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Dubai LNG Regasification Project Draft ESHIA Report
11 Environmental Social and Health Management Plan (ESHMP) Overview

This section is intended to be standalone document that will form the basis for the environmental management system during detailed design, construction and operation of the project. This Environmental Social and Health Management Plan (ESHMP) has been prepared to aid delivery of the projects environmental social and health commitments that have been identified through the Environment Social and Health Impact Assessment (ESHIA) process. The commitments from the ESHIA have been captured in a Commitments Register that has been expanded to form an Action Tracking Register, which is included as Appendix 1. The ESHMP sets out how the commitments will be translated into actions in the field and the means by which they will be monitored and verified. This ESHMP will form part of the construction and operation contract and will therefore be contractually binding. It outlines the environmental social and health commitments that are to be delivered by the Construction and Operations Contractors. The ESHMP focuses, in particular, on the following topics that are recognized as being the main mechanisms by which commitments are translated into practice: Practical training and awareness of construction and project staff; and Supervision and monitoring of environmental, social and health issues in the field.
An overview of the project ESHMP is provided in Figure 11.1.
P180005 November 2007 Rev 03
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Figure 11.1: Dubai LNG Regasification Project ESHMP Structure
11.1 Introduction
The ESHMP Overview describes the: Project outline The projects approach to management of environmental and social issues and how the elements shown in Figure 11.1 will be managed and co-ordinated
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HSE policy; The projects organization, roles and responsibilities, including responsibility for provision and implementation of the various elements of the ESHMP; Record keeping; and Environmental, social and health impacts and commitments.
The purpose of the ESHMP Overview is to set out the main elements of the system in order to establish a common understanding between the key staff involved in ensuring effective environmental and social management of the project.
11.1.1 Project Outline

In 2005, the Dubai Government predicted a potential shortfall of gas supplies during the periods of peak energy demand in summer from May 2010 onwards. It approached the Shell Group with a view to developing facilities to allow the shortfall in gas supplies to be covered by importing 3 million tonnes of LNG per year. Shell proposed the Dubai LNG Regasification Project, with DUSUP holding the lease and operating agreement. Shell has proposed a development involving the permanent mooring of an LNG tanker with retrofitted regasification equipment alongside a piled freestanding jetty to be constructed in the Port of Jebel Ali. The converted LNG tanker will act as a floating storage and regasification unit (FSRU). The FSRU will have LNG loading, storage and regasification facilities. The jetty will have loading arms for gas and will be connected to Dubais gas network via a 2km, 24-inch (61cm) diameter high-pressure gas pipeline. It will have the capacity to deliver 13 million cubic metres of gas per day to gas users in Dubai.
11.1.2 Commitments and Action Tracking Registers

The Commitments Register from the ESHIA has been developed into an Action Tracking Register, which is included in Appendix 1. The Register lists how each commitment will be implemented via the appropriate plan or procedure detailed in Section 11.5 and through training. The Register includes a status column that will be regularly updated by the DUSUP (with the support of Shells ES&H Officer) during the course of the project until each commitment is complete, i.e. discharged. This ESHMP and the Action Tracking Register form part of the construction and operation contract and are therefore contractually binding. The Action Tracking Register, however, is a live document as consultation is ongoing at the time of preparation of this ESHMP and further items may need to be added during construction and operation. It will be updated during the course of the project by DUSUP with input from the Construction and Operations Contractors.
11.1.3 Management Approach

Shells approach to Environmental, Social and Health Management is to apply the principles of environmental social and health protection to all activities for which it is responsible. These principles include: Prior assessment of environmental, social and health impact; Minimization of potential impact through design and other mitigation controls;
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Monitoring efficacy of controls; and Auditing of performance.
11.1.4 Corporate HSE Policy

DUSUP has asked that Shell implement the project using their principles of environment, social, health and safety best practice. Shell has a Corporate Health, Safety and Environmental Policy that will apply to the project and is provided below. Every Shell company: Has a systematic approach to HSE management designed to ensure compliance with the law and to achieve continuous performance improvement; Sets targets for improvement and measures, appraises and reports performance; Requires contractors to manage HSE in line with this policy; Requires joint ventures under its operational control to apply this policy and uses its influence to promote it in other ventures; and Includes HSE performance in the appraisal of all staff and rewards accordingly.
In the Group, we all committed to: Pursuing the goal of no harm to people; Protecting the environment; Using material and energy efficiently to provide our products and services; Developing energy resources, products and services consistent with these aims; Publicly reporting on our performance; Playing a leading role in promoting best practice in our industries; Managing HSE matters as any other critical business activity; and Promoting a culture in which all Shell employees share this commitment.
In this way, we aim to have an HSE performance we can be proud of, to earn the confidence of customers, shareholders and society at large, to be a good neighbour and to contribute to sustainable development. In addition, there are three Group HSE Golden Rules that help us to put our policy and commitment into practice. They are addressed to staff: You and I; Comply with the law, standards and procedures; Intervene in unsafe or non-compliant actions; and Respect our neighbours.
11.1.5 Project Organization, Roles and Responsibilities

