste hauling and disposal Contractor maintains accurate records and Waste Logs for all hazardous wastes transported from the Project site.

All containers must be appropriately labelled. All labels should be in English, Arabic and pictograms.

2.10 Inspection

The CEC and Contractors will conduct routine (daily) visual inspections of all hazardous material/waste storage areas and containers to look for signs of deterioration, leaks, unsecured container lids, or excess accumulation of materials in the containment areas. All visible leaks and releases shall be promptly corrected.

Equipment operators shall conduct routine inspections (i.e., at the start of the work day) on equipment to check for leaks, perform periodic preventive maintenance on equipment to minimise the potential for spills or leaks, and ensure spill kits are complete and available. All inspections shall be documented, with corrective action(s) taken as soon as practical.

2.11 Training

As previously noted all Bechtel employees and Contractors will be required to attend Environmental Awareness training. In addition to the general ES&H training, Contractor Supervision (e.g., foremen), Contractor Management and employees that routinely handle hazardous materials / wastes (e.g., refuelling personnel, pump operators, mechanics) shall receive additional training emphasizing the hazards and mitigation measures associated with reporting, clean up, and documentation of hazardous materials/wastes and petroleum product spills.

Emergency response crews will be trained to use spill kits to address spills or leaks that may occur at their respective locations.


Bechtel Confidential Contains Bechtel and its affiliated companies confidential and/or intellectual property which shall not be used, disclosed or reproduced in any format by any non-Bechtel Party without

Bechtel’s prior written permission. All rights reserved. Saudi Arabian Mining Company (Ma’aden) shall have an unconditional perpetual, royalty-free, freely sub-licensable and assignable license to use such intellectual property for all purposes in connection with the Project.

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APPENDIX E-1 HAZARDOUS MATERIALS INVENTORY

CONTRACTOR NAME:

INVENTORY DATE:

CONTRACT NAME: INVENTORY COMPLETED BY:

CONTRACT NO.: POSITION:

Site Stock No Product Name Manufacturer WHMIS Rating Hazardous Status Qty Unit Audit Date Entry Date


Bechtel Confidential Contains Bechtel and its affiliated companies confidential and/or intellectual property which shall not be used, disclosed or reproduced in

any format by any non-Bechtel Party without Bechtel’s prior written permission. All rights reserved. Saudi Arabian Mining Company (Ma’aden) shall have an unconditional perpetual, royalty-free, freely sub-licensable and assignable license to use such intellectual property

for all purposes in connection with the Project.

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Ras Az Zawr – Hazardous Material Evaluation Form

Page 1: To be filled out by the Works Contractor / Requestor

Date: MSDS Ref. No/Date:

Requestor: Contractor:

Product Name: Manufacturer:

Container Size: Quantity Ordered: Total Amount:

Location where product will be used:

No. of Employees involved: Duration of Task

NFPA Diamond (Warning label from MSDS) Flammability: Health: Reactivity:

1. Describe how material shall be used and a description of the surrounding environment:

2.

Will the substance/agent have the potential to be considered a physical or heath hazard in the manner used above?

Yes No

If yes, describe how:

3.

Possible Exposure Routes of entry Low Medium High

Inhalation

Ingestion

Absorption

Injection

4.

Control Evaluation: Yes No

Are safer substances available?

Can you use a substance in less harmful form?

Are control measures in use?

Are they being used correctly?

Are new control measures required?

Is training adequate?

6.

Can the Contractor control exposure by amending or establishing current working practices? Yes No

If yes, describe how:

7.

8.

9.





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Page 2: To be filled out by Ras Az Zawr ES&H

The material may be used provided all of the requirements of the Hazard Communication Program and the MSDS are followed.

The material is unacceptable for use onsite due to its hazardous properties. An alternative material should be identified. Reason for denial:

The material is approved for use provided the following requirements are complied with:

a List any Occupational Exposure Standards which apply (OES):

Personal Exposure Limits

8Hr TWA 15min STEL Substance % Composition

PPM or mg/m3 PPM or mg/m3

b

c

Can exposure be reduced by amending or establishing working practices? Yes No If Yes, describe revised work practices:

d Describe any special environmental monitoring / reporting requirements for project ES&H staff:

e Describe any special environmental handling and/or disposal requirements:

Completed by:

ES&H Representative Approval Date:

Environmental Lead Approval Date:





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Appendix F

Spill Prevention & Response Field Plan





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1. SPILL PRE-PLANNING AND PREVENTION Bechtel and Contractors will develop and implement measures to minimise the amount of hazardous materials brought onsite and used to prevent spills (and associated wastes which may be classed as hazardous). This typically forms part of the Environmental Plan produced by all contractors. Specifically, hazardous materials must be approved by Bechtel prior to being brought on site. When applicable, Bechtel will suggest a less hazardous materials be substituted for a selected material. Since approvals are required from the Saudi Ministry prior to hazardous material being brought on site, Bechtel will have the opportunity to review lists of materials well in advance of commencement of work and suggest minimization measures when appropriate.

Chemicals considered hazardous follow the hazard classification system included in the United Nations Recommendations on the Transport of Dangerous Goods.

All heavy equipment / construction plant must be inspected and approved before it is allowed onto the work onsite. The checks undertaken on the equipment include a review of hydraulic lines and maintenance records. Poorly serviced and leaking equipment is not allowed onto site until these issues have been rectified. Contractors are briefed about equipment maintenance and spill prevention during this process.

The purpose of this Spill Prevention & Response Instruction is to describe the measures to be taken by Ras Az Zawr Contractors to prevent environmental damage caused by spills of potentially contaminating materials and to assure timely and effective clean-up in such instances.

The purpose of this plan is to:

Describe procedures for responding to incidents involving releases of hazardous and/or potentially contaminating substances; and

Demonstrate compliance with applicable contractual and regulatory requirements governing spill prevention, spill response, and notification.

This instruction is applicable to Bechtel staff and Contractors on Ras Az Zawr Project.

1.1 Responsibilities Duties of the following person with respect to this plan are as follows: Site Manager: Management of all day-to-day construction activities in accordance with Ras Az Zawr

environmental guidelines and standards;

Working in conjunction with the Project Environmental lead (CEC) to manage the response to spills including appropriate clean up and response, including the use of the Third Party Environmental Contractor, the General Services Contractor and/or any third party emergency response organizations.

Ensuring that adequate resources (personnel and control materials) exist to support the implementation of this plan in the field, including the provision of reserves of spill clean up materials.





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Reviewing Works Contractor performance and activities, and implementing enforcement actions if non-compliance with the requirements of this plan is observed.

Bechtel Field Supervisors: Review Work with the CEC to determine high risk activities or job-sites which require additional

spill prevention and response measures;

Review on-site spill prevention and response equipment deployed by Contractors;

Assist in the immediate management of spills and response activities;

Assure that Contractors develop a Spill Response team that is trained and equipped with the correct PPE and materials based on the scope of work and materials in use;

Confirm that Contractor staff and management are aware of the requirements of this plan and work with the Contractor management and Bechtel ES&H department to address any weakness in understanding and/or training;

Report environmental compliance issues to the CEC and the ES&H Manager;

Assist Contractors with the development of Environmental Incident Reports in the aftermath of an incident.

Environmental, Safety and Health Manager (ES&H Manager): Timely communication to the Site Manager of environmental incidents and/or spills and response

measures required;

Procurement of spill response equipment to be retained and maintained by Bechtel for the purposes of emergency response;

Support for the implementation of this plan through the provision of sufficient resources and staffing to assure training of Contractors and compliance monitoring in the field.

