Health, Safety and Environmental Policy s5

June Origination Date: October 7, 2011 Revision Date: 2012 Release Authorized by: Danny Trahan, Safety Director Manual Rev 4

ENVIRONMENTAL MANAGEMENT & GENERAL WASTE MANAGEMENT

TABLE OF CONTENTS [Alt + Right/Left = Page Forward/Back] PURPOSE...... 1 SCOPE...... 5 APPLICATION...... 5 DEFINITIONS...... 5 1.0 INTRODUCTION...... 5 1.1 Environmental Management Objectives...... 6 1.2 Program of Work...... 6 2.0 POLICY...... 6 3.0 RESPONSIBILITIES...... 6 3.1 Whole Project Team...... 7 3.2 P2S...... 7 3.3 P2S Project Manager...... 7 3.4 Client...... 7 3.5 Contractors...... 8 3.6 The Project Team...... 8 4.0 SITE LOCATION AND DESCRIPTION...... 8 5.0 ISSUES OF CONCERN...... 8 5.1 Water Quality...... 9 A. Introduction...... 9 B. Legislation and Project-Specific Requirements...... 9 C. Possible Risks...... 9 D. Background Data...... 10 E. Mitigation Measures...... 10 F. Environmental Protective Measures...... 13 G. Monitoring...... 13 5.2 Air Quality...... 14 A. Introduction...... 14 B. Relevant Legislation and Guidance...... 14 C. Possible Risks...... 14 D. Mitigation Measures...... 14 E. Monitoring...... 16 5.3 Noise and Vibration...... 16 A. Introduction...... 16 B. Possible Restrictions...... 16 C. Background information...... 16 D. Relevant Guidance...... 17 E. Possible Risks...... 17

Copyright © 2012, P2S. All Rights Reserved. P2S Health, Safety & Environmental Page 1 of 36 June Origination Date: October 7, 2011 Revision Date: 2012 Release Authorized by: Danny Trahan, Safety Director Manual Rev 4

F. Vibration and Noise Management Objectives...... 17 G. Mitigation Measures...... 17 H. Monitoring...... 19 I. Environmental Protective Measures...... 19 5.4 Waste Management...... 19 A. Introduction...... 19 B. Relevant Legislation and Guidance...... 20 C. Waste Minimization...... 20 D. Control Measures...... 20 E. Aerosol Can Disposal...... 21 F. Environmental Protective Measures...... 21 G. Monitoring...... 22 5.5 Traffic Management...... 22 A. Introduction...... 22 B. Relevant Legislation...... 22 C. Management Measures...... 23 D. Monitoring...... 23 5.6 Contaminated Land...... 23 A. Introduction...... 24 B. References...... 24 C. Relevant Legislation and Guidance...... 24 D. Mitigation Measures...... 24 E. Monitoring Requirements...... 25 5.7 Public Relations...... 25 A. Introduction...... 25 B. Responsibilities...... 25 C. Management Measures...... 26 D. Complaints Register...... 26 5.8 Flora, Fauna, and Natural Features...... 26 A. Introduction...... 26 B. Relevant Legislation...... 26 C. Baseline Data and Sensitive Receptors...... 27 D. Management Measures...... 27 5.9 Visual Intrusion...... 28 A. Introduction...... 28 B. Management Measures...... 28 5.10 Archaeology...... 29 A. Introduction...... 29 B. Relevant Legislation and Guidance...... 29 C. Baseline Data...... 29 D. Management Measures...... 29 5.11 Worksite Housekeeping...... 29

A. Introduction...... 29 B. Management Measures...... 29 C. Housekeeping...... 30 D. Order and Arrangement...... 31 E. Personal Pathways...... 31 F. Aerosol Can Storage...... 32 5.12 Emergency Response Plans...... 32 A. Introduction...... 32 B. References...... 32 C. Reporting Requirements...... 32 D. Management Measures...... 33 E. Documentation...... 34 6.0 AUDITING AND REPORTING...... 34 7.0 RECORDS...... 34 8.0 TRAINING...... 35 8.1 Environmental Awareness/Orientation...... 35 8.2 Environmental Management Training...... 35 A. Responsibilities...... 36 B. Positions...... 36 9.0 REFERENCES...... 37 10.0 ATTACHMENTS...... 37

PURPOSE This practice defines the basic requirements for environmental management controls to mitigate potential environmental impacts at P2S project sites. This practice applies to NEW Construction Management.

SCOPE This practice includes the following major sections:  Introduction  Policy  Responsibilities  Site Location and Description  Issues of Concern  Water Quality  Air Quality  Noise and Vibration  Waste Management  Traffic  Contaminated Land  Public Relations  Flora and Fauna  Visual Intrusion  Archaeology  Housekeeping  Emergency Response Plans  Auditing and Reporting  Records  Training

APPLICATION This practice applies to work activities and employees under the control of P2S and its contractors.

DEFINITIONS Environmental Incident – An adverse impact on the environment wholly or partially resulting from an organization’s activities, products, or services.

1.0 INTRODUCTION

P2S has overall responsibility for the development and implementation of an environmental management plan (EMP) for each project. However, the client maintains responsibility for site-specific conditions and contaminants that were present on the site before P2S’s arrival (such as contaminated soil); thus, the client may require the

ENVIRONMENTAL MANAGEMENT & GENERAL WASTE MANAGEMENT project to “adopt” or work under the client’s EMP and identify unique controls or actions in job safety analyses (JSAs), safety task assignments (STAs), or other project work plans.. P2S and contractors will be required to include environmental controls to mitigate potential environmental impacts, prevent pollution, and provide sufficient equipment and resources to effectively implement the requirements of the EMP. On top of the applicable legislation, this document identifies relevant environmental protection that is applicable to all P2S projects and any other commitments. It details action to be taken to meet the target of 100 percent environmental compliance.

1.1 Environmental Management Objectives

Objectives for environmental management will be included in the project-specific EMP. Issues that could be considered include the following:  Target 100 percent environmental compliance  Target no environmental complaints  Noise levels  Minimum impact on the surrounding environment  Maximum reinstatement of original environment after construction – particularly appropriate for pipeline projects  Maximum recycling of materials

1.2 Program of Work

Project Management must prepare an overview of the work and identify the elements of this work for which P2S is responsible, and which elements may have been completed before P2S starting work at the site.

2.0 POLICY

P2S expects all parties involved in projects to comply with all applicable HSE legislation as a minimum. The adoption of best practice will be positively encouraged, and all parties will be required to demonstrate their application of best practice and innovation in order to reduce adverse environmental impacts.

3.0 RESPONSIBILITIES

For each project, it is necessary to specifically define which party is responsible for the following:  Submitting appropriate applications  Obtaining appropriate licenses  Communicating with the relevant authorities regarding use of licenses and any environmental incidents that occur

3.1 Whole Project Team

The client, P2S field execution and contractors and their management, supervisory, and field execution/commissioning staff are collectively responsible for executing their work in a manner that prevents environmental harm. They will identify at the earliest opportunity any deterioration of the target of 100 percent compliance and instigate any remedial action necessary.

3.2 P2S

P2S (or as indicated in contractual language) has overall responsibility for overseeing that the EMP is fully implemented for the duration of the construction works. P2S is also responsible for auditing the implementation of the EMP to verify that agreed environmental objectives are achieved. If the EMP is found not to achieve stated objectives, P2S will have overall responsibility for changes in working practices to meet the objectives, in consultation with the client. P2S will keep a record of all environmental incidents and remedial action taken in an incident logbook (refer to Form 000.653.F0193, Project Incident Logbook). Recommended action to prevent recurrence will be detailed and brought to the attention of the workforce. All incidents will be discussed with the client and at weekly coordination meetings.