An MOU was signed on 28 June 2005 that allows both parties (Shell Gas & Power and DUSUP) to carry out joint business development of the pre-FEED work for an LNG Import Facility. During the Select phase, it is assumed that Shell Gas & Power will be managing all
th
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works and DUSUP is in a consulting assistance role. Shell Gas & Power has contracted Shell Global Solutions to perform technical studies. During the design phase, it is assumed that Shell Gas & Power is also managing all the work though DUSUP will be engaged further. DUSUP DUSUP is responsible for letting and managing contracts for construction and operation of the project to competent contractors. Shell will provide an ES&H Officer who will be responsible for the overall management of environmental, social and health performance during detailed design, construction and operation, including update and development of the Action Tracking Register. The ES&H Officer will report directly to the Shells Project Manager. Construction/Operation Contractor The Construction and Operation Contractors are expected to appoint a full-time, suitably qualified Environmental Social and Health (ES&H) Officer to ensure effective implementation of the environmental, social and health commitments contained in the ESHIA. The Construction and Operation contractors are expected to comply fully with those aspects of the ESHMP for which they are responsible. A summary of those roles and responsibilities is provided in Table 11.1. A copy of the ESHMP will be included in the Contractor Bid Documentation. Table 11.1: Summary of Roles and Responsibilities for the ESHMP
ITEM
ESMP ESHMP
DUSUP
Prepare/Review/ Approve. Lead implementation Prepare and deliver Prepare and deliver
CONSTRUCTION/OPERATION CONTRACTOR
Implementation for those items for which responsible in the contract
Training DUSUP Senior Management Briefings Construction Contractor Senior Management Briefings Induction
N/A Participate
Toolbox Talks ESMP Pocket Guide Audits/Monitoring Monthly audits
Prepare and Deliver (ES&H Officer) and participate (others) Prepare and assist with delivery Prepare/implement Participate; identify non-conformances; advise re corrective and preventative actions; monitor close out of actions. Review nonconformances.
Participate
Deliver (ES&H Officer) and participate (others) Implement Lead and report
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ITEM
Weekly inspections
DUSUP
Participate; monitor close out of actions Review nonconformances Record and review
CONSTRUCTION/OPERATION CONTRACTOR
Lead and report
Daily observations Reports Daily Observations Diary
Record Maintain jointly with Shell
Maintain jointly with Construction Contractor; review close out of actions Incident and Near-Miss Review/approve and update re: actions/lessons learnt Audit Reports Review/approve Monthly Environmental and Review/approve and Social Reports add items for which Shell is responsible Plans/Procedures/Method Statements Change Control Procedure Prepare ESMP Plans: Community Review, implement Liaison and audit Contaminated Land Ecology Employment, Training and Procurement Pollution Prevention and Control Emergency Response Plan Traffic Management Waste Management Method Statements (see Review/approve Section 11.6 for environmental activities to be included in MS) Project Organisation
Prepare
Prepare Prepare
Implement Prepare, implement and audit
Prepare
Figure 11.2 represents an organization chart for project personnel with environmental, social, health responsibilities. The Construction and Operation Contractors should provide CVs with their tenders for the personnel identified in the organogram.
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Figure 11.2: Project Environmental, Social and Health Organogram
11.1.6 Code of Conduct

The following set of rules for behaviour on site, in the construction office, workers camp and at all other project locations will be adopted: Access to the work areas will be restricted to the construction workforce and project staff: o o o o Personnel will be issued with a permit on completion of their induction training; Permits will be carried at all times and be available for inspection on request; Access to work areas will be restricted to personnel carrying a permit and authorized visitors on project-related business; and Authorized visitors will be accompanied by a permit holder at all times
Zero tolerance of illegal activities including the use of illegal drugs by construction personnel; Zero tolerance of bribery; No use of project vehicles for non-work business;
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No use of personal vehicles within construction areas; Zero tolerance of alcohol and/or drunkenness; Strict adherence to traffic regulations and project speed limits; Seat belts to be worn by all drivers and passengers; Inconsiderate behaviour towards local land users will not be tolerated; No firearms or weapons to be carried; Appropriate PPE to be worn (which as a minimum will comprise overalls, safety boots, hard hat and high visibility vest); Potable water to be available for personnel during construction; Smoking only allowed in designated areas; and Adherence to Dubai and the UAEs laws and regulations.
11.1.7 Record Keeping

