EMP HazardousMaterialsAndWasteManagement18may11

Western Range DSO Iron Ore Project, Liberia Environmental and Social Studies, 2008-2015
Hazardous Materials and Waste Management Plan
VERSION DATE: 18 MAY 2011
ArcelorMittal Liberia Ltd. P.O. Box 1275 th Tubman Blvd at 15 Street Sinkor, Monrovia Liberia T +231 77 018 056 F +231 77 008 264 www.arcelormittal.com
Western Range DSO Iron Ore Project, Liberia Environmental and Social Studies, 2008-2015 Hazardous Materials and Waste Management Plan
Contents List of Abbreviations ................................................................................................................................ 3 1. OPERATIONAL PRACTICES (DOS AND DONTS) ...................................................................... 4 1.1 1.2 1.3 2. General Environmental Management ..................................................................................... 4 Management of Hazardous Materials ..................................................................................... 5 Waste Management ................................................................................................................ 9
INTRODUCTION ........................................................................................................................... 15 2.1 2.2 2.3 The Hazardous Materials and Waste Management Plan ..................................................... 15 Outline of Waste Generation and its Management ............................................................... 15 References ............................................................................................................................ 16
3. 4. 5.
ARCELORMITTAL ENVIRONMENTAL POLICY.......................................................................... 17 ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS .................................................. 18 ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES ........................................ 20 5.1 5.2 5.3 5.4 Storage of Materials .............................................................................................................. 20 Waste Management .............................................................................................................. 20 Health and safety of workers................................................................................................. 21 Worker Facilities .................................................................................................................... 21
6. 7.
EMERGENCY RESPONSE PLAN................................................................................................ 22 ENVIRONMENTAL COMPLIANCE CONTROLS ......................................................................... 27 7.1 7.2 7.3 7.4 Environmental Awareness Briefing for Site Crews ............................................................... 27 Environmental Compliance Review Meetings ....................................................................... 27 Local Consultative Forums.................................................................................................... 27 Environmental Compliance Inspections and Documentation ............................................... 28
8.
RESPONSIBILITIES ..................................................................................................................... 29 8.1 8.2 8.3 8.4 Organisational structure ........................................................................................................ 29 The Company ........................................................................................................................ 30 Contractors ............................................................................................................................ 32 Employment Policy ................................................................................................................ 32
9.
IDENTIFIED POTENTIALLY HAZARDOUS MATERIALS AND WASTE STREAMS .................. 34 9.1 9.2 Potentially Hazardous Materials Used in all Parts of the Companys Operations ................ 34 Component-specific Potentially Hazardous Materials and Waste Streams .......................... 35 PLAN MANAGEMENT AND ITS MONITORING ...................................................................... 38 General Principles of Environmental Management............................................................... 38 Hazardous Materials Management ....................................................................................... 40 Waste Management .............................................................................................................. 47
10. 10.1 10.2 10.3
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List of Abbreviations
AML CEMP CLO EIA EMP EPA EPML ESIA FDA FONSI HSE MDA MSDS ArcelorMittal Liberia Contractors Environmental Management Plan Community Liaison Officer Environmental Impact Assessment Environmental Management Plan Environmental Protection Agency Environmental Protection and Management Law Environmental and Social Impact Assessment Forestry Development Agency Finding of No Significant Impact Health, Safety and Environment Mineral Development Agreement Material Safety Data Sheet
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1.
OPERATIONAL PRACTICES (DOS AND DONTS)
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 What you MUST do What you must NOT do 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. Environmental awareness Allow staff and workers to neglect environmental issues. This may lead to offences under the Environment Protection and Management Law. Provision of safety equipment Allow workers on to a site without the appropriate safety gear. Allow first aid kits to become empty or out-of-date. Applicable standard (see Standards Manual) Section 5 of this EMP.
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! 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. 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!
Standard 12.1.
Standard 1.1. H&S Manual and Rules.
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1.2
Management of Hazardous Materials