3.3 P2S Project Manager

P2S’s Project Manager has overall responsibility for HSE matters on the project. These responsibilities include the following:  Effective implementation of the EMP, including training, site inspection, and audit coordination.  Inclusion of relevant environmental provisions into contractual documents for contractors’ activities.  Informing contractors of their duties in relation to environmental protection.  Liaison with the client over consent applications, licenses, permits, and specific environmental incidents.  Coordination of investigation and response to environmental complaints relating to the performance at the site.  Implementing and maintaining the appropriate actions and controls during project execution.

3.4 Client

The client has overall responsibility for the site and is responsible for all communications with third parties, including the relevant authorities and neighbors. The client is responsible for providing P2S with all relevant information pertinent to the project such as previous environmental investigations and assessments, including baseline studies.

3.5 Contractors

Before commencement of any work, contractors will submit procedures or plans, including the measures that will be taken to protect the environment, for acceptance by P2S and the client. All contractors and their employees will be responsible for implementing and maintaining the provisions of the EMP that are relevant to their particular activities during their work at the site.

3.6 The Project Team

The following information should be maintained in a readily available location for each of the site owner, client, P2S Project Management, HSE Representative, Engineering, and Construction Manager:  Name  Location  Telephone number  Facsimile number

4.0 SITE LOCATION AND DESCRIPTION

Environmental aspects of the site and its surroundings must be evaluated including the following:  Surface water  Draining and discharge of water  Ecological value, nature reserve value, and protected areas  Agricultural value  Archaeological/historical value  Soil composition  Previous land use and associated impacts  Previous environmental inspection reports  Groundwater conditions  Underground composition  Environmental features that require protection

5.0 ISSUES OF CONCERN

Environmental issues of concern must be identified for the project/site. If an Environmental Impact Assessment (EIA) has been undertaken as part of the project, it will provide the basis of the evaluation. If an EIA has not been undertaken, then previous reports on site conditions and client information should be used to identify the site- specific environmental issues of concern. The environmental and management issues that should be specifically considered include the following:  Water quality  Air quality, including dust, emissions, and odors  Noise and vibration  Waste management

 Traffic management  Contaminated land  Public relations and liaison with consultees  Wildlife, flora and fauna, and natural features  Archaeology  Visual intrusion, signage, and lighting  Worksite housekeeping  Emergency response plans

For sites with no formal EIA, the following documents may be used to evaluate environmental issues:  Previous reports on environmental risk assessments  Environmental investigation reports  Environmental sampling reports  Monitoring results  Conditions to discharge  Contaminated soil reports  Waste categorization

5.1 Water Quality

A. Introduction

Activities that have the potential to affect water quality of controlled water sources in the vicinity of P2S-managed activities at the site, namely perched water tables, groundwater, surface water dikes, lakes, and rivers must be identified. It is vital that surface water and effluent discharges are properly managed and controlled to protect the environment. Any pollutants getting into a surface water dike, surface water drain, or groundwater could enter lakes and rivers. B. Legislation and Project-Specific Requirements

Project Management must evaluate legislation for applicability to the site; this activity should be done well in advance of work starting on site. This evaluation should also include project-specific requirements such as permit conditions and client specifications. This action will identify any specific requirements that can be incorporated into the design of the facility and the project-specific EMP. C. Possible Risks

Project Management must list the possible risks that exist due to the nature of the site and the nature of the construction activities proposed on the site. Risk may include the following:  Lateral migration of contaminants already in the soil into the nearby sensitive receptors (such as surface water dikes, rivers, and lakes.)  Movement and storage of contaminated soil causing contamination

 Contamination of groundwater during earthwork operations  Migration of leached contaminants arising from the reuse of crushed demolition materials  Discharge of effluent from wheel washing or other cleaning processes  Discharge of pumped groundwater from dewatering or excavations  Incorrect disposal of storm water and other silty waters  Spillages of pollutants due to bad storage and handling of materials, or inadvertent disposal to surface water drains rather than sewer  Washout from concreting operations.

Listed below are typical questions that the project team should consider in developing the potential risk:  Is the groundwater under the site subject to some tidal influence?  Can contamination of the site potentially cause harm to sensitive receptors in the vicinity?  Does the groundwater and/or the surface water on the site contain levels of some materials in excess of legal standards?

D. Background Data

If it exists, Project Management must provide data on existing water quality and levels around the site. Management must provide details of the location of existing local watercourses and mark the position of surface water drains and sewers on site, using color-coding to distinguish them. E. Mitigation Measures

P2S and contractors are specifically required to implement pollution prevention measures, based on the potential risk identified in Paragraph C above. Typical mitigation measures based on the potential risks must be identified. Some examples are provided below.

GROUNDWATER  No groundwater will discharge from the site to controlled water unless this has been previously agreed to with the relevant authorities and the relevant permissions are in place and the composition of the groundwater can be discharged within the conditions of the permission.  If it is necessary to dewater the site to allow field execution operations to be undertaken, an appropriate approval must be obtained from the local authorities.

SURFACE WATER/CONTROLLED WATER PROTECTION  If discharges need to be made from the site, including the storm water runoff, the appropriate permits need to be sought from the local authorities, notifications filed,

and the discharges need to be made within the conditions of the permit. Monitoring may be a requirement of the permit conditions.  Management and control of surface waters on the site should eliminate the potential for contaminated runoff to impact local water quality. Water collection systems should be adequately sized to allow for the controlled release of storm flows. Silty water disposal measures should be reviewed and accepted by the local authorities. A Storm Water Pollution Prevention Plan may be required before commencement of construction activities.  Suitable protective measures must be installed around open sections of surface water to prevent surface water ingress into the construction area.  Collection of any soil arising from construction before offsite disposal should be well away from any surface water and should be arranged in such a way as to minimize the potential generation of leachate.  Minimize the potential for lateral migrations of contaminants into nearby sensitive receptors by minimizing the time excavations are open.

FUEL/CHEMICAL STORAGE  Development of a dedicated fuel/chemical storage area must provide for adequate containment.  Environmental protective measures in relation to work involving the use, movement, and storage of fuel or chemicals will be fully documented and accepted by P2S before the commencement of work.  Fuel storage areas will be surrounded by secure impervious dikes providing a containment capacity of at least 110 percent of the largest tank or 25 percent of the total capacity of the tanks, whichever is the larger. All associated valves and pipework must be contained within the dike.  Fuel storage facility must be inspected on a daily basis by the owner of the facility.  Dike water must be tested before pumping and be disposed in agreement with the client and the local authorities.  The design of the fuel storage facility will incorporate a roof structure to prevent rainwater accumulation.  All hazardous materials, including chemicals, paints, cleaning agents, solvents, and solvent-containing products will be properly sealed in containers at the end of each day by the contractor before storage in appropriately protected and diked storage areas.  Appropriate spill containment equipment will be stored on site, local to points of material storage and use as appropriate.

VEHICLE REFUELING  P2S (or as indicated in contractual language) will review and authorize any fuel and refueling activities on the site required by P2S or its contractors. Contractors are responsible for compliance with client and P2S EMP, HSE plans, and regulatory standard.

