Date : Mar.

8, 2021 MS-DD-3000-HSE-PLN-0017
Inclement Weather Plan
Rev. : 0 Page：1 of 11

INCLEMENT WEATHER PLAN

OWNER: PT. FREEPORT INDONESIA

MANYAR SMELTER PROJECT

PT CHIYODA INTERNATIONAL INDONESIA

0 Issued for Construction Mar. 8, 2021 P.Apanay L.V.Schalkwyk / N.Suzaki T.Matsunaga

D Issued for Detailed Engineering Jan. 28, 2020 P.Apanay L.V.Schalkwyk / N.Suzaki T.Matsunaga
Rev. Description Date Prepared Reviewed Approved

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
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Purpose .......................................................................................................................... 3
Scope ............................................................................................................................. 3
Reference ....................................................................................................................... 4
Terminologies and Abbreviations .................................................................................... 5
Responsibility .................................................................................................................. 6

Cranes ............................................................................................................................ 9
Lorry / Lift Trucks ............................................................................................................ 9
Light Vehicles ................................................................................................................. 9
Scaffolds ......................................................................................................................... 9

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
Inclement Weather Plan
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INTRODUCTION
Purpose

The purpose of the Wet Weather Preparation Plan is to provide all levels of Project
Management with a guideline to what precaution and actions are required to
minimize the risk to personnel and damage to properties resulting from high winds,
thunderstorms, lighting, heavy rain and flooding.

Scope

The Wet Weather Preparation Plan outlines when the severe weather,
thunderstorm, flood protection procedure initiates and points at what actions will be
taken on the project site. The plan defines the periods when actions must take place
and will be used in conjunction with the individual action plans.
The plan identifies resources and delineates responsibilities to ensure all possible
protection is provided in the event property, construction equipment and most
importantly, employee safety is threatened by a tropical cyclone, thunderstorm, high
winds, lighting or heavy rain.
This plan provides criteria to be used in determining when actions will be taken in
the event of possible exposure to a storm system. Further, it delineates those
advanced preparations that are necessary to maintain a state of readiness for all
areas of the project during rainy season (November to March).
Each Subcontractor will develop a specific Inclement Weather Preparation Plan for
their work activities and must include their equipment and materials. When the
Indonesia Badan Meteorologi Klimatologi Dan Geofisika (BMKG) (Meteorological,
Climatological, and Geophysical Agency) announces there is a Tropical Cyclone
that could impact the project, the Construction Manager and Field SHES Manager
will determine the course of action to be taken.
As inclement weather conditions may range from extreme heat, storm fronts and
high wind conditions, it can lead to secondary conditions, such as poor visibility due
to haze, dust, fog, sandstorms, rain and flooding.
Specific standalone plans were developed and should be referenced:
 MS-DD-3000-HSE-PLN-0013: Traffic Management Plan
 MS-DD-3000-HSE-PLN-0015: Heat Stress Prevention Program
 MS-DD-3000-HSE-PRO-0002: Excavation and Ground Penetration Procedure
 MS-DD-3000-HSE-PRO-0003: Mobile Plant and Equipment Procedure
ALL RIGHTS RESERVED
THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
Inclement Weather Plan
Rev. : 0 Page：4 of 11

 MS-DD-3000-HSE-PRO-0013: Scaffolding Procedure

Reference

Owner Document
Document Number Document Title
February 2020 Freeport - McMoran Contractor Health and
Safety Manual
February 2015 Freeport - McMoran Safety and Health
Policy
FCX-HS32 Crane & Rigging Policy

Contractor Document
Document Number Document Title
MS-DD-3000-HSE-PLN-0001 Safety, Health, Environmental, and
Security Management Plan
MS-DD-3000-HSE-PLN-0007 Risk and Hazard Management Plan
MS-DD-3000-HSE-PLN-0013 Traffic Management Plan
MS-DD-3000-HSE-PLN-0015 Heat Stress Prevention Program
MS-DD-3000-HSE-PRO-0001 SHES Instructions to Subcontractors
MS-DD-3000-HSE-PRO-0002 Excavation and Ground Penetration
Procedure
MS-DD-3000-HSE-PRO-0005 Safe Work Practices Procedure
MS-DD-3000-HSE-PRO-0003 Mobile Plant and Equipment Procedure
MS-DD-3000-HSE-PRO-0013 Scaffolding Procedure

