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ENVIRONMENTAL MANAGEMENT PLAN

PROJECT NAME CLIENT CONTRACTOR SITE

: INDORAMA FERTILIZER PLANT PROJECT : INDORAMA ELEME FERTILIZER & CHEMICALS LIMITED : DAEWOO NIGERIA LIMITED : NIGERIAL PORT HARCOURT ELEME PETROCHEMICAL COMPLEX

Issued for Approval REV. DATE DESCRIPTION

Y.H.WI PREPD CHKD APPD

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TABLE OF CONTENTS

1.0 2.0 3.0 4.0 5.0 6.0

SCOPE DEFINITIONS/ABBREVIATIONS RESPONSIBILITIES ENVIRONMENTAL MANAGEMENT CONTROL OPERATIONAL CONTROL AND MONITORING REFERENCES

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1.0 SCOPE

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The Procedure describes the environmental compliance DNL and Sub-contractors during the site preparation, construction and commissioning of all process plants, general facilities, storage and handling, utilities, other services, offsite activities and facilities relevant to the IEFCL FERTILIZER
PROJECT.

2.0

DEFINITIONS/ABBREVIATIONS INDORAMA ELEME FERTILIZER CHEMICALS LIMITED(IEFCL) Daewoo Nigeria Limited (DNL) means the entity required to perform the Construction/(pre-commissioning) activities Any person engaged in activities for the benefit of the Project and who receives payment, even on a temporary basis Directorate of Petroleum Resources An Incident which has resulted in actual Injury and/or Damage (Loss) to Assets, the Environment, Social program, Reputation or to 3rd Parties Environmental Guidelines and Standards or Petroleum Industries in Nigeria a person who, because of qualifications and experience, has the skills necessary to perform the stated duties. Control of Substances Hazardous to Health Decibels weighted on the A scale Emergency Action Plan Environmental Management Plan Surroundings in which an organization operate including air, water land natural resources flora fauna humans and their interrelation Element of an organizations activities, products or services that can interact with the environment International Standard for Environmental Management Systems Material Safety Data Sheets Personal Protective Equipment Pre-existing contamination refers to any environmental damage or hazard existing prior to handover of the Jobsite to IEFCL and DNL. It includes, but is not limited to, metals, waste, rubbish, pollutants, chemicals or other substances which could cause any detriment to the environment. An Incident is an unplanned event or chain of events, which has, or could have caused injury or illness and/or damage [loss] to people, assets, the environment or reputation.

Client/COMPANY CONTRACTOR SUBCONTRACTOR EMPLOYEE DPR ACCIDENT EGASPIN COMPETENT PERSON COSHH DB(A) EAP EMP ENVIRONMENT ENVIRONMENTAL ASPECTS ISO 14001 MSDS PPE PRE-EXISTING CONTAMINATION

INCIDENT

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3.0 3.1 RESPONSIBILITIES Project Manager

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The DNL Project Manager has overall responsibility to ensure full compliance with environmental requirements relevant to DNL scope of work. Will provide adequate resources and ensure that all permits relevant to DNL scope of work are obtained from the appropriate local Authorities. 3.2 HSE Manager

Will continuously monitor the implementation of this plan and associated procedures and provide feedback on performance. Verifies that all the personnel are adequately trained and informed about their environmental responsibilities. Answers or collaborates to the answer to environmental requests from interested parties, including Company Verifies that equipment and machinery are kept efficient and regularly maintained. Collects and files the local environmental regulations regarding the waste disposal, waters and other environmental aspects of the site. Verifies the correct management of the wastes, keeping the waste list and the plot plan of waste storage areas update. Organize the environmental incidents investigations. Will provide advice on all aspects of environmental and waste management, and submit monthly report to Company HSE Manager. He is responsible for organizing internal inspection and audits to ensure compliance with environmental procedures. 3.3 All Employees

They are responsible for following all applicable laws and regulations and for conducting their work in accordance with all permits, requirements and Project Procedures. 4.0 4.1 ENVIRONMENTAL MANAGEMENT CONTROL Introduction

This document sets out the basic rules for Environmental Management: Describes the handling and disposal methods for all liquid and solid wastes generated during the execution of the project;