 Refueling and tank filling will be carried out in designated protected refueling areas, except where the nature of the machinery makes this impractical.  Double-walled self-contained fuel tanks and pumps will be used for refueling of equipment where use of dedicated refueling area is impractical.  During the process of refueling, a fuel spillage kit must be available in order to contain any spillage and prevent contamination.  An emergency spill kit containing sand or suitable absorbent materials must be kept readily available in case of spillage in the main fuel storage area.  Fueling stations must be equipped with an automatic shutoff mechanism.  Trained personnel must supervise refueling operations.  Valves and taps must not be left open when unattended and must be locked when not in use.  Persons carrying out refueling will to be made aware of the requirements listed in this practice and be trained in the use of spill kits and emergency procedures.

EQUIPMENT AND MAINTENANCE  Small items of equipment such as pumps and generators must be placed on a suitable “drip tray” in order to contain any spillage and leakage.  Equipment with visible leakage must not be used on site. It must be removed for maintenance or repaired in-situ, if necessary, to prevent pollution caused by removal.  If there is insufficient space on site to provide a dedicated area for the maintenance of equipment, then wherever possible, emergency equipment repair and essential maintenance must be undertaken within a temporarily protected zone constructed within the immediate area of the equipment to be repaired or maintained.  A temporarily protected zone can be constructed by forming a spillage containment area using sandbags to form a dike wall of sufficient height to contain twice the maximum possible spillage that could occur, with an internal heavy gauge polyethylene liner overlaid with a sand mat or timber grillage onto which the item of equipment can be placed to undertake the maintenance or repair required.  For larger heavy items of equipment such as crawler cranes and earth-moving equipment, repair/maintenance can be undertaken in-situ provided localized containment of spillage is provided and an adequate number of emergency spill kits are available.  Should any contaminant spillage occur outside of a protected zone, the contractor will be responsible for containing the spillage and disposing of any waste and contaminated soil off site in compliance with the relevant legislation and the project procedures.

WHEEL WASHING If required by the local authorities and/or the client, permanent wheel-washing facilities will be provided at the site, as described below:  Provision of suitably sized settlement tanks to enable settlement of suspended solids from wheel-washing activities will be made.  A permanent wheel-washing facility will be installed with water-recycling units.  Periodic removal and disposal of contaminated sludges/waters will be arranged to maintain the effectiveness of the units. All materials will be disposed at a licensed waste disposal facility via a licensed hauler.

ROAD SWEEPING  Sweeping and cleaning of the public or client roads immediately adjacent to the site will be undertaken on a regular basis or as deemed necessary to prevent nuisance or hazards to other road users. Collected debris will be disposed at a licensed waste disposal facility.  In dry weather, mud and oils can build up on areas of hard standing. If these areas are not cleaned frequently, a sudden shower can wash mud and oils into watercourses, giving high-pollutant loads; therefore, hard standing and surface roads will be kept swept clean.

CONTAMINATED WATER DISCHARGE Potentially contaminated wastewater will be discharged to an appropriate treatment system or to an approved sewer system. Site drainage will be coded in accordance with local and/or client requirements for easy identification. Identification may be based on color. F. Environmental Protective Measures

 Before commencement of work, P2S Construction Management and contractors will submit environmental protective measures that will be taken to protect the environment, for approval by P2S Project Management and the client.  Environmental protective measures in relation to work involving the use movement, and storage of fuel or chemicals will be fully documented and accepted by P2S before commencement of work.

G. Monitoring

Regular inspections of all discharges, drainage systems, collection ditches, lagoons, interceptors, and watercourses will be undertaken to check that these items are in good order.

5.2 Air Quality

A. Introduction

Those activities that have the potential to affect local air quality and cause environmental nuisance to local residential and surrounding areas must be identified. Project Management must adopt appropriate control measures to mitigate these impacts. Dust, emissions and odors can adversely affect air quality. B. Relevant Legislation and Guidance

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on site. This evaluation should also include project-specific requirements such as permit conditions and client specifications. This action will identify any specific requirements that can be incorporated into the design of the facility and the EMP for the site. C. Possible Risks

Dusty emissions escaping the site may cause nuisance through surface impact, loss of visual amenity through deposition, and effects on flora and fauna. The most prominent cause for concern to the surrounding land users is likely to be dust and may arise from activities such as the following:  Demolition  Site preparation  Excavation  Earth movements  Air pollution from poorly maintained vehicles and equipment  Poorly maintained unpaved roads

D. Mitigation Measures

P2S and contractors are specifically required to implement pollution prevention measures, based on the potential risk identified above. Typical mitigation measures based on the potential risks must be identified. Listed below are some examples of typical mitigation measures:  Since it is difficult to suppress dust once it is airborne, it is preferable to prevent dust from being generated in the first place, where possible.  Control measures and dust suppression techniques are to be implemented in order to protect the health of site workers and the general public and to comply with occupational exposure standards.  Plan, locate, and control worksite activities that have the potential to generate dust or smoke so that nearby sensitive receptors are not adversely affected.  Consider additional protection measures such as screening and covering and implement as appropriate.

 Enclosed chutes will be used for dropping to ground level demolition materials that have the potential to cause dust.  Crushing equipment will be kept away from sensitive areas.  During earthworks and excavations, the area will be kept damp during dry weather and will be re-vegetated, sealed, or completed as soon as possible.  If needed, an appropriate wheel-washing facility will be maintained at the site to minimize and reduce the risk of dust emissions and deposition of material on the public roads. This facility will operate for the duration of work at the site as deemed necessary to control dust emissions and nuisance.  Contractors and employees will be informed during orientation and further training about the need to minimize dust emissions to neighboring property and residents and of the health hazards associated with exposure to emissions.  Equipment and vehicles will be maintained in good repair and conform to the relevant legislative requirements and emission standards. Mitigation measures could include low-sulfur fuels, soot filters, and catalytic emission controls as specified by project- specific requirements. The use of vehicles and equipment that fails to meet emission limits will not be permitted until such time as they have been serviced and re-tested. P2S will maintain records of equipment maintenance and defect reports.  Vehicle exhausts will be directed vertically upwards where possible and directed away from the ground as a minimum. Stationery equipment will be placed as far from inhabited buildings as possible.  Wherever possible, vehicles and equipment will not be left running for long periods when not directly in use. Where appropriate, electrically powered equipment will be used instead of gasoline or diesel powered equipment.  Stationery equipment will be located as far from sensitive receptors and inhabited buildings as is reasonably practical.  Vehicles transporting materials, capable of generating dust, to and from site will be suitably covered on each journey to prevent release of materials and particulate matter. The sheeting material will be maintained in good order, free from excessive rips and tear.  Speed limits on unpaved surfaces will be set to minimize dust generation where practicable. In populated areas, maximum speed limits will be set to minimize exposure.  Unsurfaced roads will be routinely dampened especially during dry periods and according to weather conditions.  Where haul routes run over materials with a high dust-raising potential that cannot be satisfactorily controlled by watering or other methods, temporary surfacing will be considered by P2S.  Burning of wastes or unwanted materials will not be permitted on site.  Hazardous materials including chemicals, paints, cleaning agents, solvents, and solvent-containing products will be properly sealed in containers at the end of each day by the contractor before storage in appropriately protected and diked storage areas.

 Where it is necessary to use soil stockpiles, they will be kept to the minimum number and size practicable, and gentle slopes will be used. They will be kept out of the wind if possible, and if necessary compacted and the surface covered.  Materials will be stored away from the site boundary and downwind of sensitive receptors.  Large quantities of concrete will be mixed in enclosed/shielded areas. Where necessary, vacuuming will be used in preference to blowing to remove dirt before concrete pours.  Dust extractors will be used to minimize dust from cutters and saws, as necessary.

