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Nimba Western Range Iron Ore Project, Liberia Environmental and Social Studies, 2008-2015

Project Phase 2: Concentrator Environmental and Social Impact Assessment

Volume 6, Part 3.7:

Environmental Management Plan: Hazardous Materials and Waste March 2013

Hazardous Materials and

Waste Management Plan

for Project Phase 2

VERSION DATE: 1 MARCH 2013

ArcelorMittal Liberia Ltd.

P.O. Box 1275 Tubman Blvd at 15

th Street

Sinkor, Monrovia Liberia

T +231 77 018 056

www.arcelormittal.com

Nimba Western Range Iron Ore Project, Liberia

Environmental and Social Studies, 2008-2015: Project Phase 2 – Concentrator Hazardous Materials and Waste Management Plan

Version: 1 March 2013 of 65

Contents

List of Abbreviations ................................................................................................................................ 3

1. OPERATIONAL PRACTICES (DO’S AND DON’TS) ...................................................................... 4

1.1 General Environmental Management ..................................................................................... 4

1.2 Management of Hazardous Materials ..................................................................................... 5

1.3 Waste Management .............................................................................................................. 10

2. INTRODUCTION ........................................................................................................................... 16

2.1 The Hazardous Materials and Waste Management Plan ..................................................... 16

2.2 Outline of Waste Generation and its Management ............................................................... 16

2.3 References ............................................................................................................................ 17

3. ARCELORMITTAL ENVIRONMENTAL POLICY .......................................................................... 18

4. ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS .................................................. 20

5. ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES ........................................ 22

5.1 Storage of Materials .............................................................................................................. 22


5.3 Health and safety of workers ................................................................................................. 23

5.4 Worker Facilities .................................................................................................................... 23

6. EMERGENCY RESPONSE PLAN................................................................................................ 24

7. ENVIRONMENTAL COMPLIANCE CONTROLS ......................................................................... 29

7.1 Environmental Awareness Briefing for Site Crews ............................................................... 29

7.2 Environmental Compliance Review Meetings ....................................................................... 29

7.3 Local Consultative Forums .................................................................................................... 29

7.4 Environmental Compliance Inspections and Documentation ............................................... 30

8. RESPONSIBILITIES ..................................................................................................................... 31

8.1 Organisational structure ........................................................................................................ 31

8.2 The Company ........................................................................................................................ 33

8.3 The Engineering and Procurement Management Consultant ............................................... 35

8.4 Contractors ............................................................................................................................ 35

8.5 Employment Policy ................................................................................................................ 36

9. IDENTIFIED POTENTIALLY HAZARDOUS MATERIALS AND WASTE STREAMS .................. 37

9.1 Potentially Hazardous Materials Used in all Parts of the Company’s Operations ................ 37

9.2 Component-specific Potentially Hazardous Materials and Waste Streams .......................... 38

10. PLAN MANAGEMENT AND ITS MONITORING ...................................................................... 41

10.1 General Principles of Environmental Management............................................................... 41

10.2 Hazardous Materials Management ....................................................................................... 43





List of Abbreviations AML ArcelorMittal Liberia

CEMP Contractor’s Environmental Management Plan

CLO Community Liaison Officer

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPA Environmental Protection Agency

EPML Environmental Protection and Management Law

ESIA Environmental and Social Impact Assessment

FDA Forestry Development Agency

FONSI Finding of No Significant Impact

HSE Health, Safety and Environment

MDA Mineral Development Agreement

MSDS Material Safety Data Sheet




1. OPERATIONAL PRACTICES (DO’S AND DON’TS) The Operational Practices for all Employees and Contractors are listed in the table below. These are based on the Project Briefs and the Environmental and Social Impact Assessment approved by the Environmental Protection Agency, and are therefore legal and contractual requirements. The Operational Practices are intended to be low in cost, practical and easy to apply. If an Employee or Contractor has a reason to request modification, he should raise the matter with the Environmental Superintendent: as part of the Environmental Management Plan, the Operational Practices can be modified according to site experience.

1.1 General Environmental Management

General Principles of Environmental Management

Employee and Contractor compliance obligations Applicable standard (see Standards

Manual) What you MUST do What you must NOT do

General principles

Avoid damage to any part of the environment (soil, plants, animals, human resources and settlements) as far as possible.

If damage cannot be avoided, then mitigate or compensate for the damage.

Follow the ArcelorMittal Environmental Policy.

Respect the environment: we have only one planet!

General principles

Undertake any work beyond the agreed boundaries of the work sites.

Undertake any work before agreeing mitigation or compensation arrangements.

Hide any damage or pollution. In the event of an accident, it is better to consult the Environmental Team and agree a mitigation plan than to risk prosecution under the law.

Section 5 of this EMP.

Standards 13.1 to 13.3.

Environmental awareness

Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main environmental messages.


Allow staff and workers to neglect environmental issues. This may lead to offences under the Environment Protection and Management Law.

Standard 12.1.

Respect for local communities

Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main messages regarding respect for the local communities.

Ensure that all professional and technical staff respect the local communities and behave well.


Ignore blatant disrespect for communities by professional and technical staff.


Provision of safety equipment

Provide all workers with safety equipment appropriate to the work that they are doing

Keep first aid kits on all work sites.

Ensure that there are two people on each work site who know what to do if there is an accident and how to use the first aid kit.

Remember that safety gear is cheaper than hospital and funeral bills!


Allow workers on to a site without the appropriate safety gear.

Allow first aid kits to become empty or out-of-date.

Standard 1.1.

H&S Manual and Rules.




1.2 Management of Hazardous Materials

Hazardous Materials Management



Sanitation at temporary work sites

Provide proper earth pit latrines at all work sites where more than 5 people will work for more than 1 day at a time.

Fill the latrines in once site work is complete.


Allow latrines to become full or overflow.

Allow site workers to defecate at random in the forest.

Standards 1.2, 1.3.

Pollution from site camps and stores

Ensure that all potentially hazardous materials (i.e. fuel, oil, other chemicals, sewage) are stored or disposed of in appropriate ways.

Provide spill, leak and leachate collection systems in storage areas to avoid land contamination.

Devise on-site emergency spillage plans and train staff in their implementation.

Remove all debris and litter from site.

Display name and appropriate caution boards.


Allow any pollution to occur to the soil or water courses.

Allow haphazard dumping of any solid or hazardous wastes.

Allow storage on open earth ground.

Standards 9.1, 10.1, 10.2 and others as appropriate.

Fuel and oil storage

Follow the hazardous materials management guidelines fully.

Only use the designated storage areas , with bunding of 150% volume of total capacity

Only use facilities located down gradient of public water supply boreholes and distant from watercourses.

Ensure that there are retention systems, including walls, bunds and lined drains to contain any spillages.

Ensure that there is hard standing, with a drainage system that includes oil/water separators.

Provide caution boards on fire risks and for no smoking.

Ensure spill kits and granules are available.

Have controls in place to minimise opportunities for fuel pilferage.

Dispose of waste appropriately.

Maintain Emergency Response / Fire Fighting teams trained for a spillage event.

Maintain fire fighting equipment at each facility.

Display fire caution and emergency contact boards.

Display operational and control procedures.

Provide training for all personnel handling fuel and oil.


Allow uncontained spills and leakages to occur, leading to soil, and ground and surface water contamination.

Allow soils to become contaminated and effectively sterilised.

Allow water courses to be affected by runoff carrying toxic substances, affecting community water supplies, aquatic biodiversity and wildlife.

Allow waste products that are not collected and stored appropriately to contaminate the surroundings.

Allow emissions of exhausts to pass outside the site.

Allow theft to occur, resulting in spillage and pollution elsewhere.

Allow any potential for explosions to occur.

Standards 9.1, 10.1, 10.2, and 11.1 to 11.6 inclusive.







Refuelling vehicles and machines

Follow the hazardous materials management guidelines fully, which include procedures for refuelling vehicles and generators.

Spill kits are to be carried by all refuelling vehicles.

Keep all fuel tanks in a central location.

Refuel vehicles only on impermeable hard standings with controlled drainage (traps and interceptors).

Plant refuelling on site is to be carried out according to strict protocols for refuelling in unprotected areas.

Enforce the reporting system for spillage incidents.

Train Emergency Response / Fire Fighting teams in readiness for a spillage, fire or other accident.

Keep fire fighting equipment available at each facility.

Provide training for all personnel handling chemicals.


Allow spills and leakages to go uncontained leading to soil, and ground and surface water contamination.






Refuelling ships at sea

Establish reliable communications between the two vessels before starting the berthing manoeuvres.

Ensure that the appropriate checklists in section 9 of this EMP have been completed by the Master of each vessel before commencing each stage of the operation.

Follow the ship-to-ship mooring procedure rigorously, with special care in fendering and in ensuring that there is no metal-to-metal contact.

Operate international best practices for ship refuelling and shipping operations, following the MARPOL 73/78 (irrespective of whether the authority of registration of the ship is a signatory).

Clean all working areas on both ships immediately after each refuelling operation.

Make ship operators contractually bound to follow national regulations and international conventions on dumping and the prevention of pollution at sea.

Ensure that the tug based in Buchanan is on short notice standby with sufficient amounts of fire-fighting foam and oil dispersant.


Permit any spill or discharge of oil into the sea.

Attempt refuelling if sea or weather conditions are not good enough.

Hesitate in stopping the operation if anything goes wrong or if weather conditions deteriorate.

Undertake refuelling if any artisanal fishing boats are in the selected area.

Use any hoses or equipment that does not meet the high standard of condition required of checks under international best practice.


Ships’

Emergency Response Plans.







Refuelling ships in port

Ensure that all appropriate pre-operation checks have been made and effective communications are in place between the ship’s crew and the shore party.

Ensure that the chartered tugs are fully enabled with tanks of fire-fighting foam and oil dispersant, and are standing by close to the vessel being refuelled.

Ensure that the shore-based fire fighting crew and the spill clean-up crew are prepared and standing by on the quay before the operation starts.


Make ship operators contractually bound to follow national regulations and international conventions on the prevention of pollution at sea.


Permit any spill or discharge of oil into the harbour basin.

Hesitate in containing and cleaning up any accidental spills that may occur.

Hesitate in stopping the operation if anything goes wrong.


Standards 9.1 to 9.4, 10.1, 10.2.

Early warning system (see section 6.1 of this EMP).

Emergency Response Plan (see section 6.2 of this EMP).

Delivery and handling of hazardous materials


Use the safest available transportation option, preferably rail.

Use Transport Emergency (TREM) cards during transportation.

Use manifests during transportation.

On roads, use convoys with accompanying support.

Deliver only to prepared locations.

Maintain supplies of spill kits and granules in all vehicles and at all offloading locations.

Ensure competent drivers and close supervision.

Provide emergency training to all personnel.

Use international labelling for identifying hazardous substances.

Comply with international standards and guidelines (e.g. OHSAS, UK COSHH).




Transport hazardous materials on public highways without having supporting vehicles in convoy to take immediate containment action in the event of an accident.

Allow any ground and water contamination from toxic materials.

Allow any potential for explosions and fires to occur.

Standards 9.1, 10.1, 10.2, 10.3.







Chemicals storage and use


Train operators on safety for handling chemicals and interpreting MSDS.

Select chemicals with the least environmental impact where possible.

Use only chemicals that are certified for use world-wide and approved by the Liberian EPA.

Minimise the volumes of chemicals stored, and reuse them where possible.

Chemicals should be stored down gradient of any public water supply boreholes.

Ensure that all containers are clearly labelled. Labelling must include non-verbal warning signs.

Provide secondary containment for all chemicals.

Provide chemical spill kits.

Ensure that the MSDS is held for every chemical on site.

Display the appropriate MSDS at storage locations.

Carry Transport Emergency cards during transportation.

Store chemicals separately, according to their natures and properties.

Ensure the availability of appropriate Personal Protective Equipment (PPE).

Ensure the availability of Chemical Spill Kits during storage, handling and transportation.





Allow any loss of containment from spills or inadequate disposal.

Allow any chemicals to spill or leak to the environment with toxic effects to soil and water.

Use any chemicals that are not approved by both the Company’s HSE Manager and the EPA.

Use any chemicals known to be mutagenic or which contain substances which bio-accumulate.

Allow any use of chemicals except by fully trained workers.

Allow the use of chemicals in confined spaces if they pose any potential for explosions.

Handle chemicals without PPE.

Standards 9.1, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.

Rail Ties (Railway Sleepers)

Minimise the number of spare rail ties kept in stock.