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It also addresses the air pollution prevention and control, noise pollution prevention and control, protection of water resources, and site reinstatement; Includes the basic actions to be taken in the event of a pollution incident involving, land, air or water. Summarize specific requirements for compliance with applicable national, and local regulatory environmental documents, permit conditions, and contractual commitments during the project execution phase; Clearly define the contractual division of responsibility for environmental compliance for all involved parties and assign tasks to Jobsite personnel; Legal and other Requirements

4.2

DNL shall fully comply with Nigerian government and local authorities, such as: The Federal Ministry of Environment, housing and urban development; The Federal Ministry of Energy (department of petroleum resources), the Federal Ministry of Agriculture and Water resources, The Federal Ministry of Transport and the rivers state Ministry of Environment. DNL shall comply with Companys Health, Safety & Environment Management Plan & Procedures based on IFC/World Bank Standards. In cases of contradictions between these regulations, the contractual requirements, including governmental and local authority regulations shall prevail. The standards and regulations shall be considered at all phases of the execution such as engineering, procurement, construction, testing, maintenance and commissioning. 4.3 Environmental Aspects and Impacts

The review of the project environmental aspects and impacts is an ongoing process throughout the projects activities. For construction activities, the risk for the creation of significant environmental impacts is maintained to as low as reasonably practical. However, the following activities require attention: Environmental impacts at the design phase Camp construction and maintenance, Clearing of the right of way and subsequent reinstatement, Soil protection against erosion during construction activities, Use and exposure of water resources, Handling and storage of waters, chemicals, fuels and hazardous materials,

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4.4 Preparation and execution of the water crossings. Training and Awareness

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All the personnel whose activity can cause a significant impact on the environment must have acquired the necessary competencies by training and appropriate documented experiences. Site HSE Manager shall verify, by interviews or appraisal of the experiences, that the personnel possesses the suitable competence to carry out his own task in the respect of the environment. The Sub-contractors Site Manager must provide adequate training to the personnel that can cause a significant environmental impact and records the training activities. 4.4.1 Environmental Awareness/Information

Environmental Awareness constitutes a major part of achieving compliance for environmental protection. Consequently, an Environmental Awareness Orientation will be given to all employees as part of their general orientation. Environmental related toolbox talks / meetings will be conducted by Sub-contractors on routine basis or as necessary. The following issue will be addressed during the environmental awareness training held during the HSE orientation session: Importance of working and operate in conformity with the environmental local legislation, the IEFCL and DNLs Environmental Policy, the Environmental Management Plan Compliance with the operating procedures (waste management, handling and storage of chemical products, etc.) and the potential consequences due to non-compliance. Procedures to face to environmental emergencies Environmental impacts consequent to their activity and the benefits for the environment deriving from their engagement; Roles and the responsibilities in the Environmental Management Plan Environmental protection - protecting the environment from the effects of construction by making personnel aware of sensitive environmental resources on-or near the Jobsite; Environmental aspects recognition and communication - training personnel to recognize potential environmental impacts (e.g., spills, erosion control failures, improper waste

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management) and to inform the Supervisor;

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Liability control demonstrating that noncompliance with regulatory requirements can lead to personal and corporate liability. DNL and Sub-contractors Site HSE Representative and Supervisors will treat environmental topics during Tool box meetings and other periodical meetings. The DNL Site HSE Department will record all Environmental Training and awareness sessions. 4.5 Environmental Communication

The means shall be used for communication between the project manager, IEFCL, supplier, other parties and the DNL head office. 4.5.1 External communication

Communication Communication with the with Authorities Company

Communication with headquarter

Communicatio Communications n with external with Suppliers interested /Sub-contractors parts

On the project, basically all formal communication runs via the Project Manager.