E. Monitoring

Whether or not quantitative dust monitoring is required on the site, it is recommended that P2S management/supervision maintain a daily log that notes weather conditions, field activities, their location on site, and visible dust-generating activities. Photographic records will be kept of dust control measures employed. If monitoring is required, the type and method should be documented. It is important that the monitoring is undertaken upstream and downstream of the field activities to allow the impact to be properly assessed. It is preferable to establish baseline monitoring during the same seasons before the start of field work, if problems are envisaged.

5.3 Noise and Vibration

A. Introduction

Activities that have the potential to cause environmental nuisance to client operations, local residents, local wildlife, and surrounding commercial activities must be identified. The adoption of appropriate control measures, monitoring, and close liaison with the client will assist in the mitigation of these impacts. B. Possible Restrictions

Project Management must list any site-specific restrictions to noise and vibration management. Listed below are examples of possible restrictions:  Operations that are audible at the site boundary will be carried out only during designated hours.  General accepted practicable means to reduce noise to a minimum will be employed.  Equipment and machinery in use will be properly silenced and maintained in accordance with the manufacture’s instructions.  Any emergency deviation from these conditions will be reported to P2S Project Management without delay.

C. Background information

Background noise levels should be obtained, if appropriate, before field operations begin. The methods of monitoring and the locations for monitoring should be determined based on relevant local guidance and the proximity of local sensitive receptors, using local consultants as appropriate.

If the proposed field methods are likely to give rise to vibration, it is useful to survey sensitive locations and structures before the start of work. D. Relevant Guidance

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on site. This action will identify any specific requirements that must be incorporated into the design of the facility and the EMP for the site. E. Possible Risks

Possible risks that exist due to the nature of the site and the nature of the activities proposed on the site must be listed. Risk may include the following:  Earthworks  Excavations and groundworks  Breaking out with pneumatic tools  Falling-ball demolition  Piling and structure works  Fabrication and assembly of structural steel  Transportation

F. Vibration and Noise Management Objectives

Vibration and noise management objectives must be listed for the project. Some typical points at which noise limits may be set are:  65 dBA(A) at a distance of 3 feet (0.9 meter) from existing building facades  75 dBA (A) at the site boundaries neighboring roads and car parks  80 dBA(A) at all other site boundaries

G. Mitigation Measures

The following factors influence noise levels at a given point:  Planning  Execution method  Execution sequence  Tool and equipment selection

P2S and contractors will be specifically required to implement noise/vibration prevention/mitigation measures based on the potential risk identified above. Mitigation measures fall into a number of categories namely:  Effective site management  Engineering control  Acoustic screening  Restricted hours of working

 Liaison with the local community  Provision of sound insulation  Noise monitoring  Vehicle speed restriction

Some examples of typical mitigation measures include the following:  Keep neighbors informed regarding the work that is to be undertaken on the site and the associated duration.  Before commencement of particularly noisy operations, a plan detailing the method of works, program of work, predicted noise levels, and manufacturer’s specifications for equipment and machinery will be submitted to Project Management and the client for acceptance.  P2S, before work commences, will assess particularly noisy operations and their timing and scheduling.  Consideration will be given to reducing noise by undertaking noisy assembly practices off site where practicable.  Where appropriate, noise-reduction methods (such as fencing or stockpiles for screening) will be used. These methods will be maintained for the duration that they are required.  Particularly noisy activities will be limited to certain periods of the day where appropriate.  Vehicles, compressors, and mobile equipment will be equipped with effective silencers and noise-reducing insulation.  Work practices will be adopted such that noise emissions are kept to a minimum, (equipment not in constant use will be switched off, excessive revving of vehicles will not be permitted, and noise suppressions covered will be closed at all times).  Where possible, noisy equipment will be located away from sensitive noise boundaries. Where this is not possible, noise emissions will be controlled by the erection of acoustic shielding, or sitting behind site accommodation or spoil heaps as appropriate.  Loading and unloading of vehicles, dismantling of site equipment such as scaffolding, or moving equipment or materials around the site will be conducted in such a manner as to minimize noise generation and where possible will be conducted away from noise sensitive areas.  If elevated noise or vibration levels are encountered, the source of noise or vibration is to be identified and alternative methods or additional control measures will be implemented.  A maximum speed limit of 10 mph (16.1 kph) will apply on the site for the safety of the workforce and to minimize disturbance from noise and dust.  Where possible, electrically powered equipment will be used in preference to diesel or gasoline powered equipment, as it is quieter.  Mobile equipment and machinery will be properly maintained to minimize noise generation.

 P2S will investigate noise complaints and excesses of agreed-to maximum acceptable levels immediately.  In the event of vibration becoming a concern, an assessment will be undertaken in accordance with applicable standards.

H. Monitoring

If required, regular noise monitoring will be performed at site boundaries, as agreed to with the client, and should take into account local requirements as documented in Section 5.3.B and Section 5.3.D. Monitoring should be required for the following:  Occupational exposure (noise and vibration)  Noise levels at the site boundary and sensitive receptors  Vibration levels at the site boundary and sensitive receptors

If vibration monitoring is required, it should be undertaken inside rooms when assessing for nuisance and measured on the structure outside when assessing for damage. For sensitive structures, visual monitoring and the measurement of crack widths is the best way to determine whether damage is being caused. I. Environmental Protective Measures

Before commencement of site work, P2S construction or contractors (as applicable) will submit a “noise management plan” covering their area of work for acceptance by P2S Project Management and the client. This plan must refer specifically to the area of development work concerned, the equipment to be used, the control measures to be used, and monitoring requirements. Before commencement of particularly noisy operations, environmental protective measures detailing the work process, program of work, predicted noise levels, and manufacturer’s specifications for equipment and machinery will be submitted to the client for acceptance. Deviation from client-approved environmental protective measures will occur only with prior approval from the client.

5.4 Waste Management

A. Introduction

P2S is responsible for implementing effective waste management at the site, complying with all waste management legislation, and introducing waste minimization objectives. The client maintains responsibility for site-specific conditions and contaminants that were present on the site before P2S’s arrival (such as contaminated soil). The client’s responsibility includes disposal of the soils or contaminants under the client’s site-specific waste disposal registration number (or EPA/state identification number, whichever is appropriate). The client retains ownership of these materials from generation through disposal. P2S’s name will not be noted on the waste manifest without Business Unit approval. Site Management and contractors and their employees will be responsible for minimizing the amount of waste produced by their activities, and are expected to fully cooperate with client requirements and legal requirements for waste minimization and proper handling, storage, and disposal of hazardous and nonhazardous wastes.

A principle objective of each project will be to reduce the amount of waste generated and exported from the site. B. Relevant Legislation and Guidance

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on site. This action will identify any specific requirements that can be incorporated into the design of the facility and the EMP for the site. In addition, for locations where hazardous wastes are to be tracked for proper disposal, the project should specify which party will be designated as the liable generator of such wastes related to construction of the facility. C. Waste Minimization

Waste minimization is a P2S objective and strategy for waste management. Site Management and contractors should consider the following:  Reuse of materials, reducing the need for the use of primary materials, through quarrying and mineral extraction (reducing the impacts associated with transport of both waste and primary materials)  Minimization of road transport, where possible.  Minimization of packaging materials, agreement with manufacturers and suppliers  Reuse of excavated soils generated by earthworks in development works  Onsite segregation, recycling, and processing of waste materials  Preferential energy recovery from any remaining wastes in lieu of landfill disposal, where practical

D. Control Measures

Project Management must list details of the project-specific control measures. Some examples of waste control measures are:  P2S will establish a dedicated area and implement a system for waste management and segregation of incompatible wastes. Waste segregation should occur at generation.  P2S Site Management and contractors will be required to maximize the opportunities for reuse and recycling of materials and to minimize waste.  P2S Site Management and contractors will produce a waste control plan detailing waste collection and removal from the site. The plan will identify where waste of different categories will be collected in separate stockpiles, bins, etc., and appropriate signage will be provided to clearly identify the category of each collection stockpile, bin, etc.  Hazardous wastes, as defined by the applicable regulations, will be stored separately from nonhazardous wastes in accordance with applicable regulations, project-specific requirements, and good waste management practices.  P2S Site Management and contractors will use provided disposal systems only after written authorization of P2S and the client.  Compliance with the appropriate waste management legislation covering the storage, removal from site, transport, and disposal of wastes is mandatory.