Keep all ties in a single location.

Wherever possible, keep rail ties under a permanent cover, in a well-ventilated place.

In temporary storage locations, ensure complete coverage of the ties and full bunding and filtration of drainage water that might contain creosote leachate.


Have numerous small stocks of rail ties.

Maintain any temporary stocks within 200 metres of a water course.

Allow even small numbers of rail ties to be uncovered during rain.

Standards 9.1, 10.1, 10.2, 10.4.







Handling, storage and use of explosives

Follow exactly the procedures given in the standard for the use of explosives.

Comply with national legislation and permitting requirements.

Liaise as required with Ministry of Lands, Mines and Energy.

Store explosives and detonators to international and manufacture's specifications.

Ensure that explosives are stored away from habitation.

Provide appropriate emergency and caution boards in the storage and handling areas.

Avoid blasting in high risk areas, if any are identified.

Train operators on all aspects of safety in the handling and use of explosives.

Train Emergency Response / Fire Fighting teams in readiness for an emergency, fire or other accident.

Keep fire fighting equipment available at site.

Provide training for all personnel handling explosives.


Permit any risks of security or potential for theft to arise in the transport and storage of explosives.

Allow standards to slip in such a way as to increase the potential for accidents due to unplanned explosions.

Relax site boundary patrols to allow trespassing by the local population (e.g. hunters, children).

Standard 10.8.




1.3 Waste Management

Waste Management – General



Waste generation and management

Operate a waste management strategy based on a principle of reduction, recovery, recycle and reuse.

Collect and segregate waste into hazardous and non-hazardous at the source.

Avoid waste spills during storage and handling.

Dispose of all waste in an appropriate manner.

Maintain full records of the types and quantities of waste generation, storage, transfers and disposals.

Conduct recycling and waste reduction campaigns.

Ensure use of PPE by staff when handling all forms of waste.


Allow an inadequate waste collection, segregation, storage and disposal system to result in environmental degradation, contamination, and hazards to human and animal health.

Allow an increase in disposable income among employees to create more waste, both quantity and type, without challenging perceptions.

Allow spillages of wastes during storage and handling.

This Plan.

Waste disposal

Dispose of wastes in the most environmentally sound manner possible.

Design and construct a landfill site that is lined and to international standards. This should be in an area that is not prone to slippage, cannot leach to surface water and groundwater, and is a suitable distance from settlement. It should be located down gradient of any water supply boreholes.

Ensure that the landfill site is in a secure compound.

Ensure landfill operations conform to international standards.

Deal with hazardous waste according to international best practice and EPA guidelines.

Dispose of wastes to EPA-authorised facilities.

Incinerate medical waste in an EPA-approved facility.

Waste disposal

Continue to use the present landfill site.

Allow the incomplete burial of waste and the lack of a secure compound to lead to scavenging.

Allow injury to persons or the environment from waste, resulting in company liability.

Allow unauthorised persons into storage areas

Allow an inappropriate site to give negative visual and odour impacts.

Burn waste, creating air pollution.

Landfill site design standard in preparation by SNC Lavalin.

Waste from ship operation

Dispose of oily water in suitable shore reception facilities if the ship is not sailing into international waters (where the oil-water separator can be used.

Ensure that garbage is disposed of properly at shore reception facilities.

Operate only approved shipboard incinerators, and only when the ship is at sea.

Treat sewage with a USCG approved Hamworthy sewage treatment plant which also has a steriliser unit.

Ensure that sewage is disposed of properly at shore reception facilities.

Maintain proper record books for the ship-board management of oil, cargo and garbage.


Allow the spillage of any kind of oil without taking immediate clean-up action.

Discharge any untreated sewage into the sea.

Operate ship-board incinerators within the breakwaters of the Port of Buchanan.

Dispose of cargo wash-water within Liberian territorial waters.

Standard 9.4.




Management of Waste Classed as Potential Company Assets



Topsoil

Minimise waste by disturbing the soil only where it is necessary to do so.

Remove topsoil carefully, by scraping off in thin layers.

Save topsoil in shallow stockpiles.

Re-vegetate stockpiles to prevent erosion and maintain soil quality.

Return the topsoil to rehabilitated areas once work has been completed.

Topsoil

Send topsoil to spoil tips.

Allow traffic to run on topsoil, causing it to become compacted.

Allow the erosion or contamination of topsoil.

Standards 6.4, 6.11 to 6.14.

Scrap Iron and Steel

Re-use metallic objects and machinery as far as it is practicable and safe.

Stockpile scrap in a safe area.

Send to a scrap plant within ArcelorMittal or auction against company rules.


Place scrap into landfill sites.

Allow scrap to be stolen by informal scrappers.

Sell scrap without following Company guidelines.

AML Procurement and Finance Rules.

Non-ferrous Metallic Scrap

(e.g. aluminium, copper and lead)

Re-use metallic objects and components as far as it is practicable and safe to do so.


Ensure that copper and lead scrap are kept in dry locations, such as shipping containers.

Auction against company rules.

Non-ferrous Metallic Scrap

(e.g. aluminium, copper and lead)





Used Commercial and Industrial Machines (vehicles, trucks, generators etc)

Reduce waste production by using machines for their full design life, and repairing rather than replacing them.

Store used machines securely, in a bunded and covered storage area.

Decommission machines thoroughly. Remove all fuel and lubricants, and degrease moving parts.

Sell usable scrap as a Company asset (see above).


Place used machines in landfill sites.

Sell used machines to unauthorised companies, uncertified small enterprises or individuals who might re-use their components without proper disposal of unwanted parts.


Used Oil Drums

Store used oil drums securely, in a bunded and covered storage area.

Recycle oil drums for waste oil or other appropriate uses.

Used Oil Drums

Sell used drums or any parts of them to unauthorised companies or uncertified small enterprises.

Wash oil drums in open water courses or non-filtered drains.

Standard 10.1.




Management of Unwanted Waste



Vegetation

Minimise waste by only cutting vegetation that is in the way. This means plants that are in the direct area required for access tracks, mining areas or other purposes.

Cut vegetation small and stack beside the working area to decompose slowly.

Forbid pit sawing in areas influenced by the Company as far as possible, and use the security force to discourage this practice.

Vegetation

Cut more vegetation than is necessary for site access and working.

Use fire to remove vegetation.

Burn cut vegetation.

Cut any plantations without following the procedures given in the Resettlement Manual.

Standard 2.1.

Spoil (overburden)

Minimise waste by removing spoil only where it is essential to do so.

Place spoil only in designated spoil tip sites.

Prepare spoil tip sites in advance, particularly for drainage blankets and slope toe retaining walls.

Place spoil in shallow layers, compacting and shaping them as they develop.

Provide erosion protection as necessary.

Monitor the water regime and stability of spoil tips and take action as required.

Spoil (overburden)

Place spoil anywhere that has not been approved, even temporarily.

Allow a steep and potentially unstable spoil tip to develop.

Continue using spoil tips when the designated area has been used up.

Allow erosion to occur.

Impede any watercourse or drainage line without making provision for through flow.

Standard 6.3.

Contaminated soils

Avoid contamination of soil by adhering to the hazardous materials storage and handling standards (see tables above and relevant standards).

Remove contaminated soil to a level and secure area, surrounded by an earth bund.

Treat the contaminated soil fully using an approved bioremediation agent.

Restore the area affected, either using appropriate topsoil from a stockpile, or by replacing the remediated soil as soon as it has been decontaminated.

Contaminated soils

Leave soil untreated if there has been any spill of hydrocarbons or other chemicals.

Try to speed up or avoid part of the bioremediation process.

Dump contaminated soils anywhere.

Standard 10.2.

Standard for soil bioremediation in preparation. Approach depends on nature of contamination.

Used Lubricants

Reduce waste production by using lubricants for their full design life.

Store used lubricants securely, in strong, leak-proof drums in a bunded and covered storage area.

Provide spill kits in storage and handling areas.

Try to use internally, where low fuel quality is acceptable, such as in incinerators.

Sell used lubricants to large rubber factories for use in the boilers.

Used Lubricants

Pour away any form of used lubricant, into either the soil or into water.

Sell used lubricants to chain saw operators.

Standard 10.1.







Used Grease

Reduce waste production by using grease for its full design life.

Store grease securely, in strong, leak-proof drums in a bunded and covered storage area.

Incinerate used grease at a high temperature in a proper industrial incinerator.

Used Grease

Place in landfill sites.

Standard 10.1.

Used Filters (fuel and oil filters)

Reduce waste production by using filters for their full design life.

Store used filters securely, in strong, leak-proof containers in a bunded and covered storage area.

Sell used filters for recycling by regular companies with a current Environmental Certificate issued by the EPA.

Alternatively, incinerate used filters in a purpose-dug pit. Place the residue into an approved landfill site.


Place any used filters in landfill sites.

Sell used filters or any parts of them to unauthorised companies or uncertified small enterprises.

Standard 10.1.

Used Containers (paint tins, pesticide containers, etc)

Store used containers securely, in a bunded and covered storage area.

Send used paint tins and pesticide containers to an approved landfill site.

Used Containers (paint tins, pesticide containers etc)

Sell used containers or any parts of them to unauthorised companies or uncertified small enterprises.

Wash containers in open water courses or non-filtered drains.

Standard 10.1.

Used Tyres

Reduce waste production by using tyres for their full design life (usually until the tread is less than 2 mm for road vehicles).

Store used tyres securely, in a recognised storage area.

Sell used tyres to recognised companies that will recycle them for non-road uses.

Where there is doubt about the future use of tyres, slash them before sale to make them useless for road vehicles.

Used Tyres

Place used tyres in landfill sites.

Give away used tyres to anyone.

Sell used tyres to unauthorised companies, uncertified small enterprises or individuals who might re-use them on road vehicles.

Burn used tyres, except in authorised incineration facilities.

Not applicable.

Used Batteries (12-volt lead-acid and gel-filled batteries)

Where possible, buy batteries under a buy-back policy from the suppliers to avoid the storage and handling of waste batteries.

Reduce waste production by using batteries for their full design life.

Store used batteries securely, in strong, leak-proof containers in a bunded and covered storage area.

Sell used batteries for recycling by regular companies with a current Environmental Certificate issued by the EPA.


Place used batteries in landfill sites.

Give away used batteries to anyone.

Sell used batteries to unauthorised companies, uncertified small enterprises or individuals who might re-use their components without proper disposal of acid or other unwanted parts.

Standard 10.1.







Used Personal Protective Equipment

Reduce waste production by using PPE for its full design life.

Store used PPE securely, in strong, leak-proof containers in a bunded and covered storage area.

Sort used PPE into chemically contaminated (e.g. overalls and gloves stained with creosote from handling rail ties) and non-contaminated items.

Incinerate chemically contaminated PPE in an industrial incinerator or, if this is not possible, in a purpose-dug pit. Place the residue into an approved landfill site.

Place non-contaminated PPE into an approved landfill site.


Place used PPE in landfill sites unless you are sure that it is uncontaminated with chemicals.

Give away or sell used PPE to anyone.

Place chemically contaminated PPE into a landfill site.

Standard 10.1.

Used Workshop Clothing and Rags (i.e. oily waste)

Reduce waste production by using clothing and rags for as long as it is safe to do so.

Store used oily waste securely, in strong, leak-proof containers in a bunded and covered storage area.

Incinerate oily waste in an industrial incinerator or, if this is not possible, in a purpose-dug pit. Place the residue into an approved landfill site.


Place oily waste in landfill sites.

Give away or sell oily clothing to anyone.

Standard 10.1.

Household Waste

Promote the minimisation of household waste through environmental education and awareness programmes.

Segregate wastes at source into bio-degradable and non bio-degradable.

Provide secure, dog-proof waste bins for each household.

Arrange collection of general household waste at least twice per week.

Place household waste into an approved landfill site.

Household Waste

Allow any township household to attempt to dispose of their own household waste.

Allow waste volumes to grow without taking additional awareness programmes.

Not applicable.

Food Waste

Minimise food waste by ensuring that canteens do not over-cook.

Place awareness boards to discourage the wastages of food.

Encourage canteen staff to use uneaten food for themselves and their families if it is still safe.

Arrange for farmers of domesticated animals to collect food waste for feeding to their stock.

Compost any unused vegetable material.

Send unused animal products to an approved landfill site.

Food Waste

Allow food waste to be left in areas where it can be eaten by dogs, crows etc.

Place large volumes of food waste into a landfill site.

Not applicable.