On Sites formal communication is

There is a frequent communication

Communication between DNL and Suppliers / Subcontractors is carried out both from the site (PM, HSE Manager) and from the headquarter

Every communication coming from external interested parties is recorded and an answer is given.

routed via the DNL between the site Project Manager with the IEFCLs assistance. Typically the formal communication with Authorities is limited as this will run between the IEFCL and the Authorities. and the head quarter which supervises the application of the EMS

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Site HSE Manager has to:

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- Record the environmental communications or claims coming from inside or outside the organization, - Coordinate, with Project Manager, the answers to the environmental communications or claims. 5.0 5.1 OPERATIONAL CONTROL AND MONITORING Potential Degradation of Soil and Water during Construction

DNL shall implement all the necessary measures in order to mitigate as far as reasonably practicable the potential degradation of general soil / ground water quality due to construction & operations, minor spillages, traffic and emplacement of fill material or due to onsite accidental spills and leakage. 5.1.1 Spill Prevention and Response

Sub-contractors shall ensure that sufficient resources are available at all times to deal with spills of hazardous materials. Every effort will be made to prevent hydrocarbon and chemical contamination of soil, groundwater and surface water. Inert absorbent material (e.g. absorbent pads, sand) shall be available near the areas where leakage of hazardous liquids can occur. The personnel who uses or manipulates paintings, oils or hydrocarbons has to be informed about the use of the absorption devices during the orientation sessions and toolbox meetings. 5.2 Dust Control

DNL is responsible for fugitive dust control within the Jobsite boundaries and control areas. During initial site preparation and construction phase, every effort will be made to minimize the discharge of visible fugitive dust beyond the property line that will interfere with land use or violate air quality standards. Source reduction and source improvements provide emission control through improved stockpile management and improved work practices related to loading and load-out operations. Examples of these include: Reduction in the amount of material being handled and minimize the frequency of stockpile surface disturbance. Reductions in material drop height when loading out to the stockpile. Covering stockpiles when practical with tarpaulin and securing the cover. Fugitive dust control for material handling operations and stockpiles will be through reduced

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handling, reduced time of stockpiling, when possible, and dust suppressants (e.g., water) under prolonged dry and windy weather conditions. All vehicles (trucks, lorries) out of site will be inspected to ensure that they have adequate means of covering loads. Torn and badly worn or ill-fitting covers will be rejected. Trucks shall not be overload while carrying earth, sand, gravel, stone or other aggregates and will be completely and adequately covered at all time while moving. Bulk storage of waste earth will be limited as far as is practicable and care will be taken during handling to reduce dust generation. Drop height between excavators and transporters will be minimized and double handling of earth in storage areas will be eliminated where possible. Every effort will be made to reduce the handling of stockpile materials during prolonged dry or windy weather. The site speed limit will be strictly applied in order to limit the disturbance of dust and truck drivers will be instructed to stay on approved routs to minimize off road traffic. Water spray trucks and/or mechanical road sweepers, or similar will be used to control dust on the site in the area of competence. Mud and dirt accidentally transported onto public roads or jobsite roads via construction traffic will be cleaned up immediately by the DNL responsible. The HSE Manager will monitor the implementation of dust control measure on site. The transportation of earth, sand, gravel, etc, HSE Department will put in place random check. 5.3 Noise Control

DNL shall follow all the local rules and IEFCL specification for noise control on the jobsite and ensure that noise levels are within the maximum limits set for the project as measured at the jobsite boundary. During site preparation, construction and commissioning activities DNL will perform work in a manner that minimizes the affects of noise generated. The noise sources (compressors, generators, etc.) will be recommended for insulation or other preparation in order to minimize the noise inside and outside the workshop. Sources Noise levels within the construction area will be assessed and control measures implemented. The selection of equipment shall be taken into account and a determination shall be made whether

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harmful levels of noise are emitted.

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For noise associated with the construction phase, which would be of relatively short duration and would principally take place during the normal working week (and during the day), higher noise limits than for normal plant operation are generally [NOISE LEVEL GUIDELINES on IFC EHS Guidelines] One Hour L Aeq(dBA) Day time Nighttime 07:00~22:00 22:00~07:00 55 70 45 70

Receptor Residential, institutional Educational Industrial, commercial

General Mitigation Measures: The following standard measures should be considered during construction: Select inherently quiet equipment wherever possible; Ensure machinery are properly maintained, particularly engine exhaust silencers; Machinery should be turned off when not in use (not left idling); Where practicable, make use of screening afforded by spoil stockpiles for high noise activities. All machines in intermittent use will be shut down during intervening periods between works or throttled down to a minimum. All vehicles and plant used during construction operations will be fitted where appropriate with effective mufflers and will be maintained in good working order. All Heavy Equipment movements will be minimized. Pile driving should be limited to daytime hours. Noise Monitoring