Construction Environmental Coordinator (ES&H Manager): Review Contractor’s spill prevention and response teams, equipment, responsiveness and

awareness to assure that they are capable of managing spill events;

Coordinate the involvement of any third party organizations involved in Ras Az Zawr spill response activities if required;

Revise and update this plan in the event of required changes;

Coordinate the completion of environmental incident reports and follow up investigations and lessons learned;

Confirm requirements for disposal of contaminated materials with SM, the Owner and local authorities to assure that material disposed of onsite is managed appropriately;

Review construction work plans and schedules to assure that proper and required environmental controls are incorporated to reduce the risk of spill events;





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Directly notifying the ES&H Manager and Site Manager of any circumstances that warrant agency notification or management action;

Provide guidance to field procurement staff on spill material acquisition;

Conduct regular field inspections of construction activities for compliance with this plan;

Coordinate site inspections by regulatory agencies and agency interface during post incident inspections;

Initiate stop-work orders when environmental non-compliance with this plan or at-risk conditions are observed in the field;

Develop and conduct training for Bechtel and Contractor personnel on the correct implementation of this plan

Contractor: Compliance with Ras Az Zawr ES&H Requirements Plan (Doc. No. Later) and Construction

Environmental Control Plan (CECP) which are intended to establish a framework for the safe management of potentially contaminating materials;

Designate a point of contact for environmental management and compliance issues with respect to this plan;

Procurement of suitable spill prevention and response equipment and materials;

Training of staff in accordance with this plan;

Identification of an appropriate third party organization that can be contacted in the event of a major spill event requiring additional response capabilities.

1.2 General Requirements for Spill Prevention and Response

Contractors are required to retain spill kits for use on site which contain, as a minimum, the materials listed in Section 1.3 below. Contractors are required to inspect spill kits at least weekly to ensure sufficient materials are available and used materials are replaced. Absorbent materials in spill kits should not be used for normal cleaning activities usually done with rags, such as wiping parts or hands unless associated with a spill clean up activity.

1.3 Spill Kits Contractors shall supply the following absorbent materials for use in the event of a spill.

1.3.1 Mobile Equipment and Stationary Construction Equipment

All plant and equipment shall be equipped with a proprietary spill kit which shall contain the following materials as a minimum:

10 x Oil Only Pads (17” x 19”)





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4 x Antifreeze pads (17” x 19”)

3 x Oil only booms (3” x 48”)

1 Paid of vinyl/latex gloves

1 x container of Plug n’ Dike hole filling compound

2 x Garbage bags for disposal

These spill kits are commercially available; however, local suppliers can produce spill kits that meet the requirements of this procedure. The Bechtel CEC can provide contact details for local suppliers upon request.

1.3.2 General Spill Response Equipment

Contractors shall be required to maintain larger quantities of spill absorbent materials in reserve which can accommodate a reasonably anticipated spill event.

As a minimum, Contractors shall maintain spill kits that contain sufficient hydrophobic absorbent material (e.g., oil absorbent booms and diaper pads) to contain and cleanup potential drips, leaks, or spills (e.g., ruptured hydraulic line), gloves and heavy plastic bags to contain oily absorbent materials and contaminated soils or wastes in each of their distinct work areas.

Works Contractors may elect to procure additional materials, however the materials listed below shall be the minimum requirements for reserve absorbents to be retained by all Contractors on the Ras Az Zawr site.

The following materials are recommended as the minimum requirements for the Ras Az Zawr construction site.

Universal Maintenance Absorbents

16 - 48" Absorbent Socks

10 - 10' Absorbent Socks

60 - 15" x 20" Universal Mat Pads

8 – Pillows

56 – Wipers

10 - Disposal Bags and Ties

Oil Only Absorbents

3 - 5" x 10' Oil-Only Booms

10 - 3" x 10' Oil-Only Booms

15” x 20” Heavy Absorbent Pads





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1.3.3 Tank Vehicles/Trucks

All refuelling and maintenance trucks shall have spill kits onboard. Refuelling shall not be performed within 15 metres of storm water management structures or channels. A trained refuelling operator shall perform refuelling operations. A spill kit and fire extinguisher shall be readily available.

All connections will be bonded to prevent static discharge, and there will be no smoking within 15 metres during refuelling operations. Upon completion of fuelling, the refuelling operator shall keep the nozzle elevated until it is drained into an approved container to remove any free material. Nozzles shall be stored in a receptacle designed to contain any fuel that may leak from the nozzle.

Fuel will only be placed into fuel tanks or vessels specifically designed for fuel containment (e.g. portable fuel containers).

1.3.4 Hazardous Materials Storage Areas

Works Contractors shall be required to supply and have available sufficient spill prevention and response materials and equipment to enable the safe storage and handling of hazardous materials, including the clean up in the event of an incident. The Bechtel CEC has responsibility for assuring that hazardous material storage areas meet the requirements of this document.

Storage areas for hazardous wastes must be equipped with a spill kit suitable for the material being stored. As a minimum it should include:

Rolls of absorbent pads specific to the material;

Large absorbent boom/socks;

Dry absorbent granules, also known as kitty litter;

Non-sparking shovels;

Buckets;

Overalls;

Chemical resistant gloves; and

Storage containers for waste material.

1.3.5 Temporary Storage of Plant, Equipment and/or Materials

During construction it is likely that Contractors will be required to store materials such as generators, light-sets and/or barrels containing potentially contaminating materials outdoors, or in other temporary locations where there is a risk of spillage and pollution, but where the installation of permanent spill containment is not feasible.

In each case, Works Contractors are required to install spill prevention equipment where practicable, in order to mitigate the risk of pollution.





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Measures which may be installed include:

Plastic containment pallets and decks for 55 gallon drums. These must be utilized in conjunction with flexible tarpaulin covers to prevent the ingress of water into the pallet which then requires disposal.

Collapsible containment which may be installed underneath temporary equipment such as light-sets and generators. Works Contractors must be aware that these are likely to fill with water if left uncovered and so these should always be utilized with tarpaulin covers, as above.

Temporary equipment may be protected through the installation of hydrophobic (does not absorb water) pads underneath to assure that any minor drips or leaks are captured. Pads must be secured, be regularly inspected and should be replaced in the event of any damage and/or deterioration.

1.4 Disposal Requirements

Absorbents and Clean Up Materials

Contractors are required to dispose of all contaminated materials generated during a spill clean up event in approved containers. A third party waste management company will be responsible for disposal of contaminated spill materials at approved locations. At all time, Contractors shall be responsible for the proper packaging, labelling (Both in English and Arabic), and classification of all wastes prior to off-site treatment or disposal.

1.5 Contaminated Soil

Soil material which has been contaminated as a result of a spillage may be disposed to approved landfills outside the site boundaries but it is possible to store the contaminated soil in approved containers on site temporarily. In each case, the method of disposal shall be determined and documented by the Bechtel CEC in conjunction with the Owner and local authorities or designee.

Contractors shall be required to procure the services of a licensed waste disposal company that will dispose of contaminated soils in an environmentally appropriate manner that accords with applicable regulations.