Plastics

Promote the minimisation of plastic waste through environmental education and awareness programmes.

Restrict the use of throw-away plastic bags inside the concession.

Monitor companies and facilities in Liberia, so that a recycling programme can be set up as soon as facilities are available.

For the time being, crush plastic waste and send it to approved landfill sites.

Plastics

Burn plastics at low temperatures (<800

ᵒC), thereby releasing harmful

chemicals.

Allow plastic materials to be disposed of where they pose a threat to animals and birds, either wild or domesticated.

Not applicable.

Hospital Waste

Store hospital waste in appropriate sealed containers.

Segregate the wastes into different categories at source, in the appropriate colour bins.

Ensure staff involved in the handling of waste are equipped with appropriate PPE.

Incinerate hospital waste at a temperature of 800 to 1600

ᵒC in an

approved specialist incinerator.

Place incinerator ash and residues into an approved landfill site.

Hospital Waste

Place any potentially hazardous hospital waste into a landfill site.

Allow anyone to operate an incinerator other than a trained operator.

Standard 10.3.

Used Domestic Machines (refrigerators, air conditioners, washing machines etc) and IT Equipment (computers, printers, UPS etc)



Sell used machines for recycling by regular companies with a current Environmental Certificate issued by the EPA.




Not applicable.




2. INTRODUCTION

2.1 The Hazardous Materials and Waste Management Plan This Hazardous Materials and Waste Management Plan takes the form of one of a series of Environmental Management Plan (EMP) that have been prepared as part of the overall Nimba Western Range Iron Ore Deposits concession (the project) to rehabilitate, operate and expand former iron ore mining, processing, and export infrastructure. The primary purpose of this plan is to assist in conducting all project activities in accordance with applicable environmental requirements. ArcelorMittal Liberia (“the Company”) and its Contractors are mining direct shipping iron ore (DSO) and lower grade ores that are beneficiated to make Concentrate at sites on Mounts Tokadeh, Gangra and Yuelliton, in the Western Range Deposits of Nimba County, Liberia. The ore is being transported from the mine to a crushing and screening plant. From there it is moved by rail to the Port of Buchanan. At the port it is stockpiled and then loaded on to ships. The schedule is to export 4 million tonnes per year from 2012 to 2014 inclusive under Phase 1, and 15 million tonnes per year from 2015 to 2026 under Phase 2. This Hazardous Materials and Waste Management Plan is focussed on a specific part of the project and as such is one of a series of complementary Environmental Management Plan plans devised at the start of the mining operation. This document specifically covers:

the handling and use of materials that are in any way potentially hazardous to the environment or any part of it; and

the management of waste from all parts of the Company’s operations. All of the Company’s EMPs are “live documents”. This plan will be updated as needed to reflect changing operations, geographical areas of working and any lessons learned. The objectives of the EMP are to:

Define the specific control measures relating to the operations that it covers, to ensure compliance with the conditions of the Environmental Certificate granted by the EPA, and other applicable environmental and social documents;

List site-specific and activity-specific environmental and social requirements, in terms of the procedures to be followed, timing and standards of completion, and reporting and monitoring;

Define responsibilities between the Company and its Contractors with respect to environmental compliance and social or community issues; and,

Assign corresponding roles and responsibilities to the Company and the Contractors’ personnel.

2.2 Outline of Waste Generation and its Management The paragraphs below summarise the Company’s approach to the management of the waste that it generates. Vegetation cut during land clearance will be either laid on the surface to act as erosion control mulch or left adjacent to the cleared areas to be used as mulch as soon as work has finished on the site. Topsoil cleared during earthworks is not a waste product but will be treated as a resource to be stockpiled for later re-use. The standard for this includes measures to keep it in good bio-chemical and physical condition. Spoil (overburden) is to be placed in carefully sites waste dumps. These are typically on flat or gently sloping land away from water courses. The spoil tips are to be carefully engineered so that there is no risk of erosion or mass failure, and so that they can be permanently stabilised at the end of the operational period.




Contaminated soils resulting from any accidental spills at machine refuelling sites will be removed and transferred to a designated waste site. This shall be in a location identified in the waste management plan. The contaminated soil will be treated with a bioremediation agent. Industrial waste will comprise items such as used lubricants, filters, tyres, batteries and personal protective equipment. These will be stockpiled until there are quantities adequate to make disposal cost effective, and will then be dealt with according to their nature and the availability of EPA-approved dealers or disposal sites. Scrap iron and steel will be stockpiled until there is sufficient quantity for export. It will then be sent to an ArcelorMittal steel mill specialising in steel recycling. Non-ferrous metallic scrap (e.g. aluminium, copper and lead) will be stockpiled until adequate quantities are available for sale to an approved dealer. Household waste will mainly be placed in an approved landfill site. Food waste is to be fed to domestic animals wherever possible. Recycling will be increased as facilities become available in Liberia. Hospital waste will be incinerated on site in purpose-built incinerators with high burn temperatures. Asbestos waste may be encountered in former LAMCO or other older buildings and wrecked machinery. This will be dealt with in consultation with the Environmental Protection Agency, in line with its draft guidelines on the subject. Spill management. The Company has a hazardous material spill clean-up plan (following the Company’s Environmental Standards Manual) and will provide all necessary equipment at the project work site in support of the plan. It will also ensure that field personnel are appropriately trained in its implementation under emergency conditions.

2.3 References The Company and Contractors must comply with or exceed the requirements of all relevant legislative statutes and regulations, specifically including but not limited to the following. (i) The Environmental Certificate granted by the EPA against the stated activities and mitigation

measures described in the Environmental and Social Impact Assessment for the Western Range DSO Iron Ore Project, 2011-15, dated September 2010.

(ii) The Environmental Protection and Management Law (2002). (iii) The Mining Licence granted by the Ministry of Lands, Mining and Energy in August 2005. (iv) The Minerals and Mining Act (2000).




3. ARCELORMITTAL ENVIRONMENTAL POLICY The Company, as an operating division of ArcelorMittal, must abide by the corporate Environmental Policy. All suppliers are also required to abide by the policy, and take responsibility for any adverse environmental impacts resulting from their actions. For ArcelorMittal Liberia, most of the practical aspects of site working in the Company’s global Environmental Policy are contained in the Policy on Caring for Nature. This is given on the next page. Key elements of the global Environmental Policy and other policies are as follows.

The implementation of environmental management systems including ISO 14001 certification for all production facilities;

Compliance with all relevant national environmental and community engagement laws and regulations, and other company commitments, to keep the company’s environmental impact to a minimum; and

Working towards a goal of zero accidents and injuries in the promotion of a healthy and safe working environment.

To ensure that these policies and plans are delivered at the local level, the company has put into place a management and monitoring framework which places the onus on national operating companies to deliver the company commitment. As part of its response, ArcelorMittal Liberia Limited has developed a Corporate Responsibility Plan, within which it pledges high standards of environmental and social safeguards.




4. ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS This Environmental Management Plan is to be implemented in accordance with the provisions of the latest version of the Company’s Environmental Standards Manual. Normally the Manual is issued with the EMP, but it is the Employee’s and Contractor’s responsibility to check with the Company’s environmental staff that they are still working to the latest standards. The list of standards current at the time of finalisation of this document is given below (taken from the version dated 1 March 2013).

1. WORK SITE STANDARDS

1.1 Standard for Safety Gear Provision to Site Staff and Workers

1.2 Standard for Pit Latrines

1.3 Standard for Disposal of Waste from Chemical Toilets

1.4 Standard for Burning or Burial of Rubbish at Temporary Camps

1.5 Standard for Conduct by Employees in Railway Operation

1.6 Standard for the Management of Waste

2. FOREST PROTECTION STANDARDS

2.1 Standard for Bush Clearance, Tree Felling and Use of Chainsaws

2.2 Standard for Bushmeat Hunting, Dealing, Transporting and Use

2.3 Standard for Clearance of Caves, Adits and Tunnels

3. COMMUNITY RELATIONS STANDARDS

3.1 Standard for Community Engagement

3.2 Standard for Contractor Identification of Land Access and Community Interaction

3.3 Standard for Acquiring Land and Other Assets

3.4 Standard for Employment of Temporary Construction Labour

3.5 Standard for Staff Behaviour

3.6 Standard for Handling Grievances

3.7 Standard for Unexpected Cultural Sites and Archaeological Finds

4. AIR QUALITY STANDARDS

4.1 Standard for Air Pollution Prevention and Control at Mine and Quarry Sites

4.2 Standard for Emissions Limits from Heavy Diesel Engines

5. WATER AND SOIL QUALITY STANDARDS

5.1 Standard for the Control of Water Pollution

5.2 Standard for Water Quality

5.3 Standard for Effluent Quality

5.4 Standard for Soil Contamination Screening

6. EROSION CONTROL AND REVEGETATION STANDARDS

6.1 Standard for Mine Drainage and Sediment Capture

6.2 Standard for Settlement and Attenuation Ponds

6.3 Standard for Mine Spoil Tips

6.4 Standard for Topsoil Stripping, Stockpiling and Restoration

6.5 Standard for Constructing and Maintaining Earth Tracks

6.6 Standard for Simple Drainage Systems

6.7 Standard for Slope Protection by Stone Pitching

6.8 Standard for Spillways Lined with Soil-filled Bags

6.9 Standard for Stone-filled Gabions

6.10 Standard for Check Dams

6.11 Standard for Selection of Revegetation Techniques for Erosion Prevention

6.12 Standard for Revegetation using Planted Grasses

6.13 Standard for Revegetation using Hardwood Cuttings (Brush Layers)

6.14 Standard for Revegetation using Shrub and Tree Seedlings

6.15 Standard for Drainage Systems on Major Roads

6.16 Standard for Slope Cutting Grades




7. NOISE AND RADIATION STANDARDS

7.1 Standard for the Limitation of Noise Emissions

7.2 Standard for Radio and Microwave Emissions

8. VISUAL APPEARANCE STANDARDS

8.1 Standard for the Colours of Structures

8.2 Standard for Night-time Lighting of Work Sites

9. POLLUTION PREVENTION STANDARDS

9.1 Standard for the General Prevention of Pollution at Work Sites

9.2 Standard for Avoiding and Treating Spills

9.3 Standard for Action to Clean Up Spills

9.4 Standard for Pollution Prevention from Ships

9.5 Standard for Ships’ Ballast Water Management

10. HAZARDOUS MATERIALS STANDARDS

10.1 Standard for the Storage, Dispensing and Disposal of Hazardous Materials

10.2 Standard for the Cleaning-up of Pollution by Hazardous Materials

10.3 Standard for Operation of the ArcelorMittal Liberia Medical Waste Incinerators

10.4 Standard for the Use of Wood Preservative

10.5 Standard for the Use of Herbicide

10.6 Standard for the Removal of Paint from Steel Bridges

10.7 Standard for the Disposal of Waste Containing Asbestos

10.8 Standard for the Use of Explosives in Quarries and Mines

11. FUEL HANDLING STANDARDS

11.1 Standard for Bunding Temporary Fuel Tanks

11.2 Standard for Dispensing Fuel at Temporary Site Camps

11.3 Standard for Pollution Prevention from Above Ground Oil Storage Tanks

11.4 Standard for Oil Separators in Surface Water Drainage Systems

11.5 Standard for Preventing Pollution from Refuelling Facilities

11.6 Standard for Pollution Prevention in Vehicle and Plant Workshops

11.7 Standard for the Remediation of Oil-contaminated Soil

12. ENVIRONMENTAL EDUCATION STANDARDS

12.1 Standard for Briefing Site Crews

12.2 Standard for Briefing Professional and Technical Staff

13. ENVIRONMENTAL POLICIES

13.1 ArcelorMittal Corporate Environmental Policy

13.2 Government of Liberia’s Environmental Principles

13.3 ArcelorMittal Liberia’s Policy on Caring for Nature




5. ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES This section defines Project-specific environmental and social requirements relevant to this particular Plan.

5.1 Storage of Materials The following good practice measures shall be adopted, as provided for in site specific Environmental Management Plans.

All hazardous liquids – fuel for machines, vehicles, railway locomotives, lubricants, solvents, other chemicals, cement, etc – shall be stored and handled in a manner so as to minimise the risk of a release to the environment, and in accordance with the Company’s Environmental Standards Manual.

The Company has a hazardous material spill clean-up plan (following the Company’s Environmental Standards Manual) and will provide all necessary equipment at the project work site in support of the plan. It will also ensure that field personnel are appropriately trained in its implementation under emergency conditions.