Hazardous Materials Management Employee and Contractor compliance obligations What you MUST do What you must NOT do Sanitation at temporary work sites Allow latrines to become full or overflow. Allow site workers to defecate at random in the forest. Applicable standard (see Standards Manual) Standards 1.2, 1.3.
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. 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. 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.
Pollution from site camps and stores 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 Allow uncontained spills and leakages Standards 9.1, 10.1, to occur, leading to soil, and ground and 10.2, and 11.1 to surface water contamination. 11.6 inclusive. 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.
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Hazardous Materials Management Employee and Contractor compliance obligations What you MUST do Refuelling 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. Delivery and handling of hazardous materials Follow the hazardous materials management guidelines fully. 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). Train Emergency Response / Fire Fighting teams in readiness for a spillage, fire or other accident. Provide training for all personnel handling chemicals. What you must NOT do Refuelling Allow spills and leakages to go uncontained 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 emissions of exhausts to pass outside the site. Allow any potential for explosions to occur. Applicable standard (see Standards Manual) Standards 9.1, 10.1, 10.2, and 11.1 to 11.6 inclusive.
Delivery and handling of hazardous materials 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.
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Hazardous Materials Management Employee and Contractor compliance obligations What you MUST do What you must NOT do Applicable standard (see Standards Manual) Standards 9.1, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.
Chemicals storage and use Chemicals storage and use Follow the hazardous materials Allow any loss of containment from management guidelines fully. spills or inadequate disposal. Allow any chemicals to spill or leak to Train operators on safety for handling the environment with toxic effects to soil chemicals and interpreting MSDS. and water. Select chemicals with the least Use any chemicals that are not environmental impact where possible. approved by both the Companys HSE Use only chemicals that are certified for Manager and the EPA. use world-wide and approved by the Use any chemicals known to be Liberian EPA. mutagenic or which contain substances Minimise the volumes of chemicals which bio-accumulate. stored, and reuse them where possible. Allow any use of chemicals except by Chemicals should be stored down fully trained workers. gradient of any public water supply Allow the use of chemicals in confined boreholes. spaces if they pose any potential for Ensure that all containers are clearly explosions. labelled. Labelling must include non Handle chemicals without PPE. 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. 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. Rail Ties (Railway Sleepers) Rail Ties (Railway Sleepers) Minimise the number of spare rail ties Have numerous small stocks of rail ties. kept in stock. Maintain any temporary stocks within 200 metres of a water course. Keep all ties in a single location. Allow even small numbers of rail ties to Wherever possible, keep rail ties under be uncovered during rain. 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.
Standards 9.1, 10.1, 10.2, 10.4.
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Hazardous Materials Management Employee and Contractor compliance obligations What you MUST do 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. What you must NOT do Handling, storage and use of 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). Applicable standard (see Standards Manual) Standard 10.8.
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1.3
Waste Management
Waste Management General Employee and Contractor compliance obligations What you MUST do What you must NOT do Applicable standard (see Standards Manual)
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. 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 EPAapproved facility.
Waste generation and management Allow an inadequate waste collection, This Plan. 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.
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.
Management of Waste Classed as Potential Company Assets Employee and Contractor compliance obligations What you MUST do 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. What you must NOT do Topsoil Send topsoil to spoil tips. Allow traffic to run on topsoil, causing it to become compacted. Allow the erosion or contamination of topsoil. Applicable standard (see Standards Manual) Standards 6.4, 6.11 to 6.14.
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Management of Waste Classed as Potential Company Assets Employee and Contractor compliance obligations What you MUST do 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. 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. Stockpile scrap in a safe area. Ensure that copper and lead scrap are kept in dry locations, such as shipping containers. Auction against company rules. 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). 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. What you must NOT do Scrap Iron and Steel Place scrap into landfill sites. Allow scrap to be stolen by informal scrappers. Sell scrap without following Company guidelines. Non-ferrous Metallic Scrap (e.g. aluminium, copper and lead) Place scrap into landfill sites. Allow scrap to be stolen by informal scrappers. Sell scrap without following Company guidelines. Applicable standard (see Standards Manual) AML Procurement and Finance Rules.
AML Procurement and Finance Rules.
Used Commercial and Industrial Machines (vehicles, trucks, generators etc) 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 Sell used drums or any parts of them to unauthorised companies or uncertified small enterprises. Standard 10.1. Wash oil drums in open water courses or non-filtered drains.
Management of Unwanted Waste Employee and Contractor compliance obligations What you MUST do 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. What you must NOT do 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. Applicable standard (see Standards Manual) Standard 2.1.
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Management of Unwanted Waste Employee and Contractor compliance obligations What you MUST do 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. 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. 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 Grease Reduce waste production by using grease for its full design life. Store grease securely, in strong, leakproof drums in a bunded and covered storage area. Incinerate used grease at a high temperature in a proper industrial incinerator. What you must NOT do Applicable standard (see Standards Manual)
Spoil (overburden) Place spoil anywhere that has not been Standard 6.3. 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.
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 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 Place in landfill sites.
Standard 10.1.
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Management of Unwanted Waste Employee and Contractor compliance obligations What you MUST do 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. 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 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 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. What you must NOT do Used Filters (fuel and oil filters) Place any used filters in landfill sites. Sell used filters or any parts of them to unauthorised companies or uncertified small enterprises. Applicable standard (see Standards Manual)
Standard 10.1.
Used Containers (paint tins, pesticide containers etc) Sell used containers or any parts of them to unauthorised companies or uncertified Standard 10.1. small enterprises. Wash containers in open water courses or non-filtered drains. Used Tyres Place used tyres in landfill sites. Not applicable. 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.
Used Batteries (12-volt lead-acid and gel-filled batteries) 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.