1.6 Spill Response and Clean Up Procedures The impact of a spill is related to the quantity and toxicity of material and the time taken to identify and respond to the spill and enact a satisfactory response and clean-up. To minimise the impact of a spill, Works Contractors shall assure the following:

1.6.1 Response Team





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A spill response team shall be developed within each Contractor organization to act as the immediate first response measure in the event of a spill. Contractor personnel shall be trained to respond to environmental releases, and shall be knowledgeable of the locations of spill response equipment and materials and their use and disposal options. Contractor Supervision and Management shall also attend all training to assure that they are aware of the actions to be taken in the event of a spill, including the requirements for notification, and the possible involvement of a third party contractor to assist, should it be required. Unless other emergent conditions exist, such as fire, toxic clouds, or injuries, the CEC will be responsible for coordinating spill clean-up activities. If there are emergency conditions which take precedence, such as fire or injury, the CEC shall inform the construction site emergency system and also SM. Contractors are required to have available the contact details for an external emergency response contractor that could be contacted to assist in the event of a spill(s) that is too large or too hazardous for the on-site resources to safely and effectively handle.

1.6.2 Response Action 1. If spilled materials are flammable, eliminate potential sources of ignition from within and near the

spill area.

2. IF IT CAN BE PERFORMED SAFELY, stop the source of the spill, seal off the drains that the spill may reach, and contain the spill within as small an area as possible.

3. If the personnel experiencing the spill requires emergency assistance, the following Emergency Services shall be contacted:

Bechtel ES&H Manager: TBD

Project Emergency Services.

4. Secure the area, warn other personnel to stay away from the area, establish perimeter control at a safe distance from the spill, and immediately notify the SM and CEC.

5. Scene management is the responsibility of the Bechtel SM, or their designee, until Emergency Services personnel assume control (if necessary).

6. Notify Employer as required.

1.6.3 Clean Up Actions for Spills of Petroleum Products 1. SAFETY FIRST

Avoid inhalation of vapours by staying upwind or use proper respiratory protection.

Use chemical-resistant personal protective equipment (PPE) during clean up activities.

Gasoline and gasoline vapours are HIGHLY FLAMMABLE and may create an explosive atmosphere - remove sources of heat, sparks, flame, friction, and electricity; restrict fires or open flames from the spill area.

2. IF IT CAN BE PERFORMED SAFELY, the Bechtel CEC will supervise the clean up of spilled material and equipment.





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3. Small spills, including leaks from equipment, should be cleaned-up immediately with absorbents and clean up materials properly labelled and disposed.

4. Large spills outside of contained areas should be diked with absorbent or soil to prevent liquids from reaching drainages, storm drains, or wadi. Clean up decisions for large amounts of free liquids will be made in conjunction with the CEC or designee. Clean up may be performed by a third party trained and licensed hazardous materials response contractor.

5. Spill clean up wastes must be placed in appropriate waste containers, properly labelled, and stored in a designated hazardous waste storage area prior to disposal. Cleanup waste shall be disposed of as hazardous waste.

6. Diesel fuel, gasoline, and hydraulic/lube oil cleanup wastes that contain free-flowing liquid should be drained to remove as much of the free-flowing product as possible. The remaining sludge / solids must be properly labelled and disposed of as hazardous waste.

7. The free product removed from the waste and all gasoline spill waste must either be recycled or, if not recyclable, disposed of as a hazardous waste.

1.6.4 Clean Up Actions for Chemical Spills 1. SAFETY FIRST

Avoid inhalation of vapours by staying upwind or use proper respiratory protection.

Use chemical-resistant PPE during clean up activities.

Restrict fires or open flames from the spill area.

Personnel not trained to deal with chemicals shall not attempt to clean up spill.

2. Refer to the MSDS for special hazards associated with any spilled chemicals, especially for reactivity with other materials in the spilled area.

3. Small spills within contained areas should be neutralized (if appropriate). Free product that cannot be used must be classified as to whether it is a hazardous waste.

4. Spills of caustics or other highly volatile or dangerous chemicals outside contained areas should be diked with absorbent or soil to prevent liquids from reaching drainages, storm sewers, or other bodies of water. Clean up decisions for large amounts of free liquids will be made in conjunction with the external Emergency Services. A third-party trained and licensed hazardous materials response contractor may perform the clean up.

5. Spill cleanup wastes must be placed in suitable containers, labelled and transferred to a designated hazardous waste storage area.

6. Bechtel’s CEC will complete a Spill Incident Report (refer to CP 108).

1.7 Notification and Reporting It is the responsibility of the person who observes or identifies a spill or other environmental emergency to ensure that their immediate supervisor and the CEC are notified with the following information:

Reporting person’s name and telephone number/call sign

Location of the spill





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Date, time, and type of incident

Type and quantity of material spilled (if known)

Extent of any injuries

Possible hazards to human health and the environment, both on and off the site

The quantity and disposition of any recovered materials

Clean up and/or mitigation actions taken

The CEC shall report to the ES&H Manager and Site Manager all reportable quantity releases of hazardous materials or releases that pose or could pose the following threats:

Fire with potential offsite impacts

Explosion

Violation of air quality standards

Release of vapours, dust, and/or gases causing illness/injury to persons offsite

Runoff from fire control or dilution waters that could result in violations of local water quality standards

The CEC shall maintain copies of all Incident Reports for Project reference. Works Contractors are required to maintain copies of all reports for reference and possible regulatory follow up, if required. Bechtel will document all spills using the appropriate report form from CP 108 and enter the occurrence in the accident / incident register. The report will include the date, time, location, type of material spilled, quantity, corrective actions taken, and any notifications made. A significant environmental matter, as defined by Bechtel Legal Instruction 127, shall be reported immediately to the SM, so that appropriate steps can be taken to fulfil Bechtel Legal Instruction 127.

Spills over 5 litres will also be reported to the Employer within the monthly and quarterly reports.





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Appendix G Waste Management Plan





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1. INTRODUCTION This plan shall be followed by all Project personnel and is applicable to all wastes generated at site and ancillary facilities during construction. Contractors shall perform their work to achieve the requirements specified in this Waste Management Plan. This plan addresses the handling, storage, and management of wastes. All wastes shall be classified as inert, non-hazardous, or hazardous (including sanitary). This plan does not address waste management that is not associated with the Bechtel’s scope of work, nor waste related to the operational phase.

2. PURPOSE The purpose of the Waste Management Plan is to describe the procedures to meet, to the greatest extent practical, the following environmental goals:

Minimum waste disposal; Maximum waste recycled; No pollution of land or water; No fugitive emissions or odours; and Sustainable use of material.

3. DEFINITIONS The Saudi Presidency of Meteorology and Environment (PME) provide the following definitions associated with wastes:

Waste. Wastes are discarded or abandoned substances which must be disposed of by use of any of the processes listed under Appendix II of the PME Environmental Protection Standards3. Wastes include discarded substances as well as substances to be recycled if collected and accumulated before recycling, incinerated for energy or for use as a fuel or for production of fuel.

3 D1- depositing in to or on land, (e.g. landfill etc.). D2- land treatment (e.g. biodegradation of liquid or muddy wastes in soils etc.). D3- Deep injection, (e.g. injection of waste into wells, salt domes or naturally occurring repositories, etc) D4- Surface impoundment (e.g. placement of liquid or muddy wastes into pits, ponds or lagoons, etc) D5- Specially designed landfills, (e.g. placement into lined discrete cells which are capped and isolated from one another and the environment, etc) D6- Discharge into a water body except seas and oceans. D7- Discharge into seas and oceans, including seabed insertion. D8- Biological treatment not specified elsewhere in this list which results in final compounds or mixtures which are discarded by means of any of the operations in this section. D9- Physic-chemical treatment not specified elsewhere in this list which results in final compounds or mixtures which are discarded by means of any of the operations in this section (e.g. evaporation, drying, neutralization, sedimentation, etc) D10- Incineration and ashing on land. D11- Incineration and ashing at sea. D12- Permanent storage (e.g. placement of containers in a mine, etc) D13- Blending and mixing prior to processing by any of the operations listed in this section. D14- Repackaging prior to processing by any of the operations listed in this section. D15- Storage pending processing by any of the operations listed in this section.