 Suitable protection measures will be incorporated in the design of the waste management areas to prevent pollution.  The P2S will inspect and manage the area to verify that stored wastes are covered to prevent accidental spills and wastes from being blown away. Any deviation from site standards will be immediately corrected.  Waste disposal containers will be appropriately labeled, and waste will be correctly segregated on site.  P2S Site Management, contractors, and employees will be required to use suitable, appropriately labeled containers that are maintained in suitable conditions for temporary waste storage.  P2S Site Management, contractors, and employees should be vigilant for the presence of additional hazardous waste that may have not been removed from the site during site preparation. Where suspected hazardous waste is identified, all activities in the vicinity will be suspended until P2S has carried out an inspection and defined an appropriate course of action.  Contaminated soil waste being collected before disposal will be stored so as to protect local surface water, minimize the potential for leachate formation, and minimize the potential for dust generation.  When leaving the site, haul truck loads will be covered with sheeting to prevent any escape of materials onto the public roadways.  The site must be left in a clean and tidy condition at the end of each working day.  Surplus materials and waste will be transferred to the waste management area.

E. Aerosol Can Disposal

At the time of disposal, any aerosol can that contains chemicals that would be a listed or characteristic hazardous waste is considered a hazardous waste container. If the can is empty – that is, it contains no propellant or product and is at atmospheric pressure – the can will not be regulated as hazardous waste and may be recycled as scrap metal or land-filled. Each site will collect empty aerosol cans at a central location approved by the client and Project Manager. A designated person will puncture the cans with an approved device designed for puncturing aerosol cans and collect the remaining propellant or product before disposal. Before the designated person punctures and collects the remaining contents of the can, they will ensure that the contents are compatible with the contents of the collection container. The recovered contents should be analyzed to determine if they are a listed or characteristic hazardous waste and labeled and disposed of accordingly. F. Environmental Protective Measures

P2S Site Management and contractors will be required to produce a waste strategy for acceptance by P2S Project Management and the client. The waste strategy must reflect the project aim of waste minimization and compliance with relevant waste management legislation. Details will be provided concerning estimates of waste quantities, waste characterization procedures, methods of processing and storage, the routes and destination of materials, the parties involved, and proposed end-use/disposal of materials.

Hazardous waste documentation requirements and identification of the responsible generator of such wastes (as applicable) will be described as defined in the project contractual agreements. In general, the client or property owner is normally the designated generator of hazardous construction wastes. P2S Project Management may elect a qualified, local waste management contractor for the day-to-day waste management activities at the site. G. Monitoring

The monitoring program should be approved by the client and should take into account requirements under applicable standards as documented in Section 5.4.B. Listed below are examples of the types of monitoring that could be required:  P2S will be responsible for implementing a program of waste monitoring to assess quantities and sources of waste. Contractors will be expected to contribute to the success of the waste monitoring and measurement program, and to seek to reduce, reuse, and recycle wherever possible.  P2S will regularly review the volumes and types of waste disposed as part of the overall assessment of the environmental performance of the site, and any significant changes will be investigated.  P2S may audit waste haulers and waste disposal sites to verify compliance with legislation. This audit may include random checks to verify waste is disposed correctly.  P2S Site Management and contractors will be required to provide P2S Project Management and the client with copies of all relevant waste management documentation/information.

5.5 Traffic Management

A. Introduction

Depending on the site location and the nature of the construction activities to be undertaken, there are a number of traffic management issues that may need to be recognized and mitigated. These issues include the following:  Potential for traffic movements associated with construction activities to impact on existing client operations, other construction activities, and the local community and environment  Traffic management strategy, covering issues such as congestion, access, noise, car parking, and waiting areas

B. Relevant Legislation

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on site. This action will identify any specific requirements that can be incorporated into the design of the facility and the EMP for the site.

C. Management Measures

P2S will provide details of site-specific traffic management measures. Typical measures that may be included are:  Parking will be permitted only in designated areas. Parking on other areas of the site or on the public highway will not be permitted.  Traffic and deliveries will arrive via an offsite truck parking lot to facilitate appropriate traffic management when necessary.  All vehicles exiting the site must pass through the wheel-washing facility and the site security compound.  Special arrangements and prior agreement with the police/local authorities (in consultation with the client) will be obtained for the routing and timing of any abnormal and large loads to or from the site.  P2S will control all deliveries and traffic entering and exiting the site.  Working hours will be limited. Working outside of these hours will require the approval of the client and the appropriate authorities.  A maximum speed limit of 10 mph (16.1 kph) will apply on the site for the safety of the workforce and to minimize disturbance from noise and dust. At large sites in unpopulated areas with significant distances between site facilities, this speed limit may be modified.  Contractors and employees will be required to maintain clear and safe pedestrian access to office areas.

D. Monitoring

P2S Site Management will conduct regular inspections to verify adequate implementation of traffic management measures. Deviations from site requirements will be corrected.

5.6 Contaminated Land

Some sites will be located where previous activities may have resulted in the contamination of the soil and/or groundwater. Before the start of any work on site, it is important to review any existing assessments and investigations to identify the potential risks and any areas of contamination. If no assessments/investigations have been undertaken and there are reasons to believe that the site may be contaminated, then steps should be taken to evaluate the site conditions and confirm responsibilities for the existing site conditions and any associated problems due to field activities, before starting work. The client maintains responsibility for site-specific conditions and contaminants that were present on the site before P2S’s arrival (such as contaminated soil and groundwater). The site evaluation will confirm site conditions and help to determine clear responsibilities for existing site conditions and associated problems. The client’s responsibility includes disposal of the soils or contaminants under the client’s site-specific waste disposal registration number (or EPA/state identification number, whichever is appropriate). The client retains ownership of these materials from generation through disposal. P2S’s name will not be noted on the waste manifest without Business Unit approval. Any assessments or investigations will be agreed to with the client.

The potential for contamination to be present on the site is normally determined in 2 phases: Phase 1 – Desk study to identify previous land uses that may have resulted in contamination. These land uses can be on or adjacent to the site. Information relevant to a preliminary investigation includes the following:  History of the site  Processes used  Layout of the site above and below ground at each stage of development  Presence of waste disposal pits, abandoned pits, and quarries with or without standing water  Mining history  Information on geology and hydrogeology (including the presence of groundwater and surface water)  Potential contamination uses of sites, past or present, in the area adjacent to the site

If Phase 1 assessment finds that contamination is probable, a Phase 2 exploratory investigation should be undertaken. Phase 2 – Site investigation to identify land areas that may have contamination from previous uses and confirm presence or absence of contamination. This investigation should establish the type, concentration, and aerial and vertical extent of contamination on the site. A. Introduction

Project Management must provide details of the previous land uses and the areas of the site that have been identified as contaminated or potentially contaminated. Project Management must also provide details of the contaminants that are present or may be present, the type and extent of the contamination, and the disposal requirements associated with any material removed from the site or reused on the site. B. References

References that have been used to identify the contaminated land issues on the site must be listed. C. Relevant Legislation and Guidance

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on site. This action will identify specific requirements that can be incorporated into the design of the facility and the EMP for the site. D. Mitigation Measures

P2S and contractors are specifically required to implement mitigation measures on the site due to the nature of the contamination/potential contamination on the site. Listed below are examples of typical measures:  Do not stockpile contaminated soil unless it cannot be avoided. Water draining from a stockpile may be contaminated and need controlling and potentially treating.