5.2 Waste Management The following good practice measures shall be adopted, in conformance with the Company’s Environmental Standards Manual.

Vegetation cut during land clearance will be either laid on the surface to act as an erosion control mulch or left adjacent to the cleared areas to be used as mulch as soon as work has finished on the site.

Topsoil cleared during earthworks is to be stockpiled for later re-use. The standard for this includes measures to keep it in good bio-chemical and physical condition.

Spoil (overburden) is to be placed in carefully sites waste dumps. These are typically on flat or gently sloping land away from water courses. The spoil tips are to be carefully engineered so that there is no risk of erosion or mass failure, and so that they can be permanently stabilised at the end of the operational period.

Contaminated soils resulting from any accidental spills at machine refuelling sites will be removed and transferred to a designated waste site. This shall be in a location identified in the waste management plan. The contaminated soil will be treated with a bioremediation agent.

Industrial waste will comprise items such as used lubricants, filters, tyres, batteries and personal protective equipment. These will be stockpiled until there are quantities adequate to make disposal cost effective, and will then be dealt with according to their nature and the availability of EPA-approved dealers or disposal sites.

Scrap iron and steel will be stockpiled until there is sufficient quantity for export. It will then be sent to an ArcelorMittal steel mill specialising in steel recycling.

Non-ferrous scrap (e.g. aluminium, copper and lead) will be stockpiled until adequate quantities are available for sale to an approved dealer.

Household waste will mainly be placed in an approved landfill site. Food waste is to be fed to domestic animals wherever possible. Recycling will be increased as facilities become available in Liberia.

Hospital waste will be incinerated on site in purpose-built incinerators with high burn temperatures.

Properly engineered toilets will be provided at long term work sites, along with appropriate permanent sewage treatment arrangements. Earth pit latrines will be provided at all work sites where it is not practical to install proper toilets. They shall be backfilled when their use is finished.

Asbestos waste may be encountered in former LAMCO or other older buildings and wrecked machinery. This will be dealt with in consultation with the Environmental Protection Agency, in line with its draft guidelines on the subject.




5.3 Health and safety of workers Supervisors and Contractors are responsible for maintaining the health of all employees and labourers during the period of employment. Contractors shall make available, free of charge, all necessary personal protective equipment as required for their site of working. Prior to mobilisation, Contractors shall provide the Company with evidence of employee accident and liability insurance to cover all workers regardless of employment status.

5.4 Worker Facilities The workforce shall be provided with the following:

1. Supplies of clean water; 2. Suitable first-aid facilities; 3. A safe and clean work environment; and 4. Personal protective equipment as necessary and as per the Company’s Environmental

Standards Manual and Health and Safety Policy .




6. EMERGENCY RESPONSE PLAN An emergency response plan is in place to cover:

Accidental spills of hazardous materials;

A major spill arising from a train derailment;

Other accidents involving personnel on the work sites; and

Major failures, such as earthquakes, landslides, tsunamis, mine failures, structural collapse, etc.

The environmental emergency response plan is linked to the Company’s overall Emergency Response Plan. This is a restricted document since it covers a number of security and other sensitive issues, but the environmental aspects are described here in some detail. The overall Emergency Response Plan (ERP) provides the Company with the framework and guidance to respond effectively to emergencies or serious incidents, reducing their impact on the project, its people, property and operations. The ERP and its attendant Incident Response Procedures should enable the Company to respond effectively to a wide range of adverse events, thus reducing any subsequent impact on the company, its staff and the surrounding environment. As well as environmental emergencies, the ERP covers explosion, fire, bomb threat, threats to personnel, suspect mail, missing persons, kidnap and ransom, extortion, medical emergency, fatality, disease outbreak, civil unrest, natural disaster, armed attack and robbery. The priority in resolving any emergency incident and for business continuity management will always be:

The safety and security of people;

The protection of assets;

Adherence to the law; and

The timely re-activation of business functions. Emergency Response Team In the event of an emergency of any kind, a Company Emergency Response Team is detailed to assemble at an Emergency Control Centre in the Buchanan concession. This takes overall responsibility for all emergency incidents affecting all or significant elements of the Company’s operations. Once the nature of the emergency is understood, the ERT determines the appropriate composition of an Incident Response Team (IRT) to deal with the problem. The IRT would be based at the appropriate concession location (Yekepa or Buchanan) and would typically be led by the Company’s Security Manager, who is required to be trained in a wide range of emergency response procedures. Any environmental disaster would automatically have the HSE Manager co-opted into the IRT as a key adviser. The IRT would then operate under the overall direction of the ERT, which would typically be led by either the Chief Operations Officer (COO), or the appropriate Manager (Mine, Rail or Port) to ensure that adequate resources and authority for actions are immediately available. The ERT would provide management guidance for the IRT in addressing the emergency. Some of the procedural guidelines for use by the ERT and IRT are discussed below, but these are only a small part of the comprehensive guidelines and checklists in the restricted Emergency Response Plan. Emergency Reporting Checklist This is one of the emergency management tools used by the Incident Response Team. It has a number of different categories to cover different possible incidents. The following is the section that covers environmental issues.




MINOR Report – Same Day

SIGNIFICANT Report – 1 HOUR

MAJOR Report – Immediately

ENVIRONMENTAL ENVIRONMENTAL ENVIRONMENTAL

• Hydrocarbon spill < 25 litres • Recovered & cleaned immediately • No off site impact potential

• Hydrocarbon Spill 25-200 litres • Recovered & cleaned immediately • Fire in railway corridor • Put out immediately • Off site impact possible

• Any spillage into a waterway or any other contamination of ground close to waterways or villages • Any spillage of material (liquid or solid) outside company industrial sites • Any spillage of liquid > 200 litres irrespective of location

Other emergency incident management tools are as follows.

Incident Notification Form

Major Incident Post Incident Report Form

Whereabouts Board

Telephone and Communications Log (for serious incidents)

Persons On Board List Immediate Response Guidelines for an Environmental Disaster These set out the recommended guidelines for the IRT’s response to the more common emergency incidents. They are designed to assist Company staff to consider appropriate responses and make the best possible decisions during emergency situations. It is important to note that detailed prescriptive planning for every scenario is both impractical and unwise, as there is a danger that flexibility could be lost. However, these guidelines serve as a useful prompt at each stage of incident resolution. The tables below show the guidelines for environmental disaster response. The Incident Response Team Leader (IRTL) would typically be the Company Security Manager. PHASE 1: Notification & Escalation – Immediate Actions

# Action Responsible

1 Immediately advise the IRTL, using the Incident Notification Form as a guide for what information needs to be passed.

Observer

2 Establish the nature of the disaster (e.g. solid or liquid material spill) and the nature of the environment affected (e.g. water course, urban area, empty bush land).

IRTL

3 Establish the need for immediate evacuation of casualties or people in danger.

IRTL

4 Notify the site manager immediately if there is any likelihood that the disaster may have an impact on AML’s facilities.

IRTL

5 Notify the Environmental Protection Agency immediately if there is any likelihood that the disaster may have an impact on any land or water resource outside of AML’s facilities.

HSE Manager

6 Record all events, actions and decisions in an Incident Management Log.

IRTL




PHASE 2: Event Containment – Follow Up Actions


7 Determine the events surrounding the environmental disaster:

What type of disaster is it?

Has the immediate risk passed, or does it still exist?

In the case of an impending disaster, what is the expected scale and what areas are likely to be affected?

Is the problem basically soil- or water- or urban-based, or a combination of these?

If water-based, what is the scale of downstream catchment affected?

IRTL

8 Determine the exact nature of the environmental fall-out, both immediate, impending and long term.

HSE Manager

9 Determine whether the Company or its Contractors have the capacity to deal with the incident, or whether specialist support is required.

HSE Manager supported by IRTL

10 Determine what people or assets are threatened in proximity to the event.

IRTL

11 Notify the Environmental Protection Agency if this has not already been done in Phase 1.

HSE Manager

12 Outline the action that needs to be taken to contain and rectify the problem:

What resources are needed?

Who should be assigned to what tasks?

What is the sequence of actions?

What authority is needed to implement the response?

IRTL supported by HSE Manager

13 Verify what action has been taken to date through the observers IRTL

14 Verify the actions and resources needed for containment or rectification, obtain necessary authority and commence implementation.

IRTL

15 Contact all principle staff clusters and advise them of the situation. HR

16 Notify the Environmental Protection Agency of the actions being taken and resources mobilised.

HSE Manager

17 Issue an information bulletin via public radio. IRTL

18 Monitor the containment or rectification process and modify as necessary.

HSE Manager




PHASE 3: Event Recovery – Not Time Critical


19 Ensure that the containment process is completed fully and effectively.

HSE Manager

20 Ensure that the rectification process is completed fully and effectively.

HSE Manager

21 Verify the impact on people, assets and the environment. Identify any further actions that may be necessary.

IRTL supported by HSE Manager

22 Issue information bulletin updates as appropriate via public radio. IRTL

23 Monitor local media and be prepared to issue media releases to quash rumours, should they develop.

IRTL

24 Request Environmental Protection Agency to review action taken and ascertain further needs.

HSE Manager

25 Conduct a post-incident review of incident management procedures.

IRTL

26 Conduct a post-incident impact assessment. IRTL

27 Ensure lessons learnt are ploughed back into Company and Contractor procedures to avoid a repeat.

COO

28 If the incident had security-related implications, consider the need for an increased physical security presence and preventative security measures.

IRTL

29 Consider the requirement to conduct an additional environmental audit.

HSE Manager

Incident Response Team: HSE Manager’s responsibilities The Health, Safety and Environment Manager is a member of the Incident Response Team. His or her responsibilities can be summarised as:

Identify HSE impact of the situation;

Ensure sufficient resources available for consequential management;

Initiate Flash Report; and

Co-ordinate incident investigation. The detailed roles and responsibilities for the HSE Manager are as given below.

# IRT Responsibilities – HSE Manager

1 Join the Incident Response Team as soon as informed by the Emergency Response Team or the IRTL. Until further notice the incidence response takes precedence over all other work or leave. It may require immediate travel to and residence at a different site.

2 Develop as full an understanding as possible of the nature of the incident and the possible immediate and long term impacts on all aspects of the environment.

3 Advise the IRTL on immediate actions that are required to counteract the initial impacts on the environment.

4 Determine what other resources are required to provide detailed specialist technical support, and request the IRTL to arrange these.




# IRT Responsibilities – HSE Manager

5 Decide whether to notify the Environmental Protection Agency in either Phase 1 or Phase 2 of the incident response (see Incident Response Guidelines). Once the EPA has been notified, establish a liaison point within the Agency and arrange to keep them updated as events develop.

6 Work closely with the field teams mobilised by the Company to deal with the incident.

7 Advise the IRTL on the longer term actions and resources that are required to contain and rectify the incident. Emphasis must be given first to minimising and then to rectifying impacts on the environment.

8 Monitor the incident response and ascertain whether it is proving effective. Advise the IRTL of any modifications or additions that are necessary to the response.

9 Once the response is substantially complete, check all of the work done and ascertain that it has been fully undertaken to a satisfactory and effective degree.

10 Work with the Environmental Protection Agency to review the actions taken, the lessons learnt and any further work that is required.

11 Produce a formal environmental audit report covering the entire incident and response, on behalf of the Company.




7. ENVIRONMENTAL COMPLIANCE CONTROLS The following primary management controls shall be implemented with the aim of ensuring that all activities are conducted in accordance with applicable environmental requirements and best practices:

1. Environmental and Social Awareness Briefing; 2. Environmental Compliance Reviews and Co-ordination Meetings; 3. Community Consultative Meetings; and 4. Environmental Compliance Inspections and Documentation.

7.1 Environmental Awareness Briefing for Site Crews All site crews of the Company or its Contractors shall be briefed on key environmental issues before starting work in the field. This shall be done at the start of each package of work and at the beginning of each working week. It is expected to take only about ten minutes. The environmental awareness messages shall also be displayed in notices on the site, which shall be painted or laminated, and maintained for the duration of site works. As a minimum, the following issues shall be raised:

1. Environmental matters: awareness of the special natural environment of the project sites and Liberia’s environment in general; essential behaviour;

2. Safety issues: the use and check of personal protective equipment, site cleanliness and “housekeeping”;

3. Pollution issues: accident procedures, hazardous materials being used, and handling details. The recommended environmental briefing messages are given in the Environmental Standards Manual (standard 12.1).