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Hazardous Wastes. Materials with hazardous properties harmfully affecting human health or adversely impacting on the environment such as infectious, toxic, explosive, inflammable substances or ionized radiations. Hazardous wastes are the remains of different activities and processes or related ashes sustaining hazardous material properties which have no subsequent-original or substitute.

These wastes result from various activities and processes considered hazardous to the environment, health and public safety. Typical sources of hazardous waste are: industrial, agricultural, petroleum, health-care, research and lab activities and garbage. Wastes are deemed hazardous if:

(i) They are a mix of hazardous wastes with other substances.

(ii) The Presidency decides to consider them specifically hazardous.

Non-hazardous Waste. The following shall not be deemed as hazardous wastes:

(i) Domestic sanitary waste water and other wastes passing through the sanitary drainage network to the treatment facility. This exclusion does not cover sludge resulting from the sanitary wastewater treatment facility.

(ii) Final discharge of treated industrial waste water. This exclusion does not cover final discharge waste water.

(iii) Agricultural drainage runoff.

(iv) Mining residual matter remaining at their natural location in the mine during extraction.

Reuse: By-products are used again, on-site or off-site, in a manner similar to the original use of the material;

Recycle: By-products are reprocessed, generally by a third-party processing company, to use the by-products as feedstock to create new materials for manufacturing new products.

4. RESPONSIBILITIES In addition to the responsibilities which are described in section 3 of the CECP document, duties of the following persons with respect to this plan are as follows: Site Manager: The SM has overall responsibility for construction on the Ras Az Zawr Site. Specific responsibilities with respect to this field instruction include: Supporting the implementation of this instruction though provision of adequate management

support and resources; Coordinating and raising issues of waste management in the Zero Accident Program, Joint

Health & Safety Committee(s); Championing waste management initiatives and strategies to improve compliance in the

field.





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Contractors: Contractors are responsible for implementation of this instruction in the field. Responsibilities include: Implementation of this instruction in the field; Provision of suitable and sufficient waste receptacles to support waste segregation and

recycling initiatives; Conducting inspections and reporting waste management compliance and opportunities for

improvement to the Bechtel CEC; Housekeeping in construction and waste storage and handling areas; Recording, as far as practicable, the mass of waste streams generated, handled and

exported; Clearly separating hazardous and non-hazardous wastes for appropriate treatment, disposal

or re-use. Raising issues of non-compliance and opportunities for improvement and assure timely and

effective follow up. Construction Camp Manager: The construction camp manager is responsible for the operation of the camp in accordance with this instruction. Specific responsibilities include: Provision of adequate waste receptacles in communal areas for use by camp residences; Display of promotional materials in support of Ras Az Zawr waste management strategy; Maintenance and upkeep of waste handling and storage areas; Housekeeping in and around the camp and communal areas; Procurement of cleaning and maintenance materials with a minimal environmental impact,

where practicable; Provision of training to camp cleaning and catering staff in waste segregation and recycling

initiatives. Construction Environmental Coordinator (CEC): The Bechtel CEC is responsible for: Providing oversight & implementation of Contractors mobilization, planning, & waste

management programs; Day-to-day environmental compliance activities for construction, development and planning

of new waste management strategies, as well as modifications and upgrades to this waste management field instruction;

Provision of technical support for auditing & tracking of by-product sorting, collection, transport and final disposition (recycle or disposal);





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Coordinate site activities for waste management including ensuring that waste containers are properly managed and materials (receptacles/signage etc.) are procured, to support the Ras Az Zawr waste management program;

Coordinate Contractor submittal of Waste Disposal and Declaration Plan required for Safe Work Plan

Collating information from Contractors on total quantities of waste produced.

5. ANTICIPATED WASTES The following matrix presents the wastes that are expected to be generated during construction and the associated handling, storage, and disposal methodologies.

Specific requirements for segregation re-use and recycling will be published to all users of the site using the ESH Bulletin system to ensure that all are up to date with current best practice.

Type Category Handling/Storage Treatment

Used Tires Hazardous Waste

Designated storage area Store in designated waste storage area unless recycling opportunities found

Scrap Metal Non Hazardous (Inert)

Designated metal scrap storage areas are provided according to type i.e. segregation of ferrous metals in the workplace, and a specialist secured area for segregation of copper and Aluminium.

Re-use onsite where possible or Recycle

Timber (wooden products not treated with hazardous materials e.g., arsenic)

Non Hazardous (Inert)

Stored in designated storage area of the site according to type i.e. segregation of softwood, plywood, particle board and other types of wood.

Re-use onsite where possible e.g. barricading materials, support for formwork, notice boards, tables and work benches, storage cupboards and bookcases, slope access ways, stairs to formwork or shallow excavations, protection of asphalt when moving equipment, etc. or store for later recycling after construction has been completed.

Food waste Non Hazardous Closed containers for storage within the workplace until waste contractor removes.

Garbage / refuse / litter

Non Hazardous Closed containers for storage within the workplace until waste contractor removes.

Recycle where possible.

Non-plastic, packaging

Non Hazardous Reduce to manageable size. Cardboard is to be placed next to

Reuse or recycle cardboard, metals and wood where possible.





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materials the general waste skips, metals go to either the ferrous metal skips in the workplace or to the copper and Aluminium storage area, and wood is taken to the sorting / storage area for segregation.

Plastic packaging material.

Non Hazardous Waste

Stored in waste container. Disposal with authorized waste disposal contractor unless recycling opportunities found.

Paints and thinners

Hazardous Waste

Stored in original sealed container at the designated hazardous waste storage area of the site.

Re-use where possible, Recycle dried containers or storage of Hazardous Waste in the main Hazardous Waste Storage area.

Hazardous wastes: Waste oil Solvents Oily filters Scrap

batteries Unidentifiable

substances

Hazardous Waste

Stored in the designated hazardous waste storage area of the site.

Recycle or disposal by contractor with authorized waste disposal contractor where possible.

Sewage Septic Waste Holding tanks - various locations within the workplace or at STP lifting station

Transportation by septic truck to approved sewerage treatment plant for treatment at an external STP at the start of project and onsite STP later.

Sewage Sludge, Grit Removal Materials and Screened Materials

Non Hazardous Waste

Skips at the STP. The STP product (Cake) should be sent off-site to the provisioned land-fills by approved contractor.

Treated Sewage Effluent

Non Hazardous Waste

Aboveground holding tanks at the STP

Re-use onsite for irrigation, dust control, wetting down for compaction activities and recycle the rest offsite (main uses expected to be irrigation and dust control).

Surplus Chemicals Hazardous Waste

Stored in designated hazardous waste storage area

Re-use where possible. Excess will be handed over to Smelter operations.





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Excess cement (dry)


Dump from concrete trucks as wet concrete in designated areas.

Re-use wet concrete where possible. Dried wastes will be broken up and reused during construction activities.

Cement truck rinse water (after dried)


Stored in designated areas. Mixed with excess soil for possible reuse onsite.

Soil contaminated with petroleum product(s)

Hazardous Waste

Stored in designated hazardous waste soil area

Bio-remediation treatment where possible (requires long term commitment as wastes will take years to bio-remediate) or disposal with authorized waste disposal contractor if one is available or storage onsite until one is located.