International Regulations and Standards

Document Number Document Title
OHSAS 18001:2007 Occupational Health and Safety

Management Systems – Requirements

ISO 45001:2018 Occupational Health and Safety

Management Systems
OSHA 29 CFR 1926 Safety and Health Regulations for
Construction
OSHA 29 CFR 1910 Occupational Safety and Health Standards

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
Inclement Weather Plan
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ILO-OSH 2001 Guidelines on occupational safety and

health management systems

Government References and Relevant Legislations

Document Number Document Title
Law No. 1 of 1970 Indonesia Law on Occupational Safety
Act 13 of 2003 Indonesian Labor Law
Gov’t Reg. No. 50 of 2012 Occupational Safety and Health
Management System Implementation
N/A Indonesia Meteorological, Climatological,
and Geophysical Agency

Terminologies and Abbreviations

Terminologies
Terminologies Definitions
Contractor PT. Chiyoda International Indonesia (CII)
Owner PT Freeport Indonesia (PTFI)
Subcontractor Any company to whom Contractor has
subcontracted any part of the works.
Works All and any parts of the works and services
by Contractor
Worksite Any location where work for the site is
carried-out

Abbreviations
Abbreviations Definitions
ALARP As Low As Reasonably Practicable
BMKG Badan Meteorologi, Klimatologi, Dan
Geofisika (Meteorological, Climatological,
and Geophysical Agency)
ERRP Emergency Response & Rescue Plans
GOI Government of Indonesia
SHES Safety, Health, Environment, and Security
WMS Work Method Statement

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
Inclement Weather Plan
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Responsibility

A. Contractor Site Manager

The Site Manager shall be responsible for the implementation of the relevant plan.
When conditions worsen to the extent that the safety of personnel could be at risk,
He shall ensure that, counter measures are put in place to protect and safe guard
personnel and assets.

B. Contractor Field SHES Manager

The Field SHES Manager is responsible to monitor, update and distribute weather
and meteorological notices/ reports on a regular basis. This will allow for a greater
period of warning for potential of severe weather that may occur within the
surrounding area. The Field SHES Manager shall:
 Ensures that the daily forecast are updated and displayed on all SHES Bulletin
Boards.
 Obtain accurate information from Badan Meteorologi, Klimatologi, Dan
Geofisika (https://www.bmkg.go.id/), to track weather systems that could affect
the project.
 Notify and assemble the Project Crisis Management Team in the event of
adverse inclement weather approach that may affect the project.

C. Crisis Management Team

The Crisis Management team comprised of Contractor and Subcontractor
Management shall activate and assemble as described in MS-DD-3000-HSE-PLN-
0006 - Emergency Response Plan.