7.2 Environmental Compliance Review Meetings Where works are undertaken in-house by the company, meetings to co-ordinate and review environmental compliance shall be held once per month between the Company’s Manager (Mine, Rail or Port, as appropriate) and the site teams. The teams will normally be represented by the Superintendent, Foreman and Supervisor, as appropriate (see section 8). These individuals will hold the responsibility for environmental compliance by their respective teams. Where works are contracted, meetings to co-ordinate and review environmental compliance shall be held once per month between the Company’s Manager (Mine, Rail or Port, as appropriate) and the Contractors’ Field Managers. The purpose of the meetings shall be to discuss current and future activities as they relate to ensuring environmental compliance. The agenda for each meeting shall be set by the Environmental Officer. It is envisaged that the Environmental Compliance Review Meetings will be held at the same time as other regular site co-ordination meetings between Company management and site teams, or between the Company and its Contractors.

7.3 Local Consultative Forums There are many distinct household groups who are primary stakeholders in the project area (i.e. people directly affected by some part of the project, either as beneficiaries or adversely affected, such as by loss of property), within the settlements in and around the mine sites and the railway. Each group needs to be involved in the project process. These include owner-farmers, absentee land owners, sharecroppers, landless households, agricultural wage labourers, market sellers, hunters, and their dependent households. Within these groups are important sub-groupings, comprising women working at home, children, the disabled and the elderly. Factors such as ethnicity, and relative wealth and resources, may further divide communities. These factors can result in the




exclusion of low status groups from community information systems and participation in decision-making. The Company’s Community Liaison Officers (CLO) have set up Local Consultative Forums (LCF) to keep stakeholders informed, consulted and involved in the project. There is to be one LCF per affected part of a Clan, meeting up to four times a year, but with additional meetings during resettlement activities. As the project progresses, these LCFs will deal in turn with issues relating to design, then resettlement and compensation, and then implementation. Written instructions for the formation, conduct and recording of the LCF meetings are given in the Company’s Resettlement Manual. It is the responsibility of each site Manager and CLO to implement these, beginning with a discussion in a workshop at the start of resettlement activities. The CLO will use the LCF mechanism to meet each Town Leader and representatives of the affected persons (stakeholders who are significantly adversely affected by the project) at intervals throughout the project, and if appropriate a Contractor’s representative will also attend. These meetings are called to consult communities over the works, to disclose the Resettlement Plan formally, discuss compensation difficulties and anomalies, and resolve grievances and outstanding issues. Records are to be kept of these meetings and the decisions agreed.

7.4 Environmental Compliance Inspections and Documentation Company staff and, if appropriate, Contractors shall participate in both regular and non-regular inspections of work sites to verify that the environmental requirements specified in this EMP are being implemented. The Environmental Officer and the Community Liaison Officer will make an inspection together a few days before each Environmental Compliance Review Meeting, sometimes accompanying the site Manager or Superintendent for this purpose. The findings of these inspections shall be documented. Other non-regular inspections may be made, possibly without warning, by other members of the environmental and community teams, and by the Government of Liberia’s Environmental Protection Agency. Inspections shall use the monitoring tables for the Employees’ and Contractors’ Operational Practices, as given in Section 10 of this plan. Key aspects of the environmental compliance inspections are as follows.

The scope of each inspection shall be based on current and completed activities, and shall be adapted as site conditions change.

Immediate changes shall be implemented where the potential for an adverse environmental impact or non-compliance is observed.

“Stop work” orders shall be issued if activities are not in accordance with the applicable environmental requirements and are likely to result in a significant adverse impact to the environment. Activities shall not be resumed until corrective actions have been agreed upon and implemented. “Stop work” orders may be made by the Company’s site Manager or Superintendent on the recommendation of the Environmental Officer, the Community Liaison Officer or any other member of the environmental or community teams.

On completion of activities on each part of every site, a final inspection will be made to ensure compliance with all environmental safeguards, and this fact will then be documented. No inspection shall be deemed “final” until all compliance has been fulfilled.




8. RESPONSIBILITIES

8.1 Organisational structure The Company is responsible for conducting all work in accordance with applicable laws and regulations, and ensuring that its workers and Contractors comply. As far as it relates to environmental and social safeguards, the general organisation of ArcelorMittal Liberia is shown on the next page, with the detailed approximate breakdown of responsibilities given on the following two pages. Specific responsibilities of Company personnel are summarised in section 8.2, and those of contractors are given in section 8.3. Detailed terms of reference for individuals are provided in the sector-specific and topic-specific Environmental Management Plans, but have been omitted from this Overall EMP for the sake of simplicity. Although ArcelorMittal employs a standard top-down pyramidal organisation structure, it is important to appreciate two main features.

Within the Company, there is a formal bottom-up reporting and responsibility system.

Nevertheless, there is widespread cross-over within and between departments, giving a fully three-dimensional structure.

All Company activities in Liberia are the responsibility of the Chief Executive Officer of ArcelorMittal Liberia. The CEO (AML) reports to the Vice President (Mining Operations) in ArcelorMittal Mining, the Company’s global mining division based in London. The ArcelorMittal Mining team provide a number of strategic and technical support functions, including environmental management. These are further strengthened by additional support functions provided from ArcelorMittal Corporate, the global Company overview teams based in London, Luxembourg and elsewhere. Within ArcelorMittal Liberia, activities are handled by a series of specialist teams. These vary between what might be termed “professional” teams (e.g. finance, legal and environmental), and “technical” teams (e.g. port operations, transport and workshops). Both types have a similar structure, as shown below. This arrangement allows delegation and responsibility to run up and down the hierarchy, but for activities to be shared between departments.

Manager (1 per department)Shared services

(ArcelorMittal Liberia or

ArcelorMittal Mining)

Formal reporting line Regular line of liaison

Professional departments Technical departments

Chief Executive Officer

Chief Operations Officer

Superintendent (1 per unit)

Foreman (varies)

Supervisors (varies)

Operators (teams)

Chief Executive Officer

Chief Operations Officer

Superintendent (1 per unit)

Officer (varies)

Assistants (varies)

Manager (1 per department)

Underlying the organisation of the Company are the universal principles of environmental management:

Everyone must take responsibility to ensure that their actions do not damage the environment beyond permitted levels; and

Everyone must undertake the agreed mitigation and rehabilitation measures for the impacts that they cause on the environment.

Hence the Environmental Department is principally responsible for advisory and monitoring services, and the implementing technical departments are responsible for the resolution of their own pollution and waste management, under Environmental Department guidelines and support.




Summary of the organisational structure of ArcelorMittal Liberia

Min

e

Rail

Port

Roads a

nd Q

uarrie

s

Pro

cure

ment

Tow

nship

s

Tra

nsport a

nd W

ork

shops

Enviro

nm

ent

Com

munitie

s

Health

and S

afe

ty

Hospita

ls

Schools

Security

Fin

ance

Legal

Inte

rnal A

udito

r

Com

munic

atio

ns

Govern

ment R

ela

tions

Hum

an R

esourc

es

Info

rmatio

n T

echnolo

gy

Genera

l Adm

inis

tratio

n

Pro

ject M

anagers

EP

CM

Pro

cure

ment

Operations Shared Services: Corporate Responsibility Shared Services: Administrative and Support Projects

ArcelorMittal Liberia: Chief Executive Officer's Responsibilities

Summary of the organisational linkages for environmental safeguards in ArcelorMittal Liberia

Hydro-

meteorological

Monitoring

Environmental

Officer

Environmental

Assistant

Environmental Manager Environmental Adviser

Mainly working on Operations Mainly working on Projects

Chief Operations Officer Project Director

Chief Executive Officer, ArcelorMittal LiberiaVice President HSESS,

ArcelorMittal Mining

Formal reporting line Regular line of liaison

Buchanan Site

Environmental

Superintendent

Environmental

Officer

Yekepa Site

Environmental

Superintendent

Biodiversity Officer

Environmental

Team of

Engineering

Procurement and

Contract

Management

Consultant

(EPCM)

Biodiversity

Conservation

("Offset")

Programme

Programme

Co-ordinator

Assistant

Co-ordinator

HSSE Site Manager

Environmental

Co-ordinators (2)

Environmental

Officers (2)




8.2 The Company The Company is the owner of the project and takes the ultimate responsibility for all actions in its implementation. The Chief Executive Officer of ArcelorMittal Liberia Limited holds the ultimate responsibility for all Company activities in Liberia. The CEO is supported by a number of head office staff. In particular, the Vice President for Health, Safety, Environment, Security and Sustainability in ArcelorMittal Mining provides guidance on those issues. At the site and contract level, the Company is represented by the Project Director, who has responsibility for delivering the Project Phase 2 construction in a safe and environmentally sound manner. The Project Director is supported by a number of Project Managers, to whom responsibility is delegated at the site level. The Company is represented by the Chief Operations Officer with respect to responsibility for operational actions and effects. A number of shared services support both Projects and Operations, and help to integrate the Company’s safeguards across the sites. The Environmental Manager is one of these, with responsibility for all matters relating to the protection of the environment. The Environmental Superintendent and the Environmental Officers support the Environmental Manager in all matters. The Environmental Manager also has an Environmental Adviser who takes particular responsibility for ensuring compliance by the Project Operations. The Health and Safety Manager reports to the CEO, and has the responsibility of ensuring that all health and safety provisions are in place and properly administered. The Communities Manager and the Community Liaison Officers support the CEO and other Company staff in all matters of relations with, and the welfare and support of, local communities. The Procurement Manager is responsible for the sourcing, purchasing, transport and storage of hazardous materials. This individual has the following responsibilities with respect to environmental management:

Ensuring that sufficient resources are provided to meet the requirements of this EMP;

Ensuring the education of the work force on all environmental requirements and the role of staff in environmental protection;

Ensuring that relevant elements of the EMP are incorporated into the contracts held with individual Contractors;

Ensuring that all hazardous materials are properly stored, transported and handled;

Monitoring the standard of environmental compliance as reported by the Environmental Superintendent;

Direction of Company staff and Contractors regarding environmental compliance requirements and other matters of environmental importance;

Liaison with Company management on overall issues relating to health, safety, environment and communities, environmental performance data, incident reports, etc;

Approval of Company and Contractors’ plans for emergencies;

Participation in Environmental Compliance Reviews;

Enforcement of all relevant mitigation measures;

Enforcing the implementation of the control measures in this plan, and any other corrective measures.

The Mine, Rail, Port and Townships Managers are the Company’s principal representatives regarding their respective component of the Project. They are responsible for ensuring that the Project, as implemented by the Company through its staff, workers and Contractors, complies with all environmental requirements. Each Manager has the following responsibilities with respect to environmental management:




Ensuring that sufficient resources are provided to meet the requirements of this EMP;

Ensuring the education of the work force on all environmental requirements and the role of staff in environmental protection;

Ensuring that relevant elements of the EMP are incorporated into the contracts held with individual Contractors;

Ensuring that all hazardous materials are properly handled and used;

Monitoring the standard of environmental compliance as reported by the Environmental Superintendent;

Direction of Company staff and Contractors regarding environmental compliance requirements and other matters of environmental importance;

Communication of site environmental issues with regulators and other interested parties;

Liaison with Company management on overall issues relating to health, safety, environment and communities, environmental performance data, incident reports, etc;

Co-ordination, via nominated agents, of compensation and resettlement for land clearance in all areas, etc;

Approval of Company and Contractors’ plans for emergencies;


Review of conditions following completion of works on site;

Enforcement of all mitigation measures;

Enforcing the implementation of the control measures in this plan, and any other corrective measures;

Monitoring and reporting all issues of environmental compliance and community relations. The Mechanical Superintendent is responsible for the management of workshops and machinery. In this capacity he or she will ensure that there is no pollution from workshops, that plant is managed in an environmentally sound way and that all used mechanical parts and waste materials are disposed of as appropriate. The Electrical Superintendent is responsible for the management of all electrical installations. In this capacity she or he will ensure that electrical plant is managed in an environmentally sound way and that all used parts and waste materials are disposed of as appropriate. The Environmental Superintendent is a member of the Company’s staff. He or she supports the Managers in all environmental matters. The Environmental Superintendent has the following duties which may be delegated to other staff, particularly the Environmental Officers, in the Environmental Department:

Communication with Company staff and Contractors regarding environmental compliance requirements and other matters of environmental importance;

Conducting and reporting on periodic Environmental Audits;

Keeping Company management informed on overall issues relating to the Project’s environmental standards and compliance;

With the Community Liaison staff, supporting Company staff and Contractors in planning for action to be taken in the event of accidents and other emergencies threatening human welfare;

Supporting Company staff and Contractors in planning for action to be taken in the event of spills or leakages of hazardous materials, and other environmental emergencies;

With the Community Liaison staff, supporting Company staff and Contractors in the provision of environmental awareness and community interaction training;

Leading of Environmental Compliance Reviews;

With the Community Liaison staff, review of conditions following completion of works on site;

Liaison with Company staff and Contractors for the implementation of all environmental mitigation measures;

Identification of additional environmental mitigation or corrective measures that are deemed to be necessary in the course of operations;

Implementation of the control measures in this plan and any other corrective measures;

Preparation for the Managers of reports on all aspects of environmental compliance.