Excess Soils, Rock, Stones

Non Hazardous Waste

Stored in designated storage areas (i.e. engineering soil / materials stock pile).

Re-use onsite where possible e.g. stones are screened from engineering fill and reused onsite, broken concrete is suitable for fill or warning layers, asphalt can be reused as base materials for pavements and car parks etc., topsoil and natural rock are a resource for landscaping once construction has been completed.

6. GENERAL WASTE MINIMIZATION AND MANAGEMENT MEASURES Based on a review of the wastes expected to be generated during construction, the following waste minimization and management measures apply to all waste:

Project waste will only be disposed of at facilities that are authorized and licensed by the PME, as per Article IV, Producers of hazardous wastes; Hazardous Waste Control Rules and Procedures; Saudi PME. Waste shall not be land filled on-site.

All waste generated shall be classified as inert, non-hazardous or hazardous.

Prior to transferring Project inert or non-hazardous wastes to third parties for reuse or disposal, Bechtel will evaluate potential adverse impacts that may result.

All spills (e.g., oil, diesel, chemical), regardless of the quantity, shall be immediately cleaned up as per the Spill Prevention and Response Plan.

Waste will only be stored in sealed containers and / or areas that have been specially designed for the waste. Partially filled containers will be stored in the workplace hazardous





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materials bunded storage areas until they are full, then they will be transferred to the main hazardous waste store in the north of the site.

Waste storages should be located in a cleared area on the leeward of the fore-dunes, away from Sabkha and should be afforded protection from wind to prevent wind driven refuse reaching water resources.

Bechtel will conduct quarterly inspection of waste documentation and track quantities of waste being generated on a monthly basis using the Waste Logs. Monthly reports documenting the amount of waste being generated will be provided to the Employer and Bechtel corporate as part of GHG tracking.

Waste Delivery confirmations are required for the waste packages (truck load) which will be sent off-site to third party facilities such as STP, landfills or Waste Water Treatment Plant (WWTP). CEC is responsible to manage obtaining the delivery confirmations and coordination with waste contractor and third party facilities.

6.1 Anticipated By-products Source control and waste avoidance shall be the preferred management strategy for reducing by product generation whilst disposal is the least preferred solution. Generally waste will be managed according to the following hierarchy:

Avoidance

Reuse

Recycle

Treatment

Containment

Disposal

By-product minimization shall be evaluated throughout the course of construction, with the hierarchy of waste management practices to be:

Identification of key waste streams to be managed by the Project; Eliminate or minimize the waste streams by procedure or technology;

Re-use immediately on site in a mode consistent with the material of product’s original purpose;

Recycle material via third-party recycling enterprise;

Compost organic material;

Landfill (not applicable to liquid by-products).





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6.2 Contractors Requirements Contractors shall review and complete the Waste Disposal Declaration and Disposal Plan which is included as Exhibit F-2 to this procedure prior to commencing work on site. The intent of this document is to define waste streams that shall be produced during the course of the works and be used as the basis of planning for waste management activities for the duration of the contract in accordance with this Waste Management plan.

Works Contractors shall define waste streams for which disposal is the option. The Bechtel CEC shall review Waste Disposal. Only waste materials for which no other economic or practicable disposal route can be identified may be disposed.

6.3 General Housekeeping

High standards of housekeeping shall be continually maintained in all work areas. Bechtel and contractors shall ensure that:

Work areas are maintained clean and tidy to prevent pollution and maintain a high environmental standard.

Waste is stored in appropriately labelled or colour-coded waste receptacles or at the bulk storage areas for concrete, stones, rock, soils etc.

All equipment or material, required to remain on-site, will be adequately secured according to the type of material and protected where necessary.

7. INERT AND NON-HAZARDOUS WASTE MANAGEMENT Inert waste and non-hazardous wastes shall be segregated and managed in accordance with information presented in the following subsections.

7.1 Non-Hazardous Waste Collection

Non-hazardous waste shall be collected in work and laydown areas in accordance with the following requirements:

Each work area shall have personnel responsible for regularly picking up litter and collecting garbage in suitable waste containers. All containers shall be provided with lids that are securely attached when not in use and distributed in locations where they can easily be seen and accessed. Garbage containers shall be emptied at the end of the day into the general waste skips where any materials are not suitable for recycling.

A dedicated waste Contractor shall collect domestic waste and other waste material from Project waste management areas. The waste contractors shall provide adequate numbers of waste and recycling receptacles and shall also ensure that all possible actions are undertaken to recycle materials from the site, using local waste recyclers where available. The contractors must also be licensed and approved in accordance with Saudi Regulations.

Receptacles for the following waste streams shall be provided in works areas:

o Plastic containers for recycling;





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o Drinks Containers;

o Cardboard, paper and cardboard containing materials;

o Ferrous and non-ferrous metals;

o Non-recyclable and non-reuseable waste;

The following materials may be neatly stockpiled onsite in an orderly manner provided it is clear of any access ways and does not present a trip hazard prior to removal from site:

o Non Ferrous Metals;

o Ferrous Metals;

o Wood materials (pallets, dunnage, wood packaging).

Bechtel’s Waste Contract Supervisor shall ensure that adequate numbers of waste and recycling containers are available in the work areas based on information provided by Bechtel Contract Supervisors and Superintendents.

The Bechtel CEC shall document, the adherence to measures outlined in this plan.

7.2 Non-Hazardous Waste Labelling and Storage

Kitchen and food waste shall be segregated from other waste materials. These covered skips will be sited at workplace dining facilities and any other areas where food is regularly consumed. The main collection container for these wastes shall be emptied regularly in the interests of health and hygiene.

Waste receptacles in eating areas shall be provided with lids or funnels to prevent wind from blowing refuse (specifically plastic bags) from the receptacle.

Other wastes such as cans, glass, packaging, and plastic shall be placed in the appropriately designated collection container. Where possible, recyclable materials, should be transported to an approved recycling site. Where recycling is not feasible the general waste materials shall be transported to and stored at an approved location until a waste disposal contractor is located.

Waste receptacles containing heavy material (e.g., ferrous metals or other metals) shall be designed to safely handle the overall weight of the waste.

All wastes shall be reduced in size (compacted, ground, dismantled, etc.), as appropriate, and segregated into the appropriate waste receptacle. Waste receptacles shall be clearly labelled or colour-coded to identify the waste authorized to be disposed within.

Inert waste (e.g., stones, concrete etc.) will be segregated and stored in a manner to promote reuse. Reuse onsite is preferred to offsite reuse.

Scrap metal shall be collected separately and stockpiled within the designated non-hazardous waste storage area for reuse, if practical, or transfer to the nearest recycling facility.

Non-Hazardous waste storage areas shall comply with the following requirements:

Located away from accommodation areas and sensitive resources;





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Signed to ensure / promote proper wastes segregation;

Signed to show wastes that are not allowed to be stored in the area (e.g., batteries and other hazardous wastes);

Designed to contain spills and leaks;

Covered to prevent rainwater from entering the area (when applicable);

Be secured (e.g., barricaded or fenced and locked) when Project personnel are not working in the area to prevent unauthorized personnel from entering, misuse, or theft prior to disposal (particularly cable off cuts and other valuable recyclables);

Kept free of any windblown garbage; and

Managed to ensure waste containers are kept covered at all times when not in use.