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Management of Unwanted Waste Employee and Contractor compliance obligations What you MUST do 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. 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. Household Waste Promote the minimisation of household waste through environmental education and awareness programmes. Segregate wastes at source into biodegradable 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. 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. What you must NOT do Used Personal Protective Equipment 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. Applicable standard (see Standards Manual)
Standard 10.1.
Used Workshop Clothing and Rags (i.e. oily waste) Place oily waste in landfill sites. Standard 10.1. Give away or sell oily clothing to anyone.
Household Waste Allow any township household to attempt Not applicable. to dispose of their own household waste. Allow waste volumes to grow without taking additional awareness programmes.
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.
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Management of Unwanted Waste Employee and Contractor compliance obligations What you MUST do 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. 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 C in an approved specialist incinerator. Place incinerator ash and residues into an approved landfill site. Used Domestic Machines (refrigerators, air conditioners, washing machines etc) and IT Equipment (computers, printers, UPS 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. Sell used machines for recycling by regular companies with a current Environmental Certificate issued by the EPA. What you must NOT do Plastics Burn plastics at low temperatures (<800 C), thereby releasing harmful chemicals. Allow plastic materials to be disposed of where they pose a threat to animals and birds, either wild or domesticated. Applicable standard (see Standards Manual) Not applicable.
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) 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.
Not applicable.
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2. 2.1
INTRODUCTION 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) 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 1 million tonnes of ore in 2011 and 4 million tonnes per year from 2012 to 2015 inclusive. 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. Document Reference Manual Environmental Management Plan Environmental Management Plan Environmental Management Plan Environmental Management Plan Environmental Management Plan Topic Environmental Standards Manual Hazardous Materials and Waste Management Plan Mining of DSO from Mount Tokadeh Operation of the Buchanan-Tokadeh Railway Trans-shipment of Iron Ore at the Port of Buchanan Operation of the Company Townships of Buchanan and Yekepa
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 companys operations. All of the Companys 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 Companys 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.
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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 EPAapproved 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 Companys 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).
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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. Contractors should take particular note of point 9.
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4.
ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS
This Environmental Management Plan is to be implemented in accordance with the provisions of the latest version of the Companys Environmental Standards Manual. Normally the Manual is issued with the EMP, but it is the Employees and Contractors responsibility to check with the Companys environmental staff that they are still working to the latest standards. The list of standards current at the time of finalisation of this EMP is given below (taken from version dated 15 May 2011). 1. 1.1 1.2 1.3 1.4 1.5 2. 2.1 2.2 2.3 3. 3.1 3.2 3.3 3.4 4. 4.1 5. 5.1 5.2 5.3 6. 6.1 6.2 6.3 6.4 6.5 6.6 6.7 6.8 6.9 6.10 6.11 6.12 6.13 6.14 6.15 7. 7.1 8. 8.1 8.2 9. 9.1 9.2 9.3 WORK SITE STANDARDS Standard for Safety Gear Provision to Site Staff and Workers Standard for Pit Latrines Standard for Disposal of Waste from Chemical Toilets Standard for Burning or Burial of Rubbish at Temporary Camps Standard for Conduct by Employees in Railway Operation FOREST PROTECTION STANDARDS Standard for Vegetation Clearance Standard for Bushmeat Hunting, Dealing, Transporting and Use Standard for Clearance of Caves, Adits and Tunnels COMMUNITY RELATIONS STANDARDS Standard for Community Engagement Standard for Contractor Identification of Land Access and Community Interaction Standard for Acquiring Land and Other Assets Standard for Employment of Temporary Construction Labour AIR QUALITY STANDARDS Standard for Air Pollution Prevention and Control at Mine and Quarry Sites WATER QUALITY STANDARDS Standard for the Control of Water Pollution Standard for Water Quality Standard for Effluent Quality EROSION CONTROL AND REVEGETATION STANDARDS Standard for Mine Drainage and Sediment Capture Standard for Settlement and Attenuation Ponds Standard for Mine Spoil Tips Standard for Topsoil Stripping, Stockpiling and Restoration Standard for Constructing and Maintaining Earth Tracks Standard for Simple Drainage Systems Standard for Slope Protection by Stone Pitching Standard for Spillways Lined with Soil-filled Bags Standard for Stone-filled Gabions Standard for Check Dams Standard for Selection of Revegetation Techniques for Erosion Prevention Standard for Revegetation using Planted Grasses Standard for Revegetation using Hardwood Cuttings (Brush Layers) Standard for Revegetation using Shrub and Tree Seedlings Standard for Drainage Systems on Major Roads NOISE STANDARDS Standard for the Limitation of Noise Emissions VISUAL APPEARANCE STANDARDS Standard for the Colours of Structures Standard for Night-time Lighting of Work Sites POLLUTION PREVENTION STANDARDS Standard for the General Prevention of Pollution at Work Sites Standard for Pollution Prevention from Ships Standard for Ships Ballast Water Management
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10. 10.1 10.2 10.3 10.4 10.5 10.6 10.7 10.8 11. 11.1 11.2 11.3 11.4 11.5 11.6 11.7 12. 12.1 12.2
HAZARDOUS MATERIALS STANDARDS Standard for the Storage, Dispensing and Disposal of Hazardous Materials Standard for the Cleaning-up of Pollution by Hazardous Materials Standard for Operation of the ArcelorMittal Liberia Medical Waste Incinerators Standard for the Use of Wood Preservative Standard for the Use of Herbicide Standard for the Removal of Paint from Steel Bridges Standard for the Disposal of Waste Containing Asbestos Standard for the Use of Explosives in Quarries and Mines FUEL HANDLING STANDARDS Standard for Bunding Temporary Fuel Tanks Standard for Dispensing Fuel at Temporary Site Camps Standard for Pollution Prevention from Above Ground Oil Storage Tanks Standard for Oil Separators in Surface Water Drainage Systems Standard for Preventing Pollution from Refuelling Facilities Standard for Pollution Prevention in Vehicle and Plant Workshops Standard for the Remediation of Oil-contaminated Soil ENVIRONMENTAL EDUCATION STANDARDS Standard for Briefing Site Crews Standard for Briefing Professional and Technical Staff
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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 Companys Environmental Standards Manual. The Company has a hazardous material spill clean-up plan (following the Companys 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 Companys 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.
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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 Companys Environmental Standards Manual and Health and Safety Policy .
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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 Companys 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 Companys 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 Companys 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.
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MINOR Report Same Day ENVIRONMENTAL Hydrocarbon spill < 25 litres Recovered & cleaned immediately No off site impact potential