The Community Liaison Officer is a member of the Company’s staff. He or she supports the Managers and other Company staff in all matters of relations with, and the welfare and support of, local communities. The Community Liaison Officer has the following duties:

Community liaison, particularly in relation to engagement with communities, enabling participation, implementation of grievance mechanisms, implementation of employment policy, and participation in determining and ensuring resettlement requirements;

Communication with Company staff and Contractors regarding liaison with communities and other matters of importance to local inhabitants;

Keeping Company management informed on relevant community issues, disputes, incident reports, etc;

Supporting of compensation and resettlement for land clearance in all areas;

With the Environmental staff, supporting Company staff and Contractors in planning for action to be taken in the event of accidents and other emergencies threatening human welfare;

With the Environmental staff, supporting Company staff and Contractors in the provision of environmental awareness and community interaction training;


Active involvement in Community Consultative Meetings;

With the Environmental staff, review of conditions following completion of works on site;

Liaison with Company staff and Contractors for the implementation of all community support measures;

Identification of additional community mitigation or corrective measures that are deemed to be necessary in the course of operations;

Implementation of the community support measures in this plan and any other corrective measures;

Preparation for the Managers of reports on all aspects of community relations.

8.3 The Engineering and Procurement Management Consultant Many of the responsibilities listed in section 8.2 for the Company and its staff may be designated to the Engineering and Procurement Management Consultant.

8.4 Contractors Where they are engaged, Contractors are responsible for complying with environmental requirements for all field activities covered by this EMP. Contractors to the Company are also responsible for the actions of any Sub-contractors they may engage. Each Contractor’s Field Manager is responsible for:

Direct overview of field personnel at the Project work sites;

Ensuring that all operations comply with the environmental standards that may be set from time to time by the Environmental Protection Agency under the provisions of the Environmental Protection and Management Law (2002);

Ensuring that the control measures provided for in the various documents of the Project’s health, safety, environmental and community safeguards systems are both understood and implemented by site personnel;

Training staff in appropriate environmental awareness issues, and ensuring that the key messages are passed on to the labourers in the work crews;

Setting up plans for action to be taken in the event of accidents and other emergencies threatening human welfare;

Setting up plans for action to be taken in the event of spills or leakages of hazardous materials, and other environmental emergencies;




Taking reasonable measures to employ local people in the work crews, particularly those whose livelihoods have been adversely affected by the Project;

Taking reasonable measures to avoid or mitigate impacts to the environment which may arise from the project’s activities (mitigation measures shall include awareness raising and training of all staff with respect to the possible environmental impacts during site works, and emergency incidents, such as accidents and pollution from fuel spills);

Monitoring of EMP implementation, by maintaining appropriate records and communications on site environmental issues and the status of compliance, and making these available to representatives of the Company as required;


Participation in Community Consultative Meetings;

Identification of significant matters pertaining to environmental compliance;

Liaise with the Company on the need for corrective action in the event of unexpected environmental or community problems emerging during the course of operations.

The Environmental staff and Community Liaison Officer are to support the Contractor in achieving many of these responsibilities, where it falls within their duties to do so.

8.5 Employment Policy Although the activities will generate a limited amount of local labour, an equitable and transparent employment strategy must be implemented that takes account of the individuals on whom the Project will have an impact. This is particularly important as the strategy applied to this initial phase will set precedents and expectations for all future activities. Responsibility for this activity will be with the Company’s Community Liaison Officers. As outlined in other sections of this EMP, a targeted employment policy should be extended to all potentially affected communities. A labour allotment strategy should be developed and implemented on the following basis.

Skilled staff who worked for LAMCO and are still living in the vicinity of the mines or railway should be employed if they are not too old and their skills are still relevant.

All unskilled labourers employed on Project works should be recruited from settlements within 5 km of the sites.

The stages for the ArcelorMittal Community Liaison Officer to implement this are as follows.

1. Collect information from the Contractors’ staff as to the numbers and locations of labourer requirements.

2. Contact the Head and Elders of the main communities to identify areas where communities are interested.

3. Organise public meetings in each community to explain the opportunities for employment and the selection procedures, and for anyone who feels excluded to voice their grievances.

4. The County Labour Commissioner should be consulted as to the hiring terms and work conditions.

Detailed guidelines for these procedures are given in the Company’s Human Resources Plan. For short term works, guidelines are given in standard 3.4 of the Company’s Environmental Standards Manual.




9. IDENTIFIED POTENTIALLY HAZARDOUS MATERIALS AND WASTE STREAMS This section of the Hazardous Materials and Waste Management Plan lists the potentially hazardous materials and waste streams that were identified in the Environmental and Social Impact Assessment. These form the basis of the practical management and monitoring requirements given in sections 1 and 10. A number of identified measures have been added by ArcelorMittal Liberia, in addition to those identified by the ESIA consultants.

9.1 Potentially Hazardous Materials Used in all Parts of the Company’s Operations Issue Potential impacts (positive & negative) Prevention, control and mitigation measures


Uncontained spills and leakages leading to soil, and ground and surface water contamination. Affected soils are contaminated and effectively sterilised, leading to loss of vegetation and subsequent erosion. Water courses are affected by the resulting toxic substances, affecting community water supplies, aquatic biodiversity and wildlife. Waste products not collected and stored appropriately leading to widespread contamination. Fugitive emissions. Theft, resulting in spillage and pollution elsewhere. Potential for explosions.

AML to develop and implement Hazardous Materials Management Plan. Train people on environmental requirements and environmental protection. Designated area, with appropriate bunding (150% volume of total capacity). The facility should be located down gradient of any public water supply boreholes wherever possible. Where this is not possible, a separate site specific hydrogeological and environmental impact assessment will be required. Retention systems, including walls, bunds and lined drains to contain any spillages. The facility should be on hard standing, distant from watercourses, with drainage system including oil/water separators. Spill kits and granules available. On-going controls to be put in place to minimise opportunities for fuel pilferage. Appropriate waste disposal. Caution boards on fire / no smoking to be displayed. Emergency Response /Fire Fighting teams trained for a spillage event. Fire fighting equipment available at each facility. On site training for all personnel handling fuel and oil.

Refuelling Uncontained spills and leakages leading to soil, and ground and surface water contamination. Affected soils are contaminated and effectively sterilised, leading to loss of vegetation and subsequent erosion. Water courses are affected by the resulting toxic substances, affecting community water supplies, aquatic biodiversity and wildlife. Fugitive emissions. Potential for explosions.

AML to develop and implement Hazardous Materials Management Plan, which will include procedures for refuelling vehicles and generators. Spill kits to be carried by all refuelling vehicles. Central location for fuel tanks, vehicle refuelling to take place only on impermeable hard standings with controlled drainage (traps and interceptors). Plant refuelling on site to be carried out according to strict protocol for refuelling in unprotected areas. Reporting system for incidents enforced. Emergency Response / Fire Fighting teams to train for such an event. Fire fighting equipment available at each facility. On site Training for all personnel handling chemicals.




Issue Potential impacts (positive & negative) Prevention, control and mitigation measures


Hazardous materials on public highways with the potential for spills and leakages to the wider environment with little chance of containment. Ground and water contamination from toxic materials, leading to significant effects on community water supplies and wildlife mortality. Danger to road users. Potential for explosion and fire effecting wider environment.

AML to develop and implement Hazardous Materials Management Plan. Assessment of available transportation options, e.g. rail transport is safer than road. Use of convoys with accompanying support. Delivery to a prepared location. Supply of spill kits and granules in all vehicles and at offloading locations. Competent drivers and supervision. Ensuring the provision and use of appropriate PPE in the sites. Emergency training to all personnel. Use of international labelling for identifying hazardous substance. Compliance with international standards and guidelines (e.g. UK COSHH, OHSAS, etc). Emergency Response / Fire Fighting teams to train for such an event. On site training for all personnel handling chemicals.

Chemicals (including herbicides) storage and use

Loss of containment from spills or inadequate disposal.Chemicals spill or leak to the environment with toxic effects to soil and water, resulting in polluted water supplies, or habitat degradation and wildlife mortality and/or reduced reproductive success. Some chemicals may be mutagenic. Some chemicals are, or contain, substances which bio-accumulate.Improper use by poorly trained workers leads to damaging health effects.Some chemicals pose a potential for explosion in confined spaces.

AML to develop and implement Hazardous Materials Management Plan. All people associated with the use of chemicals need to be trained on chemical handling and the interpretation and use of MSDS. Minimise chemicals stored, reuse where possible.Select chemicals with least environmental impact where possible.Use only chemicals that are certified for use world-wide and approved by the Liberian EPA. Chemicals should be stored down gradient of any public water supply boreholes.All containers must be clearly labelled. Labelling must include non-verbal warning signs.Secondary containment for all chemicals.MSDS held for every chemical on site. Emergency Response / Fire Fighting teams to train for such an event. Fire fighting equipment available at each facility. On site training for all personnel handling chemicals.

9.2 Component-specific Potentially Hazardous Materials and Waste Streams Mine Issue Potential impacts (positive & negative) Prevention, control and mitigation measures


Security risk in transport and storage of explosives, potential for theft. Potential for personnel accidents due to unplanned explosions. Potential for wildlife disturbance and destruction. Danger to work crew. Danger to local population who may be trespassing (e.g. hunters, children). Secondary explosion from unknown unidentified ordnance.

AML to develop and implement Hazardous Materials Management Plan. Compliance with national legislation and permitting requirements. Liaison with Ministry of Lands, Mines and Energy. Storage to international and manufacture's specifications. Avoid high risk areas. Compliance with Blast Procedures, use of sirens etc. All people associated with the use of explosives need to be trained on chemical handling and the interpretation and use of MSDS. Ensuring the provision and use of appropriate PPE in the sites. Public awareness programmes. Emergency/Fire Fighting Response teams to train for such an event. Fire Fighting Equipment available at each facility. On site training for all personnel handling explosives.




Yekepa Township Issue Potential impacts (positive & negative) Prevention, control and mitigation measures

Sewerage system operation

Leakage from waste water pipes and remainder discharges into rice paddy and River Dayea leading to environmental degradation, contamination of surface and groundwater and health hazards for the community.

AML to map pipe work system - network, depths etc. Design and build a suitable system of treatment that is fit for purpose. During construction implement precautionary measures to protect workers from health hazards. Dispose of contaminated waste appropriately in accordance with Hazardous Waste Management Plan.

Waste water treatment

DSO phase will operate under a refurbished system (only for EA, EB, EU, C and D blocks). Risk of effluent pollution.

Discontinue the use of current system. Correct design, operation and maintenance of waste water treatment plant. Follow manufacturer’s specifications. Implement a discharge monitoring programme which includes contingency arrangements in the event of operational failure.


Increased population and activity increases the types and quantity of waste products. Inadequate waste collection, segregation, storage and disposal results in environmental degradation, contamination, and a hazard to animal and human health. An increase in disposable income will also create more waste, both quantity and type. Disposal of hazardous waste from house refurbishment

AML to devise a waste management strategy based on a principle of waste minimisation and recycling. Predict types and quantities for project. Waste should be segregated into hazardous and non-hazardous waste; all waste disposed of in appropriate manner. Full records of waste transfers, types and quantity to be maintained. Recycling and Waste Reduction Campaign. PPE for staff when handling hazardous waste

Waste disposal

Incorrect disposal of waste leads to contamination of the wider environment and a health risk to the community. Incomplete burial and lack of secure compound leads to scavenging. Injury to persons or environment resulting in company liability. Visual and odour impacts if sited inappropriately Air pollution impact, if burnt

Discontinue use of present landfill site. Design and construct a landfill site that is lined and to international standards. This should be in an area that is not prone to slippage, cannot leach to surface water and groundwater, suitable distance from settlement. It should be located down gradient of any public water supply boreholes. Landfill site must be in a secure compound. Landfill operations to conform to international standards. Hazardous waste is dealt according to international best practice. Medical waste is to be incinerated in an EPA-approved facility.