The waste collection Contractor will be responsible for ensuring the Waste Log (Exhibit F-1) accurately records the movements of wastes entering and leaving the project. This is to be completed in conjunction with a Wastes Consignment Note which substitutes for the Property Removal (Gate Pass) form – refer to Project Security Plan for more details regarding removal of materials from the site during construction.

7.3 Inert Material

Inert materials such as overburden, excess rock, gravel and/or organic material shall ordinarily be stockpiled for re-use on site. Specific information pertaining to the handling of such material shall be included in Contract documents however the following general requirements shall apply:

Inert material shall be stockpiled and maintained in such a way as to prevent loss of dust and or sediment by wind and rain/surface water in accordance with the Ras Az Zawr Storm Water Erosion & Sediment Control Plan. Organic topsoil will be segregated and stored separately for use on the site for final landscaping;

Non-organic overburden, and rock which cannot be used as fill, will be placed in overburden storage piles in approved locations or used as fill in other suitable locations;

Dried concrete will be crushed and used as roadbed aggregate or used in other appropriate applications;

Where material has been designated as containing elevated levels of contaminants, stockpiles shall be covered and maintained to prevent loss of material as dust or sediment laden water.

In the event that off-site transport and/or disposal of any inert materials is required, Contractors are required to coordinate with CEC to use the waste contractor of the construction sire or another third party.

Contractors are not to transport any contaminated material offsite without specific prior approval of the responsible Field Superintendent.

Bechtel will take measures to ensure that no waste soil and/or rock, including those transferred to local municipalities or landowners for disposal, are used in a manner that will impact environmental or sensitive resources (e.g., flowing into Arabian Gulf).





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7.4 Reuse and Recycling

In order to facilitate and optimize recycling on the Ras Az Zawr, by-products shall be classified, sorted, packaged according to the following general categories.

Timber, lumber and dunnage (non-treated);

Steel/iron;

Copper;

Aluminum;

White office paper / cardboard products – must be stored in dry covered containers to prevent materials from getting wet;

Colored paper (newspapers & magazines) – must be stored in dry covered containers to prevent materials from getting wet;

Glass and porcelain;

Plastics labeled for recycling;

Household trash and all other non-recyclables;

Tires;

Kitchen & food by-products;

Drinking containers;

Batteries;

Used oil;

Non-recyclable wastes / domestic garbage.

By-product receptacles shall be clearly labeled. All by-products shall be reduced in size, as appropriate, and segregated into the appropriate by-product receptacle.

8. OTHER WASTE STREAMS

8.1 Sanitary Wastewater Management

Wastewater produced during the construction of the Ras Az Zawr Aluminium Smelter shall be treated at an onsite temporary water treatment plant. Under no circumstance, will permanent septic tanks be permitted onsite and sewage should not be transported to an off-site septic system. Once the on-site STP is commissioned, wastewaters will be processed from the Village and construction site, by an authorized and trained contractor. Removal of solid wastes from the STP will form part of the contract.

The contractor will, again, be required to receive certification from the PME before transporting effluent material off-site for disposal.

The treated wastewater could be used for irrigation or dust emission control purposes, tables F-2 and F-3 provide required water quality for irrigation and also criteria for direct discharge to coastal water. Treated wastewater shall not be applied for irrigation by spray distribution systems in areas of heavy public use or in other sensitive areas.

Table F-2





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Irrigation Water Quality Standards At The Point Of Discharge to Irrigation System

PARAMETER(1) UNITS Maximum Allowable Monthly Average PHYSICAL Floating Particles mg/m2 Nil - Total Suspended Solids mg/l 10 / 40(8) 10 Total Dissolved Solids mg/l 2000 1750 Turbidity(2) N.T.U. 5 2 CHEMICAL Aluminum mg/l 5 - Ammonia, Total as N mg/l 5 - Arsenic mg/l 0.1 - Barium mg/l 1 - Beryllium mg/l 0.1 - BOD5 mg/l 10 / 40(8) - Boron mg/l 0.075 - Cadmium mg/l 0.01 - COD mg/l 50 - Chloride mg/l 1000 500 Chlorine Residual(3) mg/l 0.5 (min) - Chromium mg/l 0.01 - Cobalt mg/l 0.05 - Copper mg/l 0.2 - Cyanide mg/l 0.05 - Dissolved Oxygen(4) mg/l 2.0 (min) - Fluoride(5) mg/l 15 5 Iron mg/l 5 - Lead mg/l 0.5 0.1 Lithium mg/l 2.5 - Manganese mg/l 0.2 0.02 Mercury mg/l 0.001 - Molybdenum mg/l 0.01 - Nickel mg/l 0.02 - Nitrate mg/l 10 - Oil and Grease mg/l Nil - pH pH 6-8.4 - Phenols mg/l 0.002 - Phosphorus total as P mg/l 30 20 Selenium mg/l 0.02 - Silver mg/l 0.5 - Sodium mg/l 1000 500 Sodium Adsorption Ratio (SAR)

SAR units 20 10

Sulfate mg/l 600 - Sulfide mg/l 0.1 0.05 Total Kjeldahl Nitrogen mg/l 60 35 Total Organic Carbon mg/l 40 - Vanadium mg/l 0.1 - Zinc mg/l 2 - BACTERIOLOGICAL Total Coliform(6) MPN/100 ml 23 2.2(7)





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PARAMETER(1) UNITS Maximum Allowable Monthly Average Fecal Coliform MPN/100 ml 1 - PARASITOLOGICAL Nematodes (eggs) No./1000 ml 1 - Protozoan Cysts No./10 ml 1 - Platyhelminths-flatworms No./10 ml 1 -

Notes 1) For any parameters not identified, specific standards will be determined on a case-by-case basis. 2) Maximum turbidity not to be exceeded more than 5% of the time in the 24-hour period. 3) Free chlorine residual after 30 minutes of contact. 4) Dissolved oxygen level is a minimum concentration requirement. 5) Fluoride levels assume well-drained sandy soil for irrigation which will not be used for forage. 6) Reclaimed water shall at all times be adequately disinfected, oxidized, clarified and filtered. 7) The wastewater shall be considered disinfected if the median number of coliform organisms in the effluent does not exceed 2.2 total coliform MPN per 100 ml, as determined from the results of the last seven days for which analyses have been completed, AND if the number of coliform does not exceed 23 total coliform per 100 ml in any sample. 8) Higher value applicable only to irrigation of highway green belts, street islands and bushes and areas not accessed by the public.

Table F-3 Water Quality Standards for Direct Discharge to Coastal Waters

PARAMETER UNITS Maximum Allowable Monthly Average

PHYSICAL Floating Particles mg/m2 NIL NIL Temperature Δ°C ≤3 above ambient ≤3 above ambient Total Suspended Solids mg/l 15 - Turbidity N.T.U 75 50 CHEMICAL Aluminum mg/l 0.29 0.29 Ammonia, Total as N mg/l 3.0 1.0 Arsenic mg/l 0.5 0.1 Barium mg/l 2.0 1.0 BOD5 mg/l 25 15 Cadmium mg/l 0.05 0.01 COD mg/l 150 75 Chlorinated Hydrocarbons mg/l 0.5 0.1 Chlorine Residual mg/l 2.0 0.5 Chromium (total) mg/l 1.0 0.1 Cobalt mg/l 2.0 0.1 Copper mg/l 0.5 0.2 Cyanide mg/l 0.1 0.05 Fluoride mg/l 20 15