A project environmental social and health filing system will be established at the construction office. The system will contain the following documents: ESHMP; ESHIA; Monthly audit reports; Weekly inspection reports; Daily diary observations; Environmental social and health incident forms; Complaints register; Environmental and social correspondence; Method statements; Training materials; and, Training plan and records.
11.1.8 Impacts and Mitigation Measures

A summary of the impacts and mitigation measures identified during the ESHIA process is given in Table 9.10 of the ESHIA. The mitigation measures are included in the Commitments Register, which has been developed into an Action Tracking Register and is provided in Appendix 1 of this document.
11.2 Training
Training requirements are highlighted in Figure 11.1 along with identification of the delivery mechanism. This is a relatively short project and the emphasis is on establishing common environmental social and health requirements and standards before or during the first few weeks of construction. All training will be delivered in English and additional languages, as appropriate and delivered through: Senior management briefings to management personnel;
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Induction courses for everyone working on the project; and Toolbox talks for individual construction teams.
11.2.1 Senior Management Briefings

The Dubai LNG Regasification Terminal Projects project manager, will organize a training workshop for the key staff listed in Section 11.2 to provide an overview of the ESHMP and ensure common understanding of roles, responsibilities and standards for the project. Following award of contract, DUSUP (through Shells Project ES&H Officer) will repeat the workshop with the Construction and Operations Contractors senior personnel. This will ensure that they are briefed fully on the ESHMP requirements and to DUSUPs commitment to good environmental performance and community relations.
11.2.2 Induction
All project construction staff will attend an environmental, social and health induction course that will take 12 hours and will explain the key requirements common to everyone on the site. The induction will have a strong focus on visual presentation graphics, illustrations, diagrams, photographs and will contain simple, clear messages. The induction courses will be prepared and delivered by Shells ES&H Officer with the assistance of the construction and operation contractors management team. Induction training will be provided to all personnel before they commence work on site. Induction courses will therefore be delivered regularly particularly during the first few weeks of the project and a training log will be maintained to record attendance. The main topics covered will be: Dubai & UAE Environmental Policy; The key sensitive receptors and actions required to protect them during day-to-day operations; Prevention and clean up of spills; Discovery of previously unknown contaminated land and new fly-tipping; Speed restrictions; Traffic safety; Noise minimization; Waste handling and storage; Good housekeeping; and Project Code of Conduct.
11.2.3 Toolbox Talks

In addition to the induction, toolbox talks will be held to provide supplementary information to staff involved in operations with the potential for significant environmental impacts and/or for which there are specific environmental, social or health requirements not covered in the general induction. A toolbox talk is a shortened training course, lasting between approximately 15 and 30 minutes, delivered direct to a field crew before a task begins. The toolbox talk will be related closely to the appropriate Method Statement for the relevant operation.
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Toolbox talks will be developed by the Construction and Operation Contractors ES&H Officers with support from Shells ES&H Officer. They will be delivered by Construction or Operation Contractors ES&H Officer, with support, from Shells ES&H Officer. The content of the toolbox talks is provided in Section 11.5 as the management plans have been written as bullet points to facilitate delivery of the project requirements to the workforce through training.
11.2.4 ESHMP Pocket Guide

In order to ensure maximum compliance with the ESHMP, a small, laminated pocket guide to the project environmental, social and health issues will be produced by the Shells ES&H Officer and distributed to all staff. This guide is intended to augment the training already received and will detail important information such as site emergency contact numbers/emergency radio bands, locations of spill kits and first aid kits, waste segregation and storage and speed limits.
11.3 Audits, Inspections and Observations

Regular audits and inspections of the project ESHMP will be conducted to track progress and performance. Reporting of these will be expected, as outlined in Section 11.4. Audits, inspections and observations will include: Monthly audits led by the Construction or Operation Contractors ES&H Officer, with the participation of the Shells ES&H Officers; Weekly joint inspections by Shell and the Construction or Operation Contractors; Weekly reviews by Shell of corrective actions from previous audits; Daily observations by Shell and the Construction and Operation Contractors; At the beginning of each monthly audit, Shells ES&H Officer will review the close-out of actions from the previous month; and One-off checks by Shell (e.g. Waste Audit).
An audit of the project may also be scheduled as part of Shells Environmental Management System audits. The frequency of monitoring for individual commitments is identified in the Action Tracking Register in Appendix 1. This will be reviewed regularly and will be adjusted as necessary to take account of audit findings.
11.3.1 Monthly Audits