Buchanan Township Issue Potential impacts (positive & negative) Prevention, control and mitigation measures

Sewerage system refurbishment

Sewage treatment plant now defunct but pipework still in place and all houses connected. Discharge is uncontrolled and is to a lagoon; suspected leakage from pipes. This has the potential for environmental degradation, contamination of surface and groundwater and health hazards for the community. Uncontrolled sewage discharge contravenes national and company standards.

Establish plan of system - network, depths etc Design and build a suitable treatment system that is fit for purpose. During construction implement precautionary measures to protect workers from health hazards. Dispose of contaminated waste appropriately in accordance with Estate Management Plan Substandard pipework, which is possibly asbestos concrete, to be abandoned in situ and a new pipe installed in parallel.

Sewerage system operation

DSO phase will operate under a refurbished system . Malfunction of this would result in discharge that is non-compliant.

AML to develop map of system - network, depths etc. Design and build a suitable treatment system that is fit for purpose. During construction implement precautionary measures to protect workers from health hazards. Dispose of contaminated waste appropriately in accordance with Hazardous Waste Management Plan.


Increased population and activity increases the types and quantity of waste products. Inadequate waste collection, segregation, storage and disposal results in environmental degradation, contamination, and a hazard to animal and human health. An increase in disposable income will also create more waste, both quantity and type. Disposal of hazardous waste from house refurbishment

AML to devise a waste management strategy based on a principle of waste minimisation and recycling. Predict types and quantities for project. Waste should be segregated into hazardous and non-hazardous waste; all waste disposed of in appropriate manner. Full records of waste transfers, types and quantity to be maintained. Recycling and Waste Reduction Campaign. PPE for staff when handling hazardous waste

Waste disposal

Incorrect disposal of waste leads to contamination of the wider environment and a health risk to the community. Incomplete burial and lack of secure compound leads to scavenging. Injury to persons or environment resulting in company liability. Visual and odour impacts if sited inappropriately Air pollution impact, if burnt

Design and construct a landfill site that is lined and to international standards. This should be in an area that is not prone to slippage, cannot leach to surface water and groundwater, suitable distance from settlement. It should be located down gradient of any public water supply boreholes. Landfill site must be in a secure compound. Landfill operations to conform to international standards. Hazardous waste is dealt according to international best practice. Medical waste is to be incinerated in an EPA-approved facility.




10. PLAN MANAGEMENT AND ITS MONITORING The tables in this section list the obligations of the Company, its staff, workers and Contractors, for hazardous materials and waste management and compliance, and how these will be monitored. They are the basis of the Operational Practices in section 1 of this EMP.

10.1 General Principles of Environmental Management

Employee and Contractor compliance obligations Applicable standard

(see Standards Manual)

Monitoring

What you MUST do What you must NOT do Check timing Responsibility for

checking

Assessment of condition and performance

Action required

General principles

Avoid damage to any part of the environment (soil, plants, animals, human resources and settlements) as far as possible.

If damage cannot be avoided, then mitigate or compensate for the damage.

Follow the ArcelorMittal Environmental Policy.

Respect the environment: we have only one planet!

General principles

Undertake any work beyond the agreed boundaries of the work sites.

Undertake any work before agreeing mitigation or compensation arrangements.

Hide any damage or pollution. In the event of an accident, it is better to consult the Environmental Team and agree a mitigation plan than to risk prosecution under the law.

Section 5 of this EMP.


Before starting work.

Monthly during operations.

After completion of operations.

Environmental Officer for bio-physical matters.

Community Liaison Officer for socio-economic matters.

To be completed at each check.

Only to be completed at check if compliance is not satisfactory. State who is responsible for action.


Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main environmental messages.


Allow staff and workers to neglect environmental issues. This may lead to offences under the Environment Protection and Management Law.

Standard 12.1.

Monthly during site operations.

Environmental Officer.








Monitoring


checking


Action required


Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main messages regarding respect for the local communities.

Ensure that all professional and technical staff respect the local communities and behave well.


Ignore blatant disrespect for communities by professional and technical staff.



Community Liaison Officer.




Provide all workers with safety equipment appropriate to the work that they are doing

Keep first aid kits on all work sites.

Ensure that there are two people on each work site who know what to do if there is an accident and how to use the first aid kit.

Remember that safety gear is cheaper than hospital and funeral bills!


Allow workers on to a site without the appropriate safety gear.

Allow first aid kits to become empty or out-of-date.

Standard 1.1.

H&S Manual and Rules.

Weekly during site operations.

Health and Safety Manager.






10.2 Hazardous Materials Management



Monitoring

What you MUST do What you must NOT do Check timing Responsibility for checking


Action required


Provide proper earth pit latrines at all work sites where more than 5 people will work for more than 1 day at a time.

Fill the latrines in once site work is complete.


Allow latrines to become full or overflow.

Allow site workers to defecate at random in the forest.

Standards 1.2, 1.3.






Ensure that all potentially hazardous materials (i.e. fuel, oil, other chemicals, sewage) are stored or disposed of in appropriate ways.

Provide spill, leak and leachate collection systems in storage areas to avoid land contamination.

Devise on-site emergency spillage plans and train staff in their implementation.

Remove all debris and litter from site.

Display name and appropriate caution boards.


Allow any pollution to occur to the soil or water courses.

Allow haphazard dumping of any solid or hazardous wastes.

Allow storage on open earth ground.

Standards 9.1, 10.1, 10.2 and others as appropriate.

Before starting work.


After completion of site operations.









Monitoring



Action required



Only use the designated storage areas , with bunding of 150% volume of total capacity

Only use facilities located down gradient of public water supply boreholes and distant from watercourses.

Ensure that there are retention systems, including walls, bunds and lined drains to contain any spillages.

Ensure that there is hard standing, with a drainage system that includes oil/water separators.

Provide caution boards on fire risks and for no smoking.

Ensure spill kits and granules are available.

Have controls in place to minimise opportunities for fuel pilferage.

Dispose of waste appropriately.

Maintain Emergency Response / Fire Fighting teams trained for a spillage event.

Maintain fire fighting equipment at each facility.

Display fire caution and emergency contact boards.

Display operational and control procedures.

Provide training for all personnel handling fuel and oil.


Allow uncontained spills and leakages to occur, leading to soil, and ground and surface water contamination.



Allow waste products that are not collected and stored appropriately to contaminate the surroundings.


Allow theft to occur, resulting in spillage and pollution elsewhere.



Before start of work.










Monitoring



Action required


Follow the hazardous materials management guidelines fully, which include procedures for refuelling vehicles and generators.

Spill kits are to be carried by all refuelling vehicles.

Keep all fuel tanks in a central location.

Refuel vehicles only on impermeable hard standings with controlled drainage (traps and interceptors).

Plant refuelling on site is to be carried out according to strict protocols for refuelling in unprotected areas.

Enforce the reporting system for spillage incidents.





Allow spills and leakages to go uncontained leading to soil, and ground and surface water contamination.
















Monitoring



Action required


Establish reliable communications between the two vessels before starting the berthing manoeuvres.

Ensure that the appropriate checklists in section 9 of this EMP have been completed by the Master of each vessel before commencing each stage of the operation.

Follow the ship-to-ship mooring procedure rigorously, with special care in fendering and in ensuring that there is no metal-to-metal contact.


Clean all working areas on both ships immediately after each refuelling operation.

Make ship operators contractually bound to follow national regulations and international conventions on dumping and the prevention of pollution at sea.

Ensure that the tug based in Buchanan is on short notice standby with sufficient amounts of fire-fighting foam and oil dispersant.


Permit any spill or discharge of oil into the sea.

Attempt refuelling if sea or weather conditions are not good enough.

Hesitate in stopping the operation if anything goes wrong or if weather conditions deteriorate.

Undertake refuelling if any artisanal fishing boats are in the selected area.



Ships’

Emergency Response Plans.

Before start of operation.

Whenever a ship is being refuelled at sea.

Ships’ Masters.

Note: this operation will only take place in international waters, outside the jurisdiction of the Liberian EPA.








Monitoring



Action required


Ensure that all appropriate pre-operation checks have been made and effective communications are in place between the ship’s crew and the shore party.

Ensure that the chartered tugs are fully enabled with tanks of fire-fighting foam and oil dispersant, and are standing by close to the vessel being refuelled.

Ensure that the shore-based fire fighting crew and the spill clean-up crew are prepared and standing by on the quay before the operation starts.


Make ship operators contractually bound to follow national regulations and international conventions on the prevention of pollution at sea.


Permit any spill or discharge of oil into the harbour basin.

Hesitate in containing and cleaning up any accidental spills that may occur.

Hesitate in stopping the operation if anything goes wrong.


Standards 9.1 to 9.4, 10.1, 10.2.

Early warning system (see section 6.1 of this EMP).

Emergency Response Plan (see section 6.2 of this EMP).

Whenever a ship is refuelling at the Port of Buchanan.

Port Manager.









Monitoring



Action required



Use the safest available transportation option, preferably rail.

Use Transport Emergency (TREM) cards during transportation.

Use manifests during transportation.

On roads, use convoys with accompanying support.

Deliver only to prepared locations.

Maintain supplies of spill kits and granules in all vehicles and at all offloading locations.

Ensure competent drivers and close supervision.

Provide emergency training to all personnel.

Use international labelling for identifying hazardous substances.

Comply with international standards and guidelines (e.g. OHSAS, UK COSHH).




Transport hazardous materials on public highways without having supporting vehicles in convoy to take immediate containment action in the event of an accident.

Allow any ground and water contamination from toxic materials.

Allow any potential for explosions and fires to occur.

Standards 9.1, 10.1, 10.2, 10.3.











Monitoring



Action required



Train operators on safety for handling chemicals and interpreting MSDS.

Select chemicals with the least environmental impact where possible.

Use only chemicals that are certified for use world-wide and approved by the Liberian EPA.

Minimise the volumes of chemicals stored, and reuse them where possible.

Chemicals should be stored down gradient of any public water supply boreholes.

Ensure that all containers are clearly labelled. Labelling must include non-verbal warning signs.

Provide secondary containment for all chemicals.

Provide chemical spill kits.

Ensure that the MSDS is held for every chemical on site.

Display the appropriate MSDS at storage locations.

Carry Transport Emergency cards during transportation.

Store chemicals separately, according to their natures and properties.


Allow any loss of containment from spills or inadequate disposal.

Allow any chemicals to spill or leak to the environment with toxic effects to soil and water.

Use any chemicals that are not approved by both the Company’s HSE Manager and the EPA.

Use any chemicals known to be mutagenic or which contain substances which bio-accumulate.

Allow any use of chemicals except by fully trained workers.

Allow the use of chemicals in confined spaces if they pose any potential for explosions.

Handle chemicals without PPE.

Standards 9.1, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.











Monitoring



Action required

Chemicals storage and use (continued)

Ensure the availability of appropriate Personal Protective Equipment (PPE).

Ensure the availability of Chemical Spill Kits during storage, handling and transportation.




Chemicals storage and use (continued)

As above.

Standards 9.1, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.







Minimise the number of spare rail ties kept in stock.

Keep all ties in a single location.

Wherever possible, keep rail ties under a permanent cover, in a well-ventilated place.

In temporary storage locations, ensure complete coverage of the ties and full bunding and filtration of drainage water that might contain creosote leachate.


Have numerous small stocks of rail ties.

Maintain any temporary stocks within 200 metres of a water course.

Allow even small numbers of rail ties to be uncovered during rain.

Standards 9.1, 10.1, 10.2, 10.4.











Monitoring



Action required


Follow exactly the procedures given in the standard for the use of explosives.

Comply with national legislation and permitting requirements.

Liaise as required with Ministry of Lands, Mines and Energy.

Store explosives and detonators to international and manufacture's specifications.

Ensure that explosives are stored away from habitation.

Provide appropriate emergency and caution boards in the storage and handling areas.

Avoid blasting in high risk areas, if any are identified.

Train operators on all aspects of safety in the handling and use of explosives.

Train Emergency Response / Fire Fighting teams in readiness for an emergency, fire or other accident.

Keep fire fighting equipment available at site.

Provide training for all personnel handling explosives.


Permit any risks of security or potential for theft to arise in the transport and storage of explosives.

Allow standards to slip in such a way as to increase the potential for accidents due to unplanned explosions.