LIGHTNING

Lightning results from the build-up and discharge of electrical energy between
positively and negatively charged areas. Rising and descending air within a
thunderstorm separates these positive and negative charges. Water and ice
particles also affect charge distribution. A cloud-to-ground lightning strike begins as
an invisible channel of electrically charged air moving from the cloud toward the
ALL RIGHTS RESERVED
THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
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ground. When one channel nears an object on the ground, a powerful surge of
electricity from the ground moves upward to the clouds and produces the visible
lightning strike.
Contractor will be monitoring the weather on site based on the warnings issued by
BMKG and will be utilizing "StrikeAlert" or similar device to monitor lightning. The
Flash/ Bang technique will also be used to estimate the distance of lightning.
Warnings shall be given to site personnel when lightning approaches the project.
The decision to take shelter will be given by the Site Manager and FSHESM on site.
The distance from the lightning to the worksite can be determined by using the
Flash/ Bang technique adopted from the National Lightning Safety Institute of the
United States to help measure storm proximity.
Flash to bang is the time from seeing the strike to hearing the thunder. For each 3
second count lightning is 1 kilometer away. At a count of 30 seconds lightning is
approximately (10 kilometers or less), while at a count of 15 seconds the proximity
would be approximately 5 kilometers and a count on 9 seconds the proximity would
be 3 kilometers. Therefore, when thunder is heard and the Flash/Bang ratio is
calculated to be 30 seconds representing 10 kilometers, supervisory personnel will
inform field personnel (i.e. radio call) of the potential for lightning in the area. This
will create a readiness and awareness for the next step should the storm moves
closer.
 If the Flash/ Bang intensity increases to a value of 15 seconds (5 kilometers),
supervisory personnel will suspend all crane hoisting and elevated work
activities. Workers will proceed to the ground area and evacuate into a large
building, rest shelter, busses staged in the work areas or enclosed vehicle.
Electrical conductors including power lines, tall objects, high places and bodies
of water attract electricity and lightning. Metal items like tools, scaffold poles
and bicycles will conduct electricity, so avoid using them when a storm
approaches.
 Ensure all lifting activities have been suspended, and secured. Mobile lifting
equipment shall insure that booms are in a down position, out riggers are
raised up to allow for tires to be resting on the ground. Larger lifting equipment
and tower cranes to be properly grounded.

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
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 Qualified subject matter experts to confirm temporary site power has be

grounded independently or connected to the grouping grid, and unplug all
unnecessary electrical equipment on site and in offices.
 If the Flash/Bang reaches a level of 9 seconds (3 kilometers), all external work
on site shall be suspended, and if deemed required by the Site Manager, work
force returned to accommodation via buses.

TROPICAL CYCLONE / STORM

Tropical storms and named cyclones are a reoccurring event in southern Indonesia.
The storms have produced strong winds and heavy rainfall in the past causing flood
and heavy damage in Indonesia.
 In the event of a tropical storm/ cyclone threat, the Site Management will meet
to evaluate the new/ updated information received from BMKG, prepare a
timeline for preparation of activities, and update the progress during the daily
construction meeting.
 Warnings shall be given to site personnel when a tropical storm is approaching
the area. The decision to make early preparations, change to scheduled work
activities will be given by the Project Manager and FSHESM. The conformation
shall then be cascaded for early information regarding the potential event.
 Areas and/ or buildings throughout the project may require sandbagging as a
preventive measure to control flooring. A build-up of dirt berms around
evaporation ponding may also be essential based on the status of the ponds
pre-storm season.
 Preparation should involve the tie-down of stored materials and equipment that
are at risk of strong winds being blown away. If not on stable foundations
equipped for uplift, field offices/toilets should be tied down.
 Ensure that all containers are closed/covered and protected in hazardous
materials storage.

HIGH WINDS AND ABNORMAL WEATHER CONDITION

This plan address the various weather conditions that have a potential to effect the
integrity of equipment or expose site personal to unwarranted danger in which lifting
ALL RIGHTS RESERVED
THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
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operations shall be stopped. (I.e. excessive wind speed, poor visibility due to mist or
fog, storms, lighting, and heavy rain). The FSHESM is responsible for update and
distribute weather and meteorological notices/ reports on a daily basis. This should
allow for a greater period of warning for potential severe weather that may occur
within the surrounding area. Site personnel should take additional precautions at this
time.

Cranes

Cranes shall not be utilized in weather conditions the could affect the safety of
personnel, and in wind speed exceeding 10m/s average wind speed in 10min and/or
30m/s maximum instantaneous wind speed, or in excess of the values set out by the
equipment manufactures whichever is less.

Lorry / Lift Trucks

All lorry/ lift trucks operation shall halt where weather conditions are bad enough to
adversely affect the performance of the equipment or expose the operator to
danger.