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PARAMETER UNITS Maximum Allowable Monthly Average Iron mg/l 10 5 Lead mg/l 0.5 0.1 Manganese mg/l 1.0 0.2 Mercury mg/l 0.005 0.001 Nickel mg/l 0.5 0.2 Nitrate mg/l 10 1 Oil and Grease mg/l 15 8 Oil (hydrcarbonated) mg/l 5 5 Oxygen - Dissolved mg/l 2.0 5.0 pH pH units 6 – 9 6 – 9 Phenols mg/l 1 0.1 Phosphorus, total as P mg/l 2 1 Salinity Δ ppt 2 1 SS mg/l 50 50 Sulfide mg/l 0.1 0.05 Total Kjeldahl Nitrogen (TKN) mg/l 10 5 Total Organic Carbon (TOC) mg/l 150 50 Zinc mg/l 5 1 BIOLOGICAL Fecal Coliforms MPN/100 ml 400 400 Total Coliform MPN/100 ml 2400 1000 Notes:

For any parameters not identified, specific standards will be determined on a case-by-case basis. Temperature standard does not apply to variance stream discharges. Chlorine residual is after 30 minutes contact and is total residual chlorine Dissolved oxygen requirement is a minimum concentration requirement

8.2 Medical Waste Management

Medical waste management will be managed by the medical facility provider as a part of the execution of their contract. It will be their responsibility to ensure that all waste containers are suitable for this type of waste, that these are correctly labelled, emptied regularly and disposed of to a suitable disposal facility.

Records shall be maintained regarding the quantity of hazardous medical wastes removed from the medical centres operating at the site during construction. They will also be required to comply with PME guidelines, 28 Rajab 1422 H (15 October 2001); Medical waste management.

8.3 Used Oil Management

Used oil shall be managed in accordance with the following requirements:

Used oil shall not be mixed with inflammable oils, any liquids containing halogen components or any other materials, particularly hazardous waste, as defined by the Saudi Presidency of Meteorology and Environment (PME).





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Standard 200 – litre drums shall not be filled more than 50% of capacity with used oil due to handling safety considerations. These should be stored in contained / bunded areas.

Waste oil storage tanks may be used, provided that these are contained within an impervious bunded area meeting the required containment capacity.

Used oil shall only be transported by carriers authorized by the Saudi PME and are required to show proof of this authorization.

Producers and transporters of used oil shall maintain a Waste Log (Exhibit F – 1).

No used oil shall be disposed of in the sewer systems, on the ground, Kingdom’s territorial waters, or its exclusive economic zone.

Contractors generating used oil shall verify their used oil is only transferred to treatment units authorized by the PME, particularly, those guidelines listed under, 28 Rajab 1422 H (15 October 2001); Used Oil Management. Contractors will supply a copy of the verification documentation to Bechtel. Used oil shall be recycled whenever possible.

9. TRAINING During Project Environmental Awareness Training, all Project personnel will receive an overview of project waste management requirements. Additionally, Supervisors and personnel that routinely work with hazardous wastes will receive additional specialized training detailing handling, segregation, labelling, storage, spill response, and disposal requirements.

10. INSPECTION REQUIREMENTS Contractors supervisors are required to undertake inspections of their own job sites to ensure the following aspects are managed in accordance with this field instruction:

Housekeeping and maintenance of waste storage and handling areas;

Provision and maintenance of waste receptacles;

Compliance with waste segregation and recycling requirements;

Bechtel Supervisory staff is also required to undertake surveillance of Contractors waste management activities.

Where any deficiencies in works contractor waste management standards are noted, these shall be recorded and reported to the responsible Contractor supervisor for action and shall be recorded on the Ras Az Zawr Job-site inspection report. Any close out actions agreed shall be recorded for follow up action by the ES&H department. Contractors are required to promptly correct any deficiency observed in inspections and confirm close out to the Bechtel supervisor.

In order to assure implementation of this field instruction, the Bechtel CEC shall complete a review of Contractor environmental compliance during site environmental tours.





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11. REPORTING AND RECORD KEEPING All incidents where oil or hazardous materials are spilled or otherwise released, within project work, laydown, or maintenance areas will be reported in accordance with the Spill Prevention and Response Plan.

The transport of all waste will be documented using a Waste Log (Exhibit F-1) or Consignment Note. Contractors may use their own waste log as long as it contains the following information:

Unique container ID number

Description of waste;

Quantity removed (kg, litres, or units);

Name of Contractor transporting the waste;

Date & time transported off-site;

Recipient of waste (e.g., used oil treatment unit);

Driver/Vehicle registration; and

Verification signature.

This Waste Log will be used in conjunction with a “Property Removal (Gate) Pass” as contained within the Project Security Plan for wastes removed by contractors prior to the general wastes contract being awarded and for those contractors not covered by this i.e. Village construction wastes and wastes from Village operations (including STP).

Waste “Delivery Confirmation” is required for all the wastes which will be sent off-site to third party facilities.





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Exhibit F-1 – Waste Log

Contractor’s Name: _____________________________________________________________ Driver/Vehicle registration _______________________________________________________ Log Verified by (name & signature):________________________________________________

NO. Time & Date

(Transported

Off-Site)

Type of Waste (See Exhibit 2)

Container ID #

Quantity (kg, litres)

Waste Recipient (e.g., landfill name, used

oil treatment unit)

Disposition (Reused, Recycled,

Disposed of, Stored)

1

2

3

4

5

6

7

8

9

10

11

WASTE SUMMARY

Type of Waste Total Quantity Unit of

Measure Comments

Domestic Refuse

Non Hazardous Industrial

Hazardous

Total Recycled

Total Reused

Total Stored

Total Disposed Of





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Exhibit F-2 – Waste Categories

WORK PACKAGE NUMBER:

LOCATION DESCRIPTION:

GROUND MATERIALS (Check boxes for waste materials anticipated to be produced/disposed of)

CONTAMINATED SOIL YES NO

CLEAN SOIL YES NO

EXTRACTED GROUNDWATER YES NO

STORMWATER / SURFACE WATER RUN OFF YES NO

ASPHALT YES NO

ROCK OR GRAVEL YES NO

WASTE MATERIAL

OIL YES NO

GENERAL WASTES INC. DOMESTIC WASTE, FOOD, OFFICE WASTE ETC. YES NO

STEEL & NON-FERROUS METALS YES NO

WOOD YES NO

PAPER YES NO

CARDBOARD YES NO

LUNCHROOM / ORGANIC WASTE YES NO

ALUMINUM YES NO

CLEARING AND GRUBBING WASTE (ORGANIC WASTE/WOOD ETC) YES NO

CONCRETE WASTES YES NO

DEMOLITION WASTES (LIST SPECIFIC TYPES OF WASTE BELOW) YES NO

CONSTRUCTION/PROCESS MATERIALS

USED SOLVENTS/CHEMICALS REQUIRING SPECIALIZED DISPOSAL YES NO

PAINT CANS/AEROSOLS/CONTAINERS FOR HAZARDOUS MATERIALS YES NO

SPILL RESPONSE YES NO

USED ABSORBENTS AND SPILL CLEAN UP EQUIPMENT YES NO

CONTAMINATED SOIL (WITH HYDRAULIC FLUID/OIL/FUEL ETC) YES NO

OTHER:





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DISPOSAL PLAN FOR ALL YES ITEMS:

ACCEPTANCE SIGNATURES

WORKS CONTRACTOR SIGNATURES: DATE:

ENVIRONMENTAL RELEASE SIGNATURE: DATE:

RTA APPROVAL SIGNATURE: DATE:

EPCM CONSTRUCTION SUPERINTENDENT SIGNATURE: DATE:





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Appendix H Environmental Inspection Reporting





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1. ENVIRONMENTAL INSPECTIONS AND REPORTING Environmental Inspections take place regularly across all areas of the site using the Environmental Inspection Report attached below and are carried out in conjunction with Health and Safety Inspections to ensure that all those required to attend the inspection walkover are available.