5.3.1

DNL shall periodically monitor the noise level at the fence line to verify the compliance with applicable standards 5.4 Housekeeping

Each department will be responsible for the maintenance of a good level of housekeeping in the

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assigned site areas and to mobilize adequate number of people (in proportion to the total work force) for the housekeeping of the site common area. 5.5 Construction Waste Management

DNL will conduct the waste management during pre-construction and construction activities in compliance with the applicable local regulation and the Companys Health, Safety & Environment management Plan & Procedures. The Health, Safety & Environment Management Plan & Procedures describes the Company requirements for correct characterization, handling, disposal and storage of wastes. Recycling is encouraged where possible. The combustion of wastes, including vegetation, is not permitted on site. Waste Collection on site As a minimum the following wastes have to be collected separately: SOLID WASTE Paper cardboard Metals Wood Plastics Glass Insulation material Municipal waste (including waste from catering and camp) Dried Concrete Empty containers of chemical products (only 1% of volume left) Oily metallic turnings, oil filters and Oily rags Used batteries Medical wastes from First Aid LIQUID WASTE HAZARD CLASSIFICATION Not Hazardous Not Hazardous Not Hazardous Not Hazardous Not Hazardous Not Hazardous Not Hazardous Not Hazardous Hazardous Hazardous Hazardous Hazardous HAZARD CLASSIFICATION

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Exhausted oil Remainders of solvents, paintings and chemicals Oily water condensed from air compressor Water from equipment washing Water from pipes washing and pressure testing Water from Batching Plant

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Hazardous Hazardous Not Hazardous Not Hazardous Not Hazardous Not Hazardous

Lay out of the site, with the areas of temporary waste storage clearly marked, will be drawn and kept updated by the HSE Department. All the personnel must collect the refusals respecting the previewed differentiation and using exclusively the predisposed and marked containers. Do not: Mix up wastes of different kinds, above all hazardous with non-hazardous and incompatible kinds of hazardous ones. Temporarily storing wastes outside the appropriate predisposed containers. Burn, bury, hide or disperse wastes. Filling up excessively the wastes containers, to make the handling operations difficult and cause spillage. Use containers to collect wastes not designated for such aim.

All personnel must collaborate to reduce the production of wastes stimulating the re-use of materials or the reduction of scraps. The HSE Manager and Supervisors will periodically inspect the site in order to assess the correct and effective waste management. 5.6 Hazardous Substances

The MSDS of off all hazardous substances stocked or used on site must be collected and recorded by the HSE Manager. Material supplier must give to the HSE Manager copy of the MSDS of every used or stored substance. For no reason dangerous substances (and the relative empty containers) can be dispersed in the environment, on the ground, in the sewer system or be burnt. The containers of dangerous substances, oils or paintings cannot be cleared or washed dispersing

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the liquids of washing operations in sewer or on the ground.

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Every container must be provided with its specific label indicating the content, the hazard characteristics, the risk phrases (R phrases) and the safety advice (S phrases). (R phrases are giving indications concerning special risks of dangerous substances and preparations in accordance with the relevant European Directive EEC; e.g. R24 = Toxic in contact with skin. The safety advice S phrases are giving indications of the precautions for the use and handling of dangerous substances and preparations; e.g. S24 = Avoid contact with the skin) 5.6.1 Storage

The storage of dangerous liquids must be done above appropriate containing tanks, apt to contain the liquids in case of accidental spillage. If possible, emergency closets provided with anti-flame, vapors aspiration and filtering devices shall be used. The storage areas must be isolated in order to avoid vehicles in motion to damage containers and cause environmental accidents. All dangerous substances must be kept in their original containers, sealed until their use and marked with the relative label. The stoppers or other closings must be the original ones, previewed at the shipment, intact and not deteriorated or damaged by the atmospheric agents or by the handling operations. Dangerous or flammable products, including paintings and oils, must be stored in suitable places and well ventilated, placed far away from heat sources. Fire extinguishers must be available near inflammable substances. Pouring devices must be suitable for the operations carried out, sure for the users and the environment, predisposed and used so as to diminish the risks of spillage or dripping on of the ground or in the sewer. At the end of their use, the unfinished containers of chemical products, paintings and oils must be brought back to the storing areas and adequately plugged. 5.6.2 Containing Basins