 If any of the following visual signs of contamination or unusual odors are discovered, they must be immediately reported to P2S supervision/management. All work in the vicinity will be suspended and the area sealed until P2S has carried out an inspection and implemented an appropriate action plan. Visual signs of potential contamination include the following:  Discolored soil (such as chemical residue)  Fibrous texture to the soil (such as asbestos)  Presence of foreign objects (such as chemical/oil containers)  Evidence of previous soil workings  Evidence of underground structures and tanks  Existence of waste pits  Fill material/made ground  Old drain runs and contamination within buildings, tanks, and flues  Appropriate waste management procedures will be used as described in Section 5.4.C.  Appropriate measures should be undertaken to protect the controlled waters in the vicinity of the site as described in Section 5.1.E.  Personal protective equipment will be used as defined in the project-specific HSE Plan.

E. Monitoring Requirements

P2S will develop a list of site-specific monitoring requirements based on the applicable standards and discussions with the client and the authorities.

5.7 Public Relations

A. Introduction

Activities that have the potential to affect neighbors, client operations, and the general public must be identified. P2S Site Management, contractors, and employees will be required to comply with these procedures. P2S Project Management will strive to establish and maintain good public relations at all times. Complaints will be handled swiftly and, where appropriate, remedial action will be taken. B. Responsibilities

Overall responsibility for the implementation of this EMP lies with P2S. P2S or client management will undertake all communications with third parties. Complaints received on site will immediately be logged and reported to the client by P2S.

C. Management Measures

Listed below are examples of typical measures:  P2S Site Management, contractors, and employees are responsible for fully implementing the provisions of the EMP where they are relevant to the specific activities of an individual, whether explicitly specified in the contract or not.  P2S will address queries about environmental management or implementation of the EMP.  P2S and the client will seek to set up and maintain good public relationship via an appropriate program of informing the public of the project and its schedules and being available to answer questions about the project in an informed and consistent manner.  In the event of unusual activities being carried out, including nonstandard hours of work, P2S will notify the client in advance, who will in turn notify all relevant neighbors or ask P2S to do so.  Complaints from neighbors or other parties will be treated seriously, and the cause investigated fully. P2S, who will notify the appropriate client contact, will log the complaint. Where appropriate, remedial action will be taken, and the complainant informed by P2S or the client of the action that has been taken.  Neighborhood liaison issues will be routinely discussed at site management meetings. Complaints will be actively pursued by P2S, and corrective action will be taken as appropriate.

D. Complaints Register

A complaints register will be maintained by P2S and will provide a permanent record of the performance of the project.

5.8 Flora, Fauna, and Natural Features

A. Introduction

Construction activities that have the potential to affect wildlife, flora or fauna, and natural features will be identified. Project Management must adopt appropriate control measures to mitigate those impacts. In particularly sensitive locations, it may be necessary to avoid disturbance during certain times of the year, such as hibernation, mating, or birthing seasons. Activities will be scheduled in consideration of sensitive times of the year. In addition, it may be necessary to avoid designated wetland areas on or adjacent to the site. B. Relevant Legislation

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on the site. This action will identify specific requirements that can be incorporated into the design of the facility and the EMP for the site.

C. Baseline Data and Sensitive Receptors

P2S will identify any sensitive receptors that may be impacted. Where an EIA has been undertaken, the baseline data will form part of the project. The EIA should be referenced in the documentation. Where an EIA has NOT been undertaken, it is important to establish if there are any sensitive receptors in the area. If applicable, a wetlands delineation survey should also be performed and appropriate approvals and permits secured. P2S should request information on the wildlife, flora, fauna, and natural features from the client along with any baseline data. These data should then be referenced and used to identify sensitive receptors and plan appropriate mitigation procedures. There are 3 main ecological issues that have to be considered on sites:  Where species or areas of the site have been identified for particular protection, studies will need to be undertaken in advance of work starting, and appropriate working methods must be developed to protect the specified areas on species.  Where protected species are discovered when work has already started on site, work in the affected areas will immediately cease and P2S will seek expert advice through the client and the authorities. The best way forward will then be agreed.  Protection of the natural environment as a whole will be covered by the management measures listed below.

D. Management Measures

Examples of typical management measures are:  P2S Site Management and contractors will be required to include environmental controls within their environmental procedures to prevent damage to the protected wildlife, flora and fauna, and wetlands and to provide sufficient equipment and resources to effectively implement the requirements of the EMP.  Site Management will ensure that P2S and contractor employees are aware of environmental restrictions related to sensitive areas on and adjacent to the site.  P2S Site Management, contractors, and employees are responsible for fully implementing and maintaining the provisions for the EMP where they are relevant to the specific activities of an individual, whether explicitly specified in the contract or not.  Work in close proximity to surface water should proceed with care.  If protected species are discovered or suspected, they must not be killed, expelled, or disturbed. Where suspected protected habitats are discovered, they must not be destroyed or disturbed. In such circumstances, work in affected areas will immediately cease, and P2S will seek expert advice through the client and the authorities.  Storage of granular or liquid materials will not be permitted adjacent to surface water or other systems draining to controlled waters (such as surface water, groundwater, lakes, and ponds), to minimize the risks to wildlife.

 In the event that other wildlife issues are identified during the course of the project, P2S will consult with the client in order to develop and agree to an appropriate management strategy.  P2S will conduct regular inspections to verify adequate implementation of any control measures that are required. Any deviation from the requirement will be corrected.  P2S will address questions about the environmental management procedures or the implementation of the EMP.

Any specific measures that are required due to the presence of protected species or ecology should be listed.

5.9 Visual Intrusion

A. Introduction

P2S is responsible for creating an environment that has minimal impact on the local surroundings, through visual intrusion or stray lighting. B. Management Measures

Listed below are examples of typical management measures:  P2S Site Management, contractors, and employees are responsible for fully implementing and maintaining the provisions of the EMP where they are relevant to the specific activities of an individual, whether explicitly specified in the contract or not.  P2S is responsible for appropriately securing the site at all times.  Site operations and storage of equipment will be conducted in such a manner to, as far as possible, minimize the effects of visual intrusion to adjacent properties.  Nighttime lighting will be such that it is sufficient to allow safe passage, but without causing shadows or visual intrusion to adjacent properties or land.  Temporary lighting of the building and the site will be designed to minimize light pollution and maintain safety. Only the lighting essential for safety and security will be kept in operation overnight. An effective switching system to provide for this requirement will be incorporated within the scheme of lighting and power.  P2S will treat any complaint relating to visual intrusion or glare from stray lighting seriously. In the event of a complaint being received, the complaint will then be logged and the cause investigated fully. Where appropriate, remedial action will be taken, and the complainant will be informed through the client of what action has been taken.  P2S will conduct regular inspections to verify adequate implementation of any control measures that are required. Deficiencies will be corrected immediately.

