Project Shaheen

SPILL PREVENTION AND RESPONSE PLAN

25875-000-2HY-H01-00008 Rev 000

Bechtel Petrofac JV

000 13/04/2015 Issue for Use K. Boyd D. Brown J. Knick W.Al Shamsi B.Murphy

REASON FOR BY ESH MGR SM OWNER OWNER

REV DATE
REVISION
JOB NO. 25875 Page 1 of 9

DOCUMENT NO.
25875-000-2HY-H01-00008 Rev 000

Template SDN: 25875-000-GFX-GEX-00006 Rev 005

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
Confidential
© 2014 Bechtel/Petrofac Joint Venture for Project Shaheen
This document is prepared under the contract between International Bechtel Ltd. Co. Ltd. (Abu Dhabi branch) (“Bechtel”) and Petrofac
Emirates L.L.C. (“Petrofac”), on one hand, and Emirates Global Aluminium PJSC on the other (the “Owner”), and contains information
confidential and/or proprietary to Bechtel or Petrofac that is not to be used, disclosed, or reproduced in any form by any person or entity
other than Bechtel, Petrofac or Owner, without Bechtel’s or Petrofac’s prior written permission. All rights reserved.
Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

TABLE OF CONTENTS

SECTIONS DESCRIPTION PAGE

1.0 INTRODUCTION ..............................................................................................................3

2.0 LEGISLATIVE REQUIREMENTS ....................................................................................3
3.0 SPECIFIC RESPONSIBILITIES ......................................................................................3
3.1 BPJV Construction Manager (CM) ...................................................................................3
3.2 Contractors: ......................................................................................................................4
3.3 ES&H Representative ......................................................................................................4
3.4 Supervision .......................................................................................................................5
4.0 SPILL PREVENTION CONTROLS..................................................................................5
4.1 Spill Kits ............................................................................................................................5
5.0 SPILL RESPONSE AND CLEAN UP PROCEDURE ......................................................7
5.1 Disposal Requirements ....................................................................................................7
6.0 SITE INSPECTION AND MONITORING .........................................................................7
7.0 TRAINING ........................................................................................................................8
8.0 REFERENCES .................................................................................................................8
9.0 DOCUMENT MANAGEMENT .........................................................................................8

Confidential © 2014 Bechtel/Petrofac Joint Venture for Project Shaheen. All rights reserved.

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
25875-000-2HY-H01-00008 Rev 000 Page 2 of 9
Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

1.0 INTRODUCTION
This purpose of this spill prevention and response plan is to ensure that the minimum
requirements for the BPJV and Contractors are properly implemented during construction
and regularly monitored to assess their effectiveness. This plan provides the minimum
requirements that will allow the reduction of risk of spills and the safe and effective
response to spills to the environment.

The Shaheen Project recognises spills of chemicals and hydrocarbon products as a

significant aspect of the Project and aims to minimise spills and associated environmental
impacts. Changes to controls will be instigated as required, dependent on their assessed
effectiveness.

This plan is subordinate to the Construction Environmental Control Plan (25875-000-2HY-

H01-00002) and is applicable to all spills to land, water and any near miss spills that BPJV
and BPJV managed contractors encounter during the construction phase of the Shaheen
Project. Additional controls for hazardous substances can be found in the project
Hazardous Substances Procedure (25875-000-GPP-GHX-00027).

The overall objectives of this plan are to:

 Describe the roles and responsibilities of all parties involved in preventing and
managing spills
 Minimise the risk of contamination and potential impacts from spills of hazardous
and/or toxic substances on the environment
 Establish a set of guidelines for spill response and safely manage and prevent
uncontrolled release of chemicals into the environment (including the marine
environment)
 Demonstrate compliance with contractual and regulatory compliance requirements
governing spill prevention, spill response and notifications

2.0 LEGISLATIVE REQUIREMENTS

The following primary legislation applies:

 Federal Law No. 24 of 1999

 CWM Technical Guideline on Requirements and Procedures for the Disposal of
Hazardous Waste

3.0 SPECIFIC RESPONSIBILITIES

3.1 BPJV Construction Manager (CM)

The CM has overall responsibility for construction on the site. Specific responsibilities
with respect to spill prevention and response include:

 Supporting the implementation of this Plan through provision of adequate

management support and resources
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Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