Relax site boundary patrols to allow trespassing by the local population (e.g. hunters, children).

Standard 10.8.









10.3 Waste Management



Monitoring


checking


Action required

General


Operate a waste management strategy based on a principle of reduction, recovery, recycle and reuse.

Collect and segregate waste into hazardous and non-hazardous at the source.

Avoid waste spills during storage and handling.

Dispose of all waste in an appropriate manner.

Maintain full records of the types and quantities of waste generation, storage, transfers and disposals.

Conduct recycling and waste reduction campaigns.

Ensure use of PPE by staff when handling all forms of waste.


Allow an inadequate waste collection, segregation, storage and disposal system to result in environmental degradation, contamination, and hazards to human and animal health.

Allow an increase in disposable income among employees to create more waste, both quantity and type, without challenging perceptions.

Allow spillages of wastes during storage and handling.

This Plan.











Monitoring


checking


Action required

General

Waste disposal

Dispose of wastes in the most environmentally sound manner possible.

Design and construct a landfill site that is lined and to international standards. This should be in an area that is not prone to slippage, cannot leach to surface water and groundwater, and is a suitable distance from settlement. It should be located down gradient of any water supply boreholes.

Ensure that the landfill site is in a secure compound.

Ensure landfill operations conform to international standards.

Deal with hazardous waste according to international best practice and EPA guidelines.

Dispose of wastes to EPA-authorised facilities.

Incinerate medical waste in an EPA-approved facility.

Waste disposal

Continue to use the present landfill site.

Allow the incomplete burial of waste and the lack of a secure compound to lead to scavenging.

Allow injury to persons or the environment from waste, resulting in company liability.

Allow unauthorised persons into storage areas

Allow an inappropriate site to give negative visual and odour impacts.

Burn waste, creating air pollution.

This Plan.











Monitoring


checking


Action required

General


Dispose of oily water in suitable shore reception facilities if the ship is not sailing into international waters (where the oil-water separator can be used.

Ensure that garbage is disposed of properly at shore reception facilities.

Operate only approved shipboard incinerators, and only when the ship is at sea.

Treat sewage with a USCG approved Hamworthy sewage treatment plant which also has a steriliser unit.

Ensure that sewage is disposed of properly at shore reception facilities.

Maintain proper record books for the ship-board management of oil, cargo and garbage.


Allow the spillage of any kind of oil without taking immediate clean-up action.

Discharge any untreated sewage into the sea.

Operate ship-board incinerators within the breakwaters of the Port of Buchanan.

Dispose of cargo wash-water within Liberian territorial waters.

Standard 9.4.

Whenever a ship is within the harbour basin of the Port of Buchanan.

For resident ships, weekly during operation.







Employee and Contractor compliance obligations Applicable

standard (see Standards

Manual)

Monitoring


checking


Action required

Assets

Topsoil

Minimise waste by disturbing the soil only where it is necessary to do so.

Remove topsoil carefully, by scraping off in thin layers.

Save topsoil in shallow stockpiles.

Re-vegetate stockpiles to prevent erosion and maintain soil quality.

Return the topsoil to rehabilitated areas once work has been completed.

Topsoil

Send topsoil to spoil tips.

Allow traffic to run on topsoil, causing it to become compacted.

Allow the erosion or contamination of topsoil.

Standards 6.4, 6.11 to 6.14.







Re-use metallic objects and machinery as far as it is practicable and safe to do so.


Send to a scrap plant within ArcelorMittal or auction against company rules.








Stores Officer.

Finance Officer.



Non-ferrous Metallic Scrap (e.g. aluminium, copper and lead)

Re-use metallic objects and components as far as it is practicable and safe to do so.


Ensure that copper and lead scrap are kept in dry locations, such as shipping containers.

Auction against company rules.

Non-ferrous Metallic Scrap (e.g. aluminium, copper and lead)







Stores Officer.

Finance Officer.








Monitoring


checking


Action required

Assets




Decommission machines thoroughly. Remove all fuel and lubricants, and degrease moving parts.

Sell usable scrap as a Company asset (see above).







Stores Officer.

Finance Officer.



Used Oil Drums

Store used oil drums securely, in a bunded and covered storage area.

Recycle oil drums for waste oil or other appropriate uses.

Used Oil Drums

Sell used drums or any parts of them to unauthorised companies or uncertified small enterprises.

Wash oil drums in open water courses or non-filtered drains.

Standard 10.1.








Employee and Contractor compliance obligations Applicable

standard (see Standards

Manual)

Monitoring


checking


Action required

Non-assets

Vegetation

Minimise waste by only cutting vegetation that is in the way. This means plants that are in the direct area required for access tracks, mining areas or other purposes.

Cut vegetation small and stack beside the working area to decompose slowly.

Forbid pit sawing in areas influenced by the Company as far as possible, and use the security force to discourage this practice.

Vegetation

Cut more vegetation than is necessary for site access and working.

Use fire to remove vegetation.

Burn cut vegetation.

Cut any plantations without following the procedures given in the Resettlement Manual.

Standard 2.1.






Spoil (overburden)

Minimise waste by removing spoil only where it is essential to do so.

Place spoil only in designated spoil tip sites.

Prepare spoil tip sites in advance, particularly for drainage blankets and slope toe retaining walls.

Place spoil in shallow layers, compacting and shaping them as they develop.

Provide erosion protection as necessary.

Monitor the water regime and stability of spoil tips and take action as required.

Spoil (overburden)

Place spoil anywhere that has not been approved, even temporarily.

Allow a steep and potentially unstable spoil tip to develop.

Continue using spoil tips when the designated area has been used up.

Allow erosion to occur.

Impede any watercourse or drainage line without making provision for through flow.

Standard 6.3.











Monitoring


checking


Action required

Non-assets

Contaminated soils

Avoid contamination of soil by adhering to the hazardous materials storage and handling standards (see tables above and relevant standards).

Remove contaminated soil to a level and secure area, surrounded by an earth bund.

Treat the contaminated soil fully using an approved bioremediation agent.

Restore the area affected, either using appropriate topsoil from a stockpile, or by replacing the remediated soil as soon as it has been decontaminated.

Contaminated soils

Leave soil untreated if there has been any spill of hydrocarbons or other chemicals.

Try to speed up or avoid part of the bioremediation process.

Dump contaminated soils anywhere.

Standard 10.2.

Standard for soil bioremediation in preparation. Approach depends on nature of contamination.



Immediately after any accident or spill.




Used Lubricants

Reduce waste production by using lubricants for their full design life.

Store used lubricants securely, in strong, leak-proof drums in a bunded and covered storage area.

Provide spill kits in storage and handling areas.

Try to use internally, where low fuel quality is acceptable, such as in incinerators.

Sell used lubricants to large rubber factories for use in the boilers.

Used Lubricants

Pour away any form of used lubricant, into either the soil or into water.

Sell used lubricants to chain saw operators.

Standard 10.1.










Monitoring


checking


Action required

Non-assets

Used Grease

Reduce waste production by using grease for its full design life.

Store grease securely, in strong, leak-proof drums in a bunded and covered storage area.

Incinerate used grease at a high temperature in a proper industrial incinerator.

Used Grease

Place in landfill sites.

Standard 10.1.






Reduce waste production by using filters for their full design life.

Store used filters securely, in strong, leak-proof containers in a bunded and covered storage area.

Sell used filters for recycling by regular companies with a current Environmental Certificate issued by the EPA.

Alternatively, incinerate used filters in a purpose-dug pit. Place the residue into an approved landfill site.


Place any used filters in landfill sites.

Sell used filters or any parts of them to unauthorised companies or uncertified small enterprises.

Standard 10.1.










Monitoring


checking


Action required

Non-assets

Used Containers (paint tins, pesticide containers, etc)

Store used containers securely, in a bunded and covered storage area.

Send used paint tins and pesticide containers to an approved landfill site.

Used Containers (paint tins, pesticide containers etc)

Sell used containers or any parts of them to unauthorised companies or uncertified small enterprises.

Wash containers in open water courses or non-filtered drains.

Standard 10.1.





Used Tyres

Reduce waste production by using tyres for their full design life (usually until the tread is less than 2 mm for road vehicles).

Store used tyres securely, in a recognised storage area.

Sell used tyres to recognised companies that will recycle them for non-road uses.

Where there is doubt about the future use of tyres, slash them before sale to make them useless for road vehicles.

Used Tyres

Place used tyres in landfill sites.

Give away used tyres to anyone.

Sell used tyres to unauthorised companies, uncertified small enterprises or individuals who might re-use them on road vehicles.

Burn used tyres, except in authorised incineration facilities.

Not applicable.










Monitoring


checking


Action required

Non-assets


Where possible, buy batteries under a buy-back policy from the suppliers to avoid the storage and handling of waste batteries.

Reduce waste production by using batteries for their full design life.

Store used batteries securely, in strong, leak-proof containers in a bunded and covered storage area.

Sell used batteries for recycling by regular companies with a current Environmental Certificate issued by the EPA.


Place used batteries in landfill sites.

Give away used batteries to anyone.

Sell used batteries to unauthorised companies, uncertified small enterprises or individuals who might re-use their components without proper disposal of acid or other unwanted parts.

Standard 10.1.










Monitoring


checking


Action required

Non-assets


Reduce waste production by using PPE for its full design life.

Store used PPE securely, in strong, leak-proof containers in a bunded and covered storage area.

Sort used PPE into chemically contaminated (e.g. overalls and gloves stained with creosote from handling rail ties) and non-contaminated items.

Incinerate chemically contaminated PPE in an industrial incinerator or, if this is not possible, in a purpose-dug pit. Place the residue into an approved landfill site.

Place non-contaminated PPE into an approved landfill site.


Place used PPE in landfill sites unless you are sure that it is uncontaminated with chemicals.

Give away or sell used PPE to anyone.

Place chemically contaminated PPE into a landfill site.

Standard 10.1.



Health and Safety Officer.




Reduce waste production by using clothing and rags for as long as it is safe to do so.

Store used oily waste securely, in strong, leak-proof containers in a bunded and covered storage area.

Incinerate oily waste in an industrial incinerator or, if this is not possible, in a purpose-dug pit. Place the residue into an approved landfill site.


Place oily waste in landfill sites.

Give away or sell oily clothing to anyone.

Standard 10.1.











Monitoring


checking


Action required

Non-assets

Household Waste

Promote the minimisation of household waste through environmental education and awareness programmes.

Segregate wastes at source into bio-degradable and non bio-degradable.

Provide secure, dog-proof waste bins for each household.

Arrange collection of general household waste at least twice per week.

Place household waste into an approved landfill site.

Household Waste

Allow any township household to attempt to dispose of their own household waste.

Allow waste volumes to grow without taking additional awareness programmes.

Not applicable.

Monthly.





Food Waste

Minimise food waste by ensuring that canteens do not over-cook.

Place awareness boards to discourage the wastages of food.

Encourage canteen staff to use uneaten food for themselves and their families if it is still safe.

Arrange for farmers of domesticated animals to collect food waste for feeding to their stock.

Compost any unused vegetable material.

Send unused animal products to an approved landfill site.

Food Waste

Allow food waste to be left in areas where it can be eaten by dogs, crows etc.

Place large volumes of food waste into a landfill site.

Not applicable.

Monthly.










Monitoring


checking


Action required

Non-assets

Plastics

Promote the minimisation of plastic waste through environmental education and awareness programmes.

Restrict the use of throw-away plastic bags inside the concession.

Monitor companies and facilities in Liberia, so that a recycling programme can be set up as soon as facilities are available.

For the time being, crush plastic waste and send it to approved landfill sites.

Plastics

Burn plastics at low temperatures (<800

ᵒC),

thereby releasing harmful chemicals.

Allow plastic materials to be disposed of where they pose a threat to animals and birds, either wild or domesticated.

Not applicable.






Hospital Waste

Store hospital waste in appropriate sealed containers.

Segregate the wastes into different categories at source, in the appropriate colour bins.

Ensure staff involved in the handling of waste are equipped with appropriate PPE.

Incinerate hospital waste at a temperature of 800 to 1600

ᵒC in

an approved specialist incinerator.

Place incinerator ash and residues into an approved landfill site.

Hospital Waste

Place any potentially hazardous hospital waste into a landfill site.

Allow anyone to operate an incinerator other than a trained operator.

Standard 10.3.

Monthly.

Hospital Administrator.










Monitoring


checking


Action required

Non-assets




Sell used machines for recycling by regular companies with a current Environmental Certificate issued by the EPA.




Not applicable.





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