5.10 Archaeology

A. Introduction

Archaeological remains are a valuable part of a country’s national heritage. Activities that have the potential to damage archeological remains will be listed. B. Relevant Legislation and Guidance

Legislation applicable to a site must be evaluated; this activity should be done well in advance of work starting on site. This action will identify any specific requirements that can be incorporated into the design of the facility and the EMP for the site. C. Baseline Data

Depending on the nature of the project and the location, work may be carried out to investigate the archaeology of the site during the planning stage. If an investigation is conducted, the findings of this investigation should be listed. If not, then a statement should be made that an investigation was not felt to be necessary and has not been undertaken. D. Management Measures

Examples of typical management measures are:  If any material of an archaeological nature, such as burnt or blackened material, brick or tile fragments, coins, pottery or bone fragments, skeletons, timber joists or post holes, or brick or stone foundations are encountered, they should be immediately reported to P2S supervision/management. All work in the vicinity will be suspended and the area sealed off until P2S has carried out an inspection and implemented an appropriate action plan.  If a skeleton is discovered, work will stop immediately and the local authorities will be contacted.

5.11 Worksite Housekeeping

A. Introduction

Arrangements for worksite housekeeping must be made during site work. B. Management Measures

Listed below are examples of typical management measures:  P2S will be responsible for the successful implementation of the requirements of this EMP and for managing worksite housekeeping at the site.  P2S Site Management, contractors, and employees are responsible for fully implementing and maintaining the provisions of the EMP where they are relevant to

the specific activities of an individual, whether explicitly specified in the contract or not.  Burning of rubbish, waste, or other material will not be permitted.  P2S Site Management and contractors are required to contribute to the clean and tidy state of the site at all times. At regular intervals, rubbish will be removed and disposed in the correct manner.  Worksite fencing will be maintained to comply with site conditions.  Toilets, offices, and canteen areas will be kept tidy at all times.  Wastes and excess materials will be promptly removed (such as at the end of each shift) from the immediate work area to the designated temporary storage areas.  Waste will be segregated as it is produced.  Eating, drinking, and smoking will not be permitted on site, except in designated areas.  No vehicles leaving the site will carry debris onto the public highways, and all vehicles will pass through an inspection/wheel-wash point.  P2S Site Management and contractors will be responsible for storing and using building materials and equipment in accordance with HSE requirements and for confirming that chemical drums, fuels, oils, and the like are stored upright and properly sealed when not in use in designated protected storage areas.  In the event of any spillage of diesel, fuel, oil, or chemicals, the contractor will clean the spillage immediately.  P2S will conduct regular inspections to verify that good housekeeping measures are maintained at all times.  Contractors are responsible for training employees in the proper lifting techniques when handling materials.

C. Housekeeping

 Work areas will be kept clean on an ongoing basis or at a minimum daily.  Oily rags and packing materials will not be allowed to accumulate on floors or in gang boxes.  Trash barrels, recycling containers, dumpsters, lugger tubs, and roll-off boxes will be placed as needed so that employees can discard trash without having to walk long distances.  Drinking water kegs, power woodcutting saws, and insulation applications must have trash receptacle for each location. The containers will be identified as to their intended content.  Small, round objects such as pieces of conduit, pipe, and welding rods will be properly discarded and never left on the ground.

Note: Welding rods and some nuts and bolts can fall through grating and must not be left on grating.

 Waste paints or solvents must be stored or staged in areas designated as flammable storage.

 Scrap lumber will be de-nailed, stacked, and then removed daily from work areas.  Containers for scrap metal will be provided and used.

D. Order and Arrangement

 Material storage areas will be clearly identified and properly maintained. Material should not be delivered to the work area until it is needed.  Do not park floats, wagons, toolboxes, or equipment in a “helter-skelter” or hap-hazardous manner.  Tape barricades will be maintained at approximately 42 inches (106.9 centimeters) above ground.  Ladders will not be left lying around on floors or leaning upright. Return them to proper storage when not in use.  Material stored inside buildings or structures under construction must not be placed within 6 feet (1.8 meters) of any hoistway or other inside floor opening, or within 10 feet (3.1 meters) of any exterior wall that does not extend above the top of the material stored.  Material must be properly stacked and secured to prevent sliding or collapse.  Aisles, stairs, and passageways must be kept clear to provide access in emergencies.  Unprotected cardboard containers will not be used in areas exposed to the weather.  Store frequently accessed materials at waist height to minimize bending and stooping.  Stored materials must not block fire-fighting equipment, aisles, stairways, or exits from any building.

E. Personal Pathways

 Clearly mark entrances to barricaded work areas.  Post signs at the jobsite entrance warning of hazardous conditions.  Ensure pathways have adequate lighting (not less than 5 foot-candles) if nighttime access is required.  When planning pathways, make provisions to store material as close as possible to work areas.  Never store material in pathways or at ingress/egress areas such as at the bottom of ladders.  Isolate hoses, cords, and welding leads from walking surfaces and doorways.  Hoses and cords will be kept 7 feet (2.1 meters) above walkways wherever possible.  Where cords or hoses are laid on the ground, they will lie flat with no loops and be covered with protective runways (bridges) where exposed to vehicle or personnel traffic.  Ensure that any pathway bridge has handrails, midrails, and toeboards, is anchored on either side of the ditch, and is sufficiently strong to carry the intended loads.

F. Aerosol Can Storage

Due to the potential, flammable, and combustible nature of aerosol cans, they should be stored in approved flammable storage containers when they are not in use.

5.12 Emergency Response Plans

A. Introduction

Activities that have the potential to lead to an environmental emergency must be identified, and the procedures to be followed in the event of an environmental incident or emergency event must be developed. In the event of an environmental incident or emergency event, actions taken will be in accordance with the Emergency Response Plan outlined in Practice 000.653.1200, Emergency Preparedness (Medical, Fire, Chemical, Weather). An environmental emergency is an incident involving, or having the potential to cause harm to, the environment. This section outlines the activities to be followed in the event of an environmental incident to minimize the damage caused to the environment or human health. An Environmental Incident is defined as “An adverse impact on the environment wholly or partially resulting from an organization’s activities, products, or services.” B. References

P2S Site Management and contractors should make reference to the current client and P2S site emergency plans in addition to the specific requirements of this EMP. An example spill prevention, containment, and counter measure (SPCC) summary is presented in Form 000.653.F0203, Spill Prevention and Countermeasure Plan. Refer to applicable standard (such as the United States Code of Federal Regulations, Title 40, Part 112) for detailed SPCC requirements. Refer to Attachment 01 for an example emergency plan. C. Reporting Requirements

Environmental incidents that must be reported (refer to Form 000.653.F0198, Incident Investigation Report) are spills or discharges to atmosphere, water supplies, sewerage systems, rivers, and other watercourses, or to the ground of:  Any chemical product or formulation  Oils and fuels  Effluents  Waste or contaminated materials  Gas or fumes

In addition, report damage to:  Trees  Wildlife  Flora  Fauna

 Existing local habitat

Also, report any environmental incident that could lead to:  Local authority or regulatory enforcement  Public complaint  Media attention

D. Management Measures

Listed below are examples of typical management measures:  P2S Project Management will incorporate the findings of the review of emergency events leading to environmental impacts, undertaken as part of the HSE risk assessments of field activities.  Environmental considerations in planning the response to environmental emergencies will include the following:  List of appropriate pollution prevention equipment  Maintenance regime for equipment  Environmental training records for employees  Potential locations and circumstances of environmental incidents  After work hours contact number for key personnel  Details of employee responsibilities for contacting authorities and neighbors  Details of employee responsibilities for coordination of response to environmental incidents  In the event of an environmental emergency or incident, immediate action should be taken to prevent pollutants from spreading.  Environmental emergency incidents will be reported immediately to this site emergency response team.  Regularly check that the contents of the spill kits held on site are complete. The content of the spill kit will depend on the site, but they may contain the following:  oil-absorbent granules  “pigs” or “sausages”  floating booms  absorbent materials  polyethylene sheeting  polyethylene sacks

 They should be stored in a marked bag or wheeled bin in a well sign-posted location. It is best if kits are stored near to where they may be needed. Buckets of sand, earth, and straw bales are good for cleaning up small spills.  Appropriate training will be provided in the use of the spill kits.