SIGNIFICANT Report 1 HOUR ENVIRONMENTAL Hydrocarbon Spill 25-200 litres Recovered & cleaned immediately Fire in railway corridor Put out immediately Off site impact possible
MAJOR Report Immediately ENVIRONMENTAL 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 IRTs 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 # 1 2 Action Immediately advise the IRTL, using the Incident Notification Form as a guide for what information needs to be passed. 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). Establish the need for immediate evacuation of casualties or people in danger. Notify the site manager immediately if there is any likelihood that the disaster may have an impact on AMLs facilities. 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 AMLs facilities. Record all events, actions and decisions in an Incident Management Log. Responsible Observer IRTL
3 4 5
IRTL IRTL HSE Manager
IRTL
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PHASE 2: Event Containment Follow Up Actions # 7 Action 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? 8 9 Determine the exact nature of the environmental fall-out, both immediate, impending and long term. Determine whether the Company or its Contractors have the capacity to deal with the incident, or whether specialist support is required. Determine what people or assets are threatened in proximity to the event. Notify the Environmental Protection Agency if this has not already been done in Phase 1. 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? 13 14 Verify what action has been taken to date through the observers Verify the actions and resources needed for containment or rectification, obtain necessary authority and commence implementation. Contact all principle staff clusters and advise them of the situation. Notify the Environmental Protection Agency of the actions being taken and resources mobilised. Issue an information bulletin via public radio. Monitor the containment or rectification process and modify as necessary. IRTL IRTL HSE Manager HSE Manager supported by IRTL IRTL HSE Manager IRTL supported by HSE Manager Responsible IRTL
10 11 12
15 16 17 18
HR HSE Manager IRTL HSE Manager
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PHASE 3: Event Recovery Not Time Critical # 19 20 21 22 23 24 25 26 27 28 Action Ensure that the containment process is completed fully and effectively. Ensure that the rectification process is completed fully and effectively. Verify the impact on people, assets and the environment. Identify any further actions that may be necessary. Issue information bulletin updates as appropriate via public radio. Monitor local media and be prepared to issue media releases to quash rumours, should they develop. Request Environmental Protection Agency to review action taken and ascertain further needs. Conduct a post-incident review of incident management procedures. Conduct a post-incident impact assessment. Ensure lessons learnt are ploughed back into Company and Contractor procedures to avoid a repeat. If the incident had security-related implications, consider the need for an increased physical security presence and preventative security measures. Consider the requirement to conduct an additional environmental audit. Responsible HSE Manager HSE Manager IRTL supported by HSE Manager IRTL IRTL HSE Manager IRTL IRTL COO IRTL
29
HSE Manager
Incident Response Team: HSE Managers 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. # 1 IRT Responsibilities HSE Manager 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. 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. Advise the IRTL on immediate actions that are required to counteract the initial impacts on the environment. Determine what other resources are required to provide detailed specialist technical support, and request the IRTL to arrange these.
2 3 4
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# 5
IRT Responsibilities HSE Manager 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. Work closely with the field teams mobilised by the Company to deal with the incident. 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. 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. 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. Work with the Environmental Protection Agency to review the actions taken, the lessons learnt and any further work that is required. Produce a formal environmental audit report covering the entire incident and response, on behalf of the Company.
6 7
8 9 10 11
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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 Liberias 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 Companys 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 Companys 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
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exclusion of low status groups from community information systems and participation in decisionmaking. The Companys 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 Companys 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 Contractors 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 Liberias 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 Companys 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.
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8. 8.1
RESPONSIBILITIES 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. The general organisation of ArcelorMittal Liberia is shown below, as far as it relates to environmental and social safeguards. Specific responsibilities of Company personnel are addressed in the following sections. Company organisational structure, showing the position of staff assigned to ensure environmental and social safeguards
Chief Executive Officer
Chief Operations Officer
Procurement
Mine
Rail
Port
Townships
Safety, Health & Environment Health and Safety
Government Relations Corporate Responsibility Community Liaison
Purchasing
Fuel handling
Contracts
Environment
Operations
Electrical
Mechanical
Technical
Operations Maintenance
Roads
Operations
Materials Handling
Maintenance
Power Generalised hierarchy controlling each operational unit
Utilities
Maintenance
Chief Executive Officer
Chief Operations Officer The three operational units (in the mine, rail and port) will have four teams each, working a three-shift rota. Most of the other units will be singleteam structures, where continuous working is not necessary.
Manager
Superintendent (1 per unit)
Foreman (1 per team)
Supervisor (varies)
Operators (teams)
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8.2
The Company
The Company is the owner of the project and takes the ultimate responsibility for all actions in its implementation. The Company is represented by the Chief Operations Officer with respect to ultimate responsibility for operational actions and effects. 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 Companys 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; Participation in Environmental Compliance Reviews; 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.
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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 Companys 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 Projects 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 Companys 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; Participation in Environmental Compliance Reviews; Active involvement in Community Consultative Meetings; With the Environmental staff, review of conditions following completion of works on site;
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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
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 Contractors 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 Projects 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 projects 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 Environmental Compliance Reviews; 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.
8.4
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 Companys Community Liaison Officers. As outlined in other sections of this EMP, a targeted employment policy should be extended to all potentially affected communities.
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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 Companys Human Resources Plan. For short term works, guidelines are given in standard 3.4 of the Companys Environmental Standards Manual.
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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 Companys Operations