As a minimum each inspection will include a representative of the contractor working in the particular work area, the contract supervisor and a representative from Bechtel’s Environment Safety and Health team. Typically, however, there should be more than one representative from both the contractor and Bechtel ESH team in order to get the most from the walkover. A client representative may also attend these walkovers. Special attention should be paid to testing and monitoring the potable water and treated wastewater from sewage treatment plant qualities. The operator of these facilities on the construction site is responsible to provide periodic reports from a certified laboratory for quality of potable water and grey water if the latter is going to be used for irrigation or dust control purposes.

A summary of the walkover is provided at the conclusion of the inspection visit and mitigation measures and actions are discussed in detail so that issues can be rectified as soon as possible.

Any environmental risks and the associated corrective actions are formally communicated to the Contract Supervisor and Contractor Representative using the Environment Health and Safety Inspection Form (attached below). Others are copied in on this information as required.

The form is normally discussed at the start of each weekly contractor meeting to ensure that the relevant actions have been undertaken and a copy is attached to the meeting minutes for wider distribution.

The ESH Inspection Form combines the observations and expected corrective actions for Environment, Health and Safety into one document rather than duplicating this information in more than one form.





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ENVIRONMENTAL INSPECTION REPORT

Date: Time:

Inspector (Name/Title): _____________________________________ Weather: ________________ Areas Inspected: Infrastructure Potline Sewage Treatment Plant Port Facilities Cast House Water Treatment Plant Construction Village Carbon Refinery

ACCEPTABLE REMARKS ITEM INSPECTED Yes No

Solid Waste Storage

Recyclable Waste Storage

Trash Bins Condition

Hazardous Material Storage

Hazardous Waste Storage

Vehicle Maintenance Areas

Dust Controls

Storm water/Sediment Basins and Outfalls

Waste Log

Erosion Controls

Evidence of Spills

Equipment Spill Kits

Were Contractor Daily Inspections Performed?

Toilets/Septic System

OTHER ITEMS INSPECTED:

ADDITIONAL COMMENTS:

Signature: ____________________________ Date: ___________________

ATTACH TO WEEKLY CONTRACT INSPECTION REPORT


Bechtel Confidential Contains Bechtel and its affiliated companies confidential and/or intellectual property which shall not be used, disclosed or reproduced in any format by any non-Bechtel Party without Bechtel’s prior written

permission. All rights reserved. Saudi Arabian Mining Company (Ma’aden) shall have an unconditional perpetual, royalty-free, freely sub-licensable and assignable license to use such intellectual property for all purposes in connection with the Project.

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RAS AZ ZAWR ALUMINIUM SMELTER PROJECT

ENVIRONMENTAL, HEALTH AND SAFETY INSPECTION FORM

Date: Contractor: Area:

Bechtel Leadership Inspection Team: Contractor Inspection Team:

Please a √ in the box for areas WELL DONE and an X in the box for areas requiring IMPROVEMENT Risk Assessment Mobile Plant Heat Stress Manual Handling Electrical Safety Tagging of Plant

Methods of Work Plant Log Nooks Hot Work Load Electrical Equipment Condition of Equipment

Qualified for task Elevating Work Platform Fire Extinguishers Vision obstructed Tagging First Aid Facilities

Permits Cranes Welding and Cutting/Oxy Isolation & Lock Out Work at height Amenities

Access Fork Lift Excavation Permits/System Fall potential Hygiene

Housekeeping PPE Barricade Compliance Scaffolding/Ladders Safety Signage

Trip Hazards Condition Benching/shoring Tags and Lock Fall Arrest Equipment Clamps/safety pins

Uncontrolled Waste Selection & use Access Understanding/Training Environment

Positive Safety Reinforcement (i) (ii)

No.

Location Hazards/Risks

(Unsafe Conditions) Priority L/M/H

Improvement Requirements Action By Action When

Copy to: Bechtel ESH Department. Area Manager, Contractor





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Appendix I GHG Tracking Procedure





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1. INSTRUCTIONS The following information will provide general guidance on how to collect the data required for calculating each of the contractor’s activities carbon footprint:

1 - The GHG Data Form shall be reviewed by the contractors to become familiarize with the information required to gather and report. The contractor does not need to collect data on a daily basis but instead provide a total value at the end of the period.

2 - If required, the contractor shall designate one person who will need to work on GHG Tracking to ensure that all the data for the following: energy use, fuel use, water use and waste generated/disposed will be captured during the project’s life. If there are areas where all the data can not be captured (e.g. fuel used by subcontracted equipment managed by the subcontractor) reasonable assumptions shall be taken and necessary explanation should be provided in the box marked “Notes/Comments” on the form provided here.

3 - Required data shall be collected and reported monthly with the presented form. The deadline for submission is 5th of each month. Carbon emissions equivalents will be calculated by Bechtel and raw use data are only required to be provided in the forms.





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GHG Data Form

PROJECT INFORMATION

Location/Region:

Project’s Name:

Contractor’s Name:

Contractor’s Responsibility:

Report Prepared By: Date :

DATA TRACKING INFORMATION

Start Date: End Date:

Number Buildings: Approximate Work Force:

Approximate Site Size:

(Please provide unit)

Approximate Stage of Construction:

Project Notes:

TACKING DATA

Power Use

What is the primary power supply source?

(e.g. Grid, Power Station, Generator, etc.)

What is the energy source for your power?

(e.g. Coal, Natural Gas, Wind, Hydro, etc.)

What is the total power use for the project?

(Please provide the results in kWh)

Comments/Notes on Power Use:





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FUEL USE

Please complete the table below for all fuels used on site:

Fuel Type Amount Used Units (gal, L) Notes/Details

Diesel

Natural Gas

LPG

Kerosene

Propane

Petrol

Other

Are there any other sources of fuel use that have not been captured in the above table? If yes, describe:

Comments/Notes on Fuel Use:

WATER USE

What is your total water use for the period?

(Please provide results in gal, L or m3)

List the primary areas where your greatest water use occurs (e.g. batch plant, showers, etc):

Comments/ Notes on Water Use:

WASTE

Please Complete the table below for all the waste generated based on your activities on site:

Generated Recycled Waste Type

Quantity Units Quantity Units Notes on disposal method

Aerosol Cans

Aggregate

Aluminium

Aluminium Cans

Batteries





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Branches

Cardboard

Contaminated Soil

Copper

Copper Wire

Corrugated Box

Fibreboard

Fly Ash

Food Waste

General Waste

Glass

HDPE

LDPE

Lumber

Magazines

Mixed Paper Board

Mixed Paper

Mixed Metals

Mixed Plastics

Mixed Organics

Mixed Recyclables

Office Paper

Oil Drums

Oily Filters

Oily Rags

Oily Water

Paint Cans

PET

Phonebooks

Steel

Steel Cans

Tires

Waste Oil

Other…

Does the above list capture all of your waste?





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How do you dispose the waste?

(Landfill, Incinerate, Recycle, Burnpit, Compost, Other(Please Indicate))

Comments/Notes on Waste Generation:

Project CECP.pdf

Documents

project environmental

environmental requirements

project description

project manager

bechtel confidential

general project information

nonbechtel party

site description