 Communicate spill response issues, compliance, developments and incidents to the

Owner Project team
 Consult with BPJV ES&H Manager or BPJV Project Environmental Lead on matters
pertaining to spill management

3.2 Contractors:
Contractors are responsible for undertaking work in accordance with this plan, including:

 Producing a spill prevention and response plan that includes the following:
– Description of physical layout and site diagram showing locations of
hazardous substances storage areas
– List and quantity of hazardous substances stored on site
– Procedure for handling, disposal and recovery of hazardous substances
– Contact details for emergency response personnel
 Maintaining records/log of spill incidents and responses
 Training their personnel on proper spill response procedures
 Maintaining spill kits
 Storing and using chemicals in accordance with site and legislative requirements
and product Material Safety Data Sheets/Safety Data Sheets (MSDS/SDS)
 Conducting emergency response drills
 Reporting immediately to the BPJV Supervision on any spills that occur
 Conducting preventative maintenance to all project equipment and providing records
of maintenance to BPJV on request.

3.3 ES&H Representative

The ES&H Representative is responsible for monitoring spill prevention compliance, in the
following ways:

 Reviewing contractor spill mitigation measures including response teams,

equipment, responsiveness, and awareness to assure that they are capable of
managing spill events
 Ensure spills are inputted into incident log
 Investigate and report on all significant spills
 Coordinate the completion of environmental incident reports and follow up
investigations and lessons learned
 Conduct regular field compliance inspections of construction activities for
compliance with this Plan
 Initiate Stop Work orders when environmental non-compliance with this plan or at
risk conditions are observed in the field
 Directly notify the BPJV ES&H Manager or BPJV Project Environmental Lead of any
circumstances that warrant regulatory notification or management action

Confidential © 2014 Bechtel/Petrofac Joint Venture for Project Shaheen. All rights reserved.

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
25875-000-2HY-H01-00008 Rev 000 Page 4 of 9
Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

 Review Construction Work Plans, JHAs, and schedules to assure that proper
environmental controls are incorporated to reduce risks of spill events
 Revise and update this plan in the event of required changes

3.4 Supervision
BPJV Contractor Superintendents are responsible for the supervision of construction in
the field. As such they are responsible for assuring that Contractor spill prevention and
response is conducted in accordance with this plan. Specifically:

 Inspected work areas to ensure works are being undertaken in accordance with
environmental requirements
 Ensure all workers are trained in the location and use of spill kits and
understand/adhere to reporting requirements
 Regularly review work procedures, plans and housekeeping practices to ensure spill
management requirements are compliant with this plan and relevant legislation
 Raising issues of non-compliance and opportunities for improvement and ensuring
timely and effective follow-up
 Reporting any environmental incidents to the BPJV Project Environmental Lead.
 Partaking in the investigation of any environmental incidents including environmental
spills.

4.0 SPILL PREVENTION CONTROLS

4.1 Spill Kits

Spill kits are to be kept at each hazardous materials storage facility/container, within all
plant and vehicles carrying chemicals and in close proximity to operating mobile plant, gen
sets and vehicles etc. At minimum spill kits will be placed in the following areas with the
following specifications:

Area Type(s)
Vehicle and Equipment servicing areas Oils and Fuels
Fuel transfer and refueling stations Oils and Fuels
Mobile Refueling Vehicles Oils and Fuels
Chemical Storage Areas Oils and Fuels/Hazardous Chemical
Medical Facilities Biomedical/Biohazards

Spill kits located at chemical/hazardous substance storage areas will be selected based
on the risk for the types and amount of chemicals being stored. Plant service vehicles may
have easily transportable bags that can be stored in the cabs. Any areas that are not
covered by the above list will be risk assessed to ascertain the level of spill kit availability
needed.

Spill kits should be:

 Brightly colored for easy identification

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Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
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Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

 Labeled with spill kit type e.g.: fuel and oil, hazardous chemical, acids,
biohazardous, biomedical
 Contained in a weatherproof box, drum, wheelie bin, lidded container or trunk which
can be mobilized to where needed quickly
 Able to be secured so it is evident when the kit has been used

Contactors shall ensure that there is a ready supply of spill clean-up materials in inventory
to restock used kits. At minimum each spill kit (other than for medical facilities) should
contain:

Absorbent Booms Spill Pads bags of Absorbent Granules

Clean Up Equipment PPE Heavy Duty Plastic Bags

Clean up equipment should be non-sparking. Gloves should be chemical resistant. Spill

kits shall be secured so that the contents cannot be accessed except in case of being
needed for cleanup. Immediately after product has been used for cleaning up a spill, this
should be reported to the correct department so the kit can be restocked.