Potential impacts (positive & negative) 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. Prevention, control and mitigation measures 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. 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 Fuel and oil storage
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.
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Issue Delivery and handling of hazardous materials
Prevention, control and mitigation measures 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 Loss of containment from spills or AML to develop and implement Hazardous Materials Management Plan. (including inadequate disposal.Chemicals spill or herbicides) leak to the environment with toxic effects All people associated with the use of chemicals need to be trained on chemical handling and the interpretation storage to soil and water, resulting in polluted and use water supplies, or habitat degradation and and use of MSDS. wildlife mortality and/or reduced Minimise chemicals stored, reuse where possible.Select reproductive success. Some chemicals chemicals with least environmental impact where may be mutagenic. Some chemicals are, possible.Use only chemicals that are certified for use or contain, substances which bioworld-wide and approved by the Liberian EPA. Chemicals should be stored down gradient of any public accumulate.Improper use by poorly trained workers leads to damaging health water supply boreholes.All containers must be clearly labelled. Labelling must include non-verbal warning effects.Some chemicals pose a potential for explosion in confined spaces. 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.
Potential impacts (positive & negative) 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.
9.2
Mine
Component-specific Potentially Hazardous Materials and Waste Streams
Issue Handling, storage and use of explosives
Potential impacts (positive & negative) 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.
Prevention, control and mitigation measures 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.
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Yekepa Township
Issue Sewerage system operation Potential impacts (positive & negative) 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. Prevention, control and mitigation measures 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. Discontinue the use of current system. Correct design, operation and maintenance of waste water treatment plant. Follow manufacturers specifications. Implement a discharge monitoring programme which includes contingency arrangements in the event of operational failure. 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 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 EPAapproved facility.
Waste water treatment
DSO phase will operate under a refurbished system (only for EA, EB, EU, C and D blocks). Risk of effluent pollution.
Waste generation and management
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 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
Waste disposal
Buchanan Township
Issue Sewerage system refurbishment Potential impacts (positive & negative) 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. Prevention, control and mitigation measures 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.
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Issue Sewerage system operation
Potential impacts (positive & negative) DSO phase will operate under a refurbished system . Malfunction of this would result in discharge that is non-compliant.
Waste generation and management
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 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
Waste disposal
Prevention, control and mitigation measures 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. 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 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 EPAapproved facility.
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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 Assessment of Responsibility for condition and checking performance Environmental Officer for biophysical matters. Community Liaison Officer for socioeconomic matters. To be completed at each check.
What you MUST 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.
What you must NOT do
Check timing
Action required
Respect the environment:

we have only one planet! 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.
General principles Section 5 of this Undertake any work beyond EMP. 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. Environmental awareness Allow staff and workers to neglect environmental issues. This may lead to offences under the Environment Protection and Management Law.
Before starting work. Monthly during operations. After completion of operations.
Only to be completed at check if compliance is not satisfactory. State who is responsible for action.
Standard 12.1.
Monthly during site operations.
Environmental Officer.
To be completed at each check.
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Employee and Contractor compliance obligations What you MUST do What you must NOT do
Applicable standard (see Standards Manual) Standard 1.1. H&S Manual and Rules.
Check timing
Monitoring Assessment of Responsibility for condition and checking performance Health and Safety Manager. To be completed at each check.
Action required
Provision of safety equipment Provision of safety equipment Allow workers on to a site Provide all workers with without the appropriate safety safety equipment gear. appropriate to the work Allow first aid kits to become that they are doing empty or out-of-date. 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!
Weekly during site operations.
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10.2
Hazardous Materials Management

Employee and Contractor compliance obligations What you MUST do What you must NOT do Sanitation at temporary work sites Allow latrines to become full or overflow. Allow site workers to defecate at random in the forest. Pollution from site camps and stores 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. Applicable standard (see Standards Manual) Standards 1.2, 1.3. Monitoring Assessment of Responsibility condition and for checking performance Environmental Officer. To be completed at each check.
Check timing
Action required
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. 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.
Only to be completed at check if compliance is not satisfactory. State who is responsible for action. Only to be completed at check if compliance is not satisfactory. State who is responsible for action.
Standards 9.1, 10.1, 10.2 and others as appropriate.
Environmental Before starting Officer. work. Monthly during site operations. After completion of site operations.
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Applicable standard (see Standards Manual)
Check timing
Monitoring Assessment of Responsibility condition and for checking performance Environmental Officer. To be completed at each check.
Action required
Fuel and oil storage Fuel and oil storage Allow uncontained Standards 9.1, 10.1, Follow the hazardous materials spills and leakages to 10.2, and 11.1 to management guidelines fully. occur, leading to soil, 11.6 inclusive. Only use the designated storage and ground and surface areas , with bunding of 150% volume water contamination. of total capacity Allow soils to become Only use facilities located down contaminated and gradient of public water supply effectively sterilised. boreholes and distant from Allow water courses to watercourses. be affected by runoff Ensure that there are retention carrying toxic systems, including walls, bunds and substances, affecting lined drains to contain any spillages. community water Ensure that there is hard standing, supplies, aquatic with a drainage system that includes biodiversity and wildlife. oil/water separators. Allow waste products Provide caution boards on fire risks that are not collected and for no smoking. and stored appropriately to Ensure spill kits and granules are contaminate the available. surroundings. Have controls in place to minimise Allow emissions of opportunities for fuel pilferage. exhausts to pass Dispose of waste appropriately. outside the site. Maintain Emergency Response / Fire Allow theft to occur, Fighting teams trained for a spillage resulting in spillage and event. pollution elsewhere. Maintain fire fighting equipment at Allow any potential for each facility. explosions to occur. Display fire caution and emergency contact boards. Display operational and control procedures. Provide training for all personnel handling fuel and oil.
Before start of work. Monthly during site operations.
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Check timing
Action required
Refuelling Refuelling Follow the hazardous materials Allow spills and Standards 9.1, 10.1, management guidelines fully, which leakages to go 10.2, and 11.1 to include procedures for refuelling uncontained leading to 11.6 inclusive. vehicles and generators. soil, and ground and surface water Spill kits are to be carried by all contamination. refuelling vehicles. Allow soils to become Keep all fuel tanks in a central contaminated and location. effectively sterilised. Refuel vehicles only on impermeable Allow water courses to hard standings with controlled be affected by runoff drainage (traps and interceptors). carrying toxic Plant refuelling on site is to be substances, affecting carried out according to strict community water protocols for refuelling in unprotected supplies, aquatic areas. biodiversity and wildlife. Enforce the reporting system for Allow emissions of spillage incidents. exhausts to pass outside the site. Train Emergency Response / Fire Fighting teams in readiness for a Allow any potential for spillage, fire or other accident. explosions to occur. Keep fire fighting equipment available at each facility. Provide training for all personnel handling chemicals.
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Employee and Contractor compliance obligations What you MUST do Delivery and handling of hazardous materials Follow the hazardous materials management guidelines fully. 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). Train Emergency Response / Fire Fighting teams in readiness for a spillage, fire or other accident. Provide training for all personnel handling chemicals. What you must NOT do Delivery and handling of hazardous materials 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.
Applicable standard (see Standards Manual) Standards 9.1, 10.1, 10.2, 10.3.
Check timing
Action required
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Employee and Contractor compliance obligations What you MUST do Chemicals storage and use Follow the hazardous materials management guidelines fully. 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 nonverbal 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. What you must NOT do
Check timing
Action required
Chemicals storage and use Standards 9.1, 10.1, Allow any loss of 10.2, 10.4, 10.5, containment from spills 10.6, 10.7. 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 Companys HSE Manager and the EPA. Use any chemicals known to be mutagenic or which contain substances which bioaccumulate. 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.
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Employee and Contractor compliance obligations What you MUST do 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. 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. 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 wellventilated place. In temporary storage locations, ensure complete coverage of the ties and full bunding and filtration of drainage water that might contain creosote leachate. What you must NOT do Chemicals storage and use (continued) As above.
Check timing
Monitoring Assessment of Responsibility condition and for checking performance
Action required
Standards 9.1, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.
Rail Ties (Railway Sleepers) 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.
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Employee and Contractor compliance obligations What you MUST do 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. What you must NOT do
Check timing
Action required
Handling, storage and use of explosives Standard 10.8. 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).
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10.3
Waste Management
Employee and Contractor compliance obligations What you MUST do What you must NOT do Applicable standard (see Standards Manual) Monitoring Assessment of Responsibility for condition and checking performance