An example of a typical emergency plan is presented in Attachment 01.

E. Documentation

 P2S will maintain a record of all environmental incidents (refer to Form 000.653.F0198) occurring on site and remedial action taken in an incident logbook.  All environmental incidents will be reported to the client.  Records of correspondence complaints received will also be recorded and investigated. All correspondence will be directed through the appropriate client contact, and records will be maintained by P2S according to the schedule provided in Practice 000.653.1500.

6.0 AUDITING AND REPORTING

P2S is responsible for auditing the implementation of the EMP to verify that environmental objectives are achieved. If the system is found not to achieve the objectives, P2S will have overall responsibility for changes in work practices to meet the objectives. HSE auditing and reporting will occur in accordance with Practice 000.653.1305, Inspections/Assessments and Audits. P2S Site Management will conduct daily site inspections and will conduct a formal, documented HSE audit on a regular basis. Weekly audits will be summarized and recorded on the form presented in Form 000.653.F0202, Key Result Area (KRA) Performance Index – Weekly Environmental Audit Summary Sheet. P2S will generate a monthly report that will document the environmental performance of the site including any incidents that have occurred.

7.0 RECORDS

P2S will maintain all relevant documentation and correspondence related to environmental management according to the schedule provided in Practice 000.653.1500, Records Management and Document Control. General environmental recordkeeping requirements include the following:  Correspondence with local, state, region, federal, in-country, and similar authorities records  Records of all environmental incidents associated with waste management and remedial action taken  Air quality monitoring  Recorded and investigated complaints relating to waste management will be recorded and investigated  Vehicle and equipment maintenance  Correspondence from the client relating to waste management for the duration of the project (these records will be made available to the authorities and the client upon request)  Water contamination  Discharge consents

Also refer to Section 5.12.E.

8.0 TRAINING

8.1 Environmental Awareness/Orientation

Environmental awareness training will be provided to employees and contractors working on the site in conjunction with other site orientation topics. Training will include the following:  General introduction to environmental concerns relating to activities on the site  Overview of legal requirements in relation to environmental performance on the site  Overview of the provisions of the site-specific EMP  Importance of good housekeeping  Good practices in dealing with potential pollutants  Emergency procedures  Management of wastewater  Waste management practices and facilities on site  Description of key control measures to achieve project-/site-specific requirements  Personal responsibilities and liabilities

Additional training areas may include the following:  Proper use of the waste management system  Completion of environmental logs/incident reports  Use of pollution response equipment  Use of wheel-wash facilities  Maintenance and use of wastewater system

8.2 Environmental Management Training

This section describes positions and responsibilities for management of dangerous waste activities. Legislation often requires employees in this category to be trained and certified. No employee will perform tasks for which they are not properly trained, except to gain required experience while under the direct supervision of a supervisor or coworker who is properly trained. Training will be completed for targeted employees within 6 months of the date of hire, within 6 months of assignment to a workplace, or within 6 months of assignment to a new position. Regulations often require a written description of the type and amount of both introductory and continuing training required for each dangerous waste management position. Federal, state, or in-country regulations should be consulted for specific training requirements. The job title, job description, and name of employee will be maintained for each position related to dangerous waste management at the facility. The job description will include requisite skills, education, and other qualifications and duties for each position.

A. Responsibilities

Project/Site Management will oversee and ensure the implementation of applicable dangerous waste management training. Management will ensure that employees assigned to a specific position complete the required training and become thoroughly familiar with applicable contingency plans, operations, activities, location and properties of all wastes handled, location of all records, and the building layout. Employees working in an area where incidents or upsets involving dangerous waste could occur will be properly trained to respond to the incident or upset condition. Management will be responsible for identifying the waste management training requirements for employees, based on position and responsibilities described in this practice. Management will ensure annual refresher training is provided in sufficient detail to make certain each employee is trained to handle dangerous waste properly within the scope of assigned job responsibilities. B. Positions

Positions are defined by the project. A suggested categorization of waste worker positions is as follows: All Employees – This category is inclusive of administrative and technical/professional personnel, engineers, designers, administrative assistants, clerks, and support organizations touring or providing oversight. This position includes personnel who gain access to the site to complete work in controlled areas where their work does not involve management of dangerous waste. Personnel in this category are not categorized into one of the other 3 worker positions. Waste Worker – This category is inclusive of employees with waste management duties and responsibilities who require unescorted access and whose responsibilities are limited to the initial generation of dangerous waste and placement of the waste into pre-approved containers, or who conduct dangerous waste inspections. Employees who function as waste workers may include, but are not limited to, craft, transporters, and technical support. Pre- approved containers can include those in a satellite accumulation area, 90-day accumulation area, or temporary storage and disposal unit. These employees can be responsible for generating dangerous waste while working on a non regulated system. The work may be unsupervised or completed under the supervision of trained employees. A waste worker must also fulfill the position for “all employees.” A waste worker’s assigned duties and responsibilities include the following:  Place waste into pre-approved containers and filling out log sheets, where applicable.  Load packaged containers into trucks or moving containers.  Respond to a spill or release of known contents where the duties and responsibilities are limited to containing the spill/release, returning the drum to an upright position, and placing the known spilled material or waste into a pre-approved container.  Apply container markings or labels based on direction received from others.  Respond to the regulatory agency compliance inspector’s questions about waste management procedures.  Perform an inventory of dangerous waste.  Conduct inspections of dangerous waste.

Advanced Waste Worker – Advanced waste workers are those whose duties and responsibilities concerning dangerous waste exceed those of a waste worker (therefore, an advanced waste worker may fulfill the role of a waste worker). Examples of duties include, but are not limited to the following:  Determine container markings (such as label and shipping requirements)  Sample waste  Designate waste materials  Classify waste materials before shipment

Waste Worker Supervisor/Manager – Various types of managers and non-managers are included in this position. Employees are assigned to this category if they direct waste worker or advanced waste worker activities related to dangerous waste management and compliance activities. Examples of duties and responsibilities assigned to the waste worker supervisor/manager include, but are not limited to the following:  Emergency coordinator or alternate  Building emergency director or building warden, as appropriate  Environmental programs manager  Immediate manager of waste workers or advanced waste workers (such as area mangers)

Note: Site-specific dangerous waste management training materials can be developed on request to the HSE Representative or Regional Safety Manager.

9.0 REFERENCES

Document ID Document Title 000.653.1200 Emergency Preparedness (Medical, Fire, Chemical, Weather) 000.653.1305 Inspections/Assessments and Audits 000.653.1500 Records Management and Document Control Forms: 000.653.F0198 Incident Investigation Report 000.653.F0202 Key Result Area (KRA) Performance Index – Weekly Environmental Audit Summary Sheet 000.653.F0203 Spill Prevention and Countermeasure Plan

10.0 ATTACHMENTS

Attachment No. Attachment Title Attachment 01 Example of a Typical Emergency Plan