Confidential © 2014 Bechtel/Petrofac Joint Venture for Project Shaheen. All rights reserved.

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
25875-000-2HY-H01-00008 Rev 000 Page 6 of 9
Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

5.0 SPILL RESPONSE AND CLEAN UP PROCEDURE

The following principles will be applied for any spill:

IF SAFE TO DO SO:

Control the source of the spill by closing valves, correcting upturned

CONTROL drums that may continue to spill liquids etc.

Contain the spilt material using available resources including dedicated

CONTAIN spill kits, dirt or other materials. Pay attention to preventing entry of spills
to drains / water bodies.

Clean up the spilt material and contaminated containment material and

CLEAN UP dispose of correctly in the brown regulated waste bins.

Report to supervisor and complete appropriate documentation/ reporting

REPORT as quickly as possible.

If an immediate threat to human health or the environment does not exist the contractor
will arrange for safe cleanup of the spill. If a threat to human health or the environment
exists contractors are required to immediately notify the BPJV ES&H Manager or BPJV
Project Environmental Lead.

All spills are to be reported to BPJV in accordance with the incident reporting, recording
and investigation procedure (25875-000-GPP-GHX-00032).

5.1 Disposal Requirements

Absorbents and spill clean-up materials (including contaminated soils) are to be disposed
of into the hazardous waste bins. At all times, Contractors will be responsible for the
proper packaging, labelling, and classification of all wastes prior to offsite transport or
disposal. Bags containing used clean up materials will be transported to the designated
hazardous material/waste storage on site, prior to being disposed of offsite in accordance
with the Shaheen Project Waste Management Plan.

6.0 SITE INSPECTION AND MONITORING

Contractors are required to maintain their equipment in accordance with manufacturers
specifications. Documented evidence of scheduled and preventative maintenance shall
be made available to Bechtel upon request for any equipment on site. Contractors shall

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Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

regularly maintain their equipment maintenance areas and discard hoses that are past
their nominated shelf life.

BPJV Supervisors and/or ES&H will conduct weekly inspections of work areas with
Contractors that shall include spill prevention and response capabilities including:

 Spill kit availability and stocking levels

 Hazardous substance management
 Hazardous waste segregation compliance
 Evidence of unmanaged spills around site.

An Inspection Report will be completed for each work area and any issues (e.g. location
or conditions of storage areas) shall be actioned for correction. Contractors are expected
to conduct daily walk downs of work areas that include, at a minimum, the above
requirements.

BPJV may conduct random inspections of specific operations (e.g. refuelling operations)
at any time. Equipment and vehicle operators shall conduct pre-shift inspections on
equipment to check for leaks, deficiencies, damage or wear and tear that may lead to a
spill (e.g. split or damaged hydraulic hoses, loose or damaged fittings or hoses etc.). Any
deficiencies shall be reported immediately to Supervision.

Contractors shall perform periodic preventive maintenance on equipment to minimise the

potential for spills or leaks, and ensure spill kits are stocked and available. All inspections
shall be documented, with corrective action(s) identified and closed out as soon as
practicable.

7.0 TRAINING
All personnel, including Contractors, working at the Project site shall be briefed in
prevention of spills and cleaning up and the process for reporting incidents. Operators
that have specific duties under this Plan will be trained by the Contractor.

8.0 REFERENCES
 25875-000-2HY-H01-00002 - Construction Environmental Control Plan
 25875-000-2HY-H01-00003 – Waste Management Plan
 25875-000-GPP-GHX-00027 – Hazardous Substances Procedure
 25875-000-GPP-GHX-00032 - Incident Reporting, Recording and Investigation

9.0 DOCUMENT MANAGEMENT

Rev # Date: Changes

Confidential © 2014 Bechtel/Petrofac Joint Venture for Project Shaheen. All rights reserved.

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
25875-000-2HY-H01-00008 Rev 000 Page 8 of 9
Project Shaheen SPILL PREVENTION AND RESPONSE PLAN

Confidential © 2014 Bechtel/Petrofac Joint Venture for Project Shaheen. All rights reserved.

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the electronic documents in the project electronic database for current revisions.
25875-000-2HY-H01-00008 Rev 000 Page 9 of 9