Check timing
Action required
General Waste generation and Waste generation and management management Operate a waste management Allow an inadequate This Plan. strategy based on a principle of waste collection, reduction, recovery, recycle segregation, storage and and reuse. disposal system to result in environmental Collect and segregate waste degradation, into hazardous and noncontamination, and hazardous at the source. hazards to human and Avoid waste spills during animal health. storage and handling. Allow an increase in Dispose of all waste in an disposable income appropriate manner. among employees to Maintain full records of the create more waste, both types and quantities of waste quantity and type, generation, storage, transfers without challenging and disposals. perceptions. Conduct recycling and waste Allow spillages of wastes reduction campaigns. during storage and Ensure use of PPE by staff handling. when handling all forms of waste.
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Check timing
Monitoring Assessment of Responsibility for condition and checking performance
Action required
General Waste disposal Waste disposal Dispose of wastes in the most Continue to use the environmentally sound manner present landfill site. possible. Allow the incomplete Design and construct a landfill burial of waste and the site that is lined and to lack of a secure international standards. This compound to lead to should be in an area that is not scavenging. prone to slippage, cannot leach Allow injury to persons to surface water and or the environment from groundwater, and is a suitable waste, resulting in distance from settlement. It company liability. should be located down Allow unauthorised gradient of any water supply persons into storage boreholes. areas Ensure that the landfill site is in Allow an inappropriate a secure compound. site to give negative Ensure landfill operations visual and odour conform to international impacts. standards. Burn waste, creating air Deal with hazardous waste pollution. according to international best practice and EPA guidelines. Dispose of wastes to EPAauthorised facilities. Incinerate medical waste in an EPA-approved facility.
This Plan.
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Employee and Contractor compliance obligations What you MUST do 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. Scrap Iron and Steel Re-use metallic objects and machinery as far as it is practicable and safe to do so. Stockpile scrap in a safe area. Send to a scrap plant within ArcelorMittal or auction against company 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. Stockpile scrap in a safe area. Ensure that copper and lead scrap are kept in dry locations, such as shipping containers. Auction against company rules. What you must NOT do
Check timing
Action required
Topsoil Send topsoil to spoil tips. Standards 6.4, 6.11 to 6.14. Allow traffic to run on topsoil, causing it to become compacted. Allow the erosion or contamination of topsoil.
Scrap Iron and Steel Place scrap into landfill sites. Allow scrap to be stolen by informal scrappers. Sell scrap without following Company guidelines. Non-ferrous Metallic Scrap (e.g. aluminium, copper and lead) Place scrap into landfill sites. Allow scrap to be stolen by informal scrappers. Sell scrap without following Company guidelines.
Environmental Officer. Stores Officer. Finance Officer.
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Employee and Contractor compliance obligations What you MUST do Assets 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). 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. What you must NOT do
Check timing
Action required
Used Commercial and Industrial Machines (vehicles, trucks, generators etc) 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.
Monthly during operations.
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 nonfiltered drains.
Standard 10.1.
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Employee and Contractor compliance obligations What you MUST do 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. 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. What you must NOT do
Check timing
Action required
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) Place spoil anywhere that Standard 6.3. 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.
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Employee and Contractor compliance obligations What you MUST do 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. 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. What you must NOT do
Check timing
Action required
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.
Before start of work. Monthly during site operations. Immediately after any accident or spill.
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.
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Employee and Contractor compliance obligations What you MUST do 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 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. What you must NOT do
Check timing
Action required
Used Grease Place in landfill sites.
Standard 10.1.
Used Filters (fuel and oil filters) 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.
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Employee and Contractor compliance obligations What you MUST do 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. What you must NOT do
Check timing
Action required
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 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 nonfiltered drains. 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.
Standard 10.1.
Not applicable.
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Employee and Contractor compliance obligations What you MUST do Non-assets 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. What you must NOT do
Check timing
Action required
Used Batteries (12-volt lead-acid and gel-filled batteries) 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.
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Employee and Contractor compliance obligations What you MUST do Non-assets 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 noncontaminated 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. 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. What you must NOT do
Check timing
Action required
Used Personal Protective Equipment Place used PPE in landfill Standard 10.1. 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.
Environmental Officer. Health and Safety Officer.
Used Workshop Clothing and Rags (i.e. oily waste) Place oily waste in landfill Standard 10.1. sites. Give away or sell oily clothing to anyone.
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Employee and Contractor compliance obligations What you MUST do 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. 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. What you must NOT do
Check timing
Action required
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.
Environmental Officer. Community Liaison Officer.
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.
Page 57 of 59
Employee and Contractor compliance obligations What you MUST do 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. 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 C in an approved specialist incinerator. Place incinerator ash and residues into an approved landfill site. What you must NOT do
Check timing
Action required
Plastics Burn plastics at low temperatures (<800 C), 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.
Environmental Officer. Community Liaison Officer.
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. Environmental Officer. Health and Safety Officer.
Page 58 of 59
Employee and Contractor compliance obligations What you MUST do Non-assets Used Domestic Machines (refrigerators, air conditioners, washing machines etc) and IT Equipment (computers, printers, UPS 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. Sell used machines for recycling by regular companies with a current Environmental Certificate issued by the EPA. What you must NOT do
Check timing
Action required
Used Domestic Machines (refrigerators, air conditioners, washing machines etc) and IT Equipment (computers, printers, UPS etc) 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.
Not applicable.
Page 59 of 59