Personnel Transport
Personnel transport vehicles movement will be restricted to as needed basses.
During low visibility conditions i.e. fog and sand storm. Headlights and other
installed signal/ warning beacons should be operated and remain active throughout
the incidents operations. Flashing hazard lights should NOT be used unless the
vehicle has moved off the road and has stopped traveling.

Light Vehicles

Light vehicles movement will be restricted to as needed basses. During low visibility
conditions i.e. fog, and night. Emergency warning beacon lights, headlights, and
other installed signal/ safety lights should be operated and remain active throughout
the abnormal weather conditions. Flashing hazard lights should NOT be used unless
the vehicle has moved off the road and has stopped traveling. Unpaved roads
should be avoided during weather events.

Scaffolds

Competent Scaffold Inspectors shall re-inspect scaffolds after severe weather.

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
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When a high wind/ wet weather alert has been cancelled or there is no longer a
threat to site, an “All Clear” notification will be issued. Before commencement of
work, Competent Personnel shall carry out a full inspection in their respective areas,
report on site conditions and evaluate the potential hazards. This assessment
should form the basis of the return to work plan in the area. A report will be given to
the Site Management before site work returns to normal duties.
Structures that may have been affected by high winds:
 Site facilities and amenities;
 Construction equipment.

WET WEATHER PREPARATIONS

In the event of rain, the following shall be implemented:

 Workers shall not be allowed to enter an excavation or trench that contains
flowing water or standing water greater than 10 cm in depth;
 Trenches and open hole to be inspected by a competent person to insure wall
integrity post heavy rain events;
 Prior to worker entry, confined space excavations or trenches (1 m or greater
in depth) must be stabilized by shoring, engineer designed side slopes, or
sheeting/ bracing unless it is a hard rock;
 Ensure that access and egress to and from the work location is secure and
cannot be flooded;
 When rain creates a hazard to craftsmen on work being performed (i.e.,
unstable footing conditions due to slippery structural steel, muddy and flooded
work environments, unstable trenches or excavations, poor visibility due to rain
or eye protection) supervision shall stop specific work due to the hazards, re-
assign work duties and/ or working areas, and obtain further instructions from
Site Management;
 Minimize the amount of wet weather work to be done at height;
 All Electrical operated equipment and power tools should be inspected by
qualified electrical technician prior to utilization after it exposed and/ or contact
with water/ rain;
 De-energize all unnecessary electrical power. Ensure all temporary electric
cables are raised to a safe height above the ground;
ALL RIGHTS RESERVED
THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.
Date : Mar. 8, 2021 MS-DD-3000-HSE-PLN-0017
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 Water levels in evaporation ponds, secondary containment areas for

hazardous chemical storage (including tanks and other large volume storage
containers) to be maintained at the lowest possible levels to allow for seasonal
rain fall. De-watering of standing/ pooling rainwater to be pumped to approve
locations. There shall no discharge directly into natural water ways;
 Contractor and Subcontractor shall have pumps on standby to respond to wet
weather and pump out trapped water in emergency situations.
 Stockpiles of soil to be inspected to confirm stability.

ALL RIGHTS RESERVED

THIS DOCUMENT WAS PREPARED FOR THE EXCLUSIVE USE OF PT FREEPORT INDONESIA (PTFI) AND CHIYODA GROUP PURSUANT TO THE ENGINEERING,
PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN PTFI AND PT CHIYODA INTERNATIONAL INDONESIA. THIS DOCUMENT IS THE PROPERTY OF PTFI,
AND THIS DOCUMENT, DATA AND INFORMATION MAY BE DISCLOSED TO THIRD PARTIES ONLY FOR THE MANYAR SMELTER PROJECT. CHIYODA GROUP SHALL
NOT BE LIABLE FOR USE OR RELIANCE ON THIS DRAWING BY ANY THIRD PARTY NOT UNDER THE DIRECTION OF CHIYODA GROUP, UNLESS OTHERWISE AGREED
IN WRITING.