The containing basins placed under containers of hazardous liquids, must be tight, having capacity at least 110% of the biggest containers stocked. The containing tanks cannot be provided with drainage pipe, whereas they will have to be supplied with appropriate cover in order to prevent accumulation of rainwater, if in the open air. Whichever mixing or pouring operation of oils, paintings, hydrocarbons or other dangerous liquids must be carried out over containing tanks in order to prevent soil pollution. Periodically the HSE Manager will inspect the site and the storage areas in order to assess the

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correct dangerous product management, verifying the presence of all the safety data sheets, containing tanks, fire extinguish devices, etc. 5.7 Environmental Incidents and reports

Possible environmental emergencies: Fire Spillage of hydrocarbons, oils, paintings or dangerous substances Emergency related to the use of ionizing sources Breaking of discharge or adduction water pipes

Environmental accidents report Every incident or anomalous situation that has caused impacts, on the environment (fire, liquids spillage, gas escapes, breaking of water pipes, erroneous disposal of dangerous waste, etc.) has to be reported to the Site HSE Manager. DNL shall continuously carry out visual checks for emissions and all environmental incidents will be reported in line with the project procedure HSE Manager will issue corrective action notices where action is required and will submit a periodical report to Company. 5.8 Fire

Fire extinguishers have to be placed near the storing areas and by the areas with fire risk, in conformity with the safety data sheets of the dangerous products stored and used. Inert absorbent material (e.g., absorbent pads, sand) must be available near the areas where leakage of hazardous liquids can happen. The predisposed material must be matched with clear use instructions, in order to make clear its use modalities and its position to all the personnel. 5.9 Dewatering, Storm water, Hydro testing, Flushing effluent and Environmental Monitoring 5.9.1 Excavation Dewatering and storm Water Discharge

DNL will divert all water pumped from excavations and trenches to temporary or permanent Jobsite drainage ditch (that utilize sediment removal controls), or sedimentation basins (or ponds). DNL will perform the monitoring of the excavation dewatering discharges to the surface water drain systems in accordance with the following local standard. Before starting any pumping activities DNL will perform the visual inspection of the water

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according to the reported table.

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DNL will take a representative sample from each excavation and further investigate as necessary before discharges the water into the surface water drain systems. At least skimming activities and placements of oil adsorbent boom/pads will be performed. 5.9.2 Hydro test and Flushing Water Effluent

At the end of the construction phase hydro tests and flushing activities will be performed on piping and vessels utilizing water. The water will be when possible reused many times for hydro test and flushing and finally discharged to storm water drain system. DNL will be responsible for the monitoring of the discharge of hydro test water 5.9.3 Wheel Wash

DNL will be responsible for the monitoring of the discharge of wheel wash water If visual inspection identifies oily sheen or turbidity, DNL shall perform total petroleum hydrocarbon (TPH) and/or total suspended solids (TSS) analyses. Concrete additives must be stored on concrete curbed slabs. Runoff from these storage areas must also be directed into the settlement basin. Storage of aggregate materials must be done in a manner that controls turbid runoff. 5.9.4 Report

HSE Supervisor will issue the following periodical report to DNL Management and Company in relation to the water discharge monitoring: Sediment basin sampling Excavation dewatering Concrete batch plant(s) discharge Wheel wash discharge During Pre-commissioning Hydro test water discharge, Flushing water discharge

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The report shall include: Results of periodic monitoring; Test methods used; and Comparison with Project and local

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REFERENCES Rivers State Environmental Protection Agency Law Federal Environmental Protection Agency(FEPA) Act Environmental Guidelines and Standards for the Petroleum Industry in Nigeria(EGASPIN) IFC Environment, Health & Safety Guidelines