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

Hazardous Materials and Waste Management Plan

VERSION DATE: 18 MAY 2011

10. 10.1 10.2 10.3

OPERATIONAL PRACTICES (DOS AND DONTS)

General Environmental Management

Respect the environment: we have only

Standard 1.1. H&S Manual and Rules.

Management of Hazardous Materials

Standards 9.1, 10.1, 10.2 and others as appropriate.

Standards 9.1, 10.1, 10.2, 10.3.

Standards 9.1, 10.1, 10.2, 10.4.

Landfill site design standard in preparation by SNC Lavalin.

AML Procurement and Finance Rules.

AML Procurement and Finance Rules.

Used Grease Place in landfill sites.

INTRODUCTION The Hazardous Materials and Waste Management Plan

Outline of Waste Generation and its Management

ARCELORMITTAL ENVIRONMENTAL POLICY

ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS

ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES

Health and safety of workers

EMERGENCY RESPONSE PLAN

IRTL IRTL HSE Manager

HR HSE Manager IRTL HSE Manager

ENVIRONMENTAL COMPLIANCE CONTROLS

Environmental Awareness Briefing for Site Crews

Environmental Compliance Review Meetings

Local Consultative Forums

Environmental Compliance Inspections and Documentation

RESPONSIBILITIES Organisational structure

Chief Operations Officer

Safety, Health & Environment Health and Safety

Government Relations Corporate Responsibility Community Liaison

Power Generalised hierarchy controlling each operational unit

Chief Executive Officer

Superintendent (1 per unit)

Foreman (1 per team)

IDENTIFIED POTENTIALLY HAZARDOUS MATERIALS AND WASTE STREAMS

Potentially Hazardous Materials Used in all Parts of the Companys Operations

Issue Fuel and oil storage

Issue Delivery and handling of hazardous materials

Component-specific Potentially Hazardous Materials and Waste Streams

Issue Handling, storage and use of explosives

Waste water treatment

Waste generation and management

Issue Sewerage system operation

Waste generation and management

PLAN MANAGEMENT AND ITS MONITORING

General Principles of Environmental Management

What you must NOT do

Respect the environment:

Before starting work. Monthly during operations. After completion of operations.

Monthly during site operations.

To be completed at each check.

Weekly during site operations.

Hazardous Materials Management

Monthly during site operations.

Standards 9.1, 10.1, 10.2 and others as appropriate.

To be completed at each check.

Applicable standard (see Standards Manual)

Before start of work. Monthly during site operations.

Applicable standard (see Standards Manual)

Before start of work. Monthly during site operations.