The monthly audits will involve a full review and update of the Action Tracking Register and will therefore cover all the key elements of this ESHMP. The Construction and Operation Contractors ES&H Officers will submit an updated version of the Action Tracking Register (Appendix 1), with a summary report of the audit findings, to Shell within two days of completing the audit. Shells ES&H Officer will:
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Review and approve each audit report; Identify any non-conformances; Identify/agree corrective actions (with timescales) with the Construction Contractor; and Monitor the close-out of corrective actions at least weekly.
11.3.2 Weekly Inspections

The weekly inspections will be simpler, concentrating on day-to-day items such as pollution control, waste storage, and traffic movement. In addition, certain requirements are best monitored through informal daily observations, which are made whilst personnel are travelling around the works.
11.3.3 Daily Observations

A diary containing daily observations will be maintained by the Construction and Operation Contractors and Shells ES&H Officers. The diary should also record the actions taken to correct any observations that could lead to a breach of the commitments or contract. The diary will be reviewed as part of the monthly audits by Shell.
11.4 Reporting
The amount of reporting required by the ESMP has been minimized as far as practicable, having regard to the scale and length of the project. However, a minimum of four types of report is required, as detailed below. All reports will be prepared in English to facilitate review.
11.4.1 Incident & Near-Miss Reports

All personnel employed on the project are responsible for reporting all environmental incidents and near misses. Whilst ensuring the safety of themselves and others, all personnel are required to initiate and or/assist in immediate containment/ remediation/corrective action to their best of their capabilities in relation to incidents and near misses. Incident and near-miss reports will be generated by the Construction Contractor, Operation Contactor and DUSUP, as appropriate, and will be completed after any environmental, social or health incident or near-miss. These include spills, environmental damage, accidents, complaints from communities and neighbours, etc. A pro forma will be produced which will include identification of root causes and recommendations for mitigation and improvement. Incident and near miss reports will be submitted to the Construction or Operation Manager within 48 hours of the occurrence. Each report will be reviewed by the DUSUP who will be responsible for ensuring that appropriate action is taken to prevent a recurrence. Records of incidents and near misses shall be kept at the site office.
11.4.2 Audits, Inspections and Observations

Monthly audit and weekly inspection reports will be generated through the audit process described in Sections 11.3.1 and 11.3.2. Daily observations will be recorded informally in a diary as described in Section 11.3.3.
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11.4.3 Monthly Environmental & Social Report

A short combined Environmental, Social and Health Report will be generated by the Construction and Operation Contractors, and reviewed by DUSUP each month. This will include: Incidents and near misses; Status of all non-conformances identified during audits and inspections; Complaints; Accidents; Waste volumes, types and disposal; Contaminated land discovered; Archaeological finds; Ecological issues; and Other relevant environmental issues.
11.5 Plans and Procedures

The suite of plans and procedures detailed in this section forms the framework for managing environmental and social issues throughout construction and operation. They will form the contents of the training described in Section 3. Target audiences for training are outlined in Appendix 1, together with audit frequency for each commitment.
11.5.1 Community Liaison

The Construction and Operation Contractors ES&H Officers will: Maintain a Communications Log that records discussions with community members; Maintain a Complaints Register that records all complaints from local communities. The Complaints Register will be available for project stakeholders and local community representatives to inspect when requested; and Provide details of any discussions with DP World, PCFC and Dubai Government Officers or Inspectors.
The Construction and Operation Contractors and DUSUP will monitor the above activities on a monthly/weekly basis as detailed in Appendix 1. In addition, they will jointly review the Complaints Register monthly. Deliverables: Communications Log; Complaints Register: o o o o o o o Date complaint was lodged; Name and contact details of the complainant; Nature of complaint; Agreed corrective action and party responsible for implementation; Record of when the correction was completed; Record of outcome as agreed with complainant; and Date of close-out.
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11.5.2 Contaminated Land

Before construction begins, DUSUP will carryout a contaminated land survey to identify potential areas of contamination. If contaminated land is identified: Clear the area of known contamination: o o o o o o o Prepare a Method Statement and Risk Assessment before clearance of contamination begins; Ensure appropriate precautionary measures identified in the Risk Assessment are implemented, including use of appropriate PPE; Ensure removal of fly-tipped materials from all construction areas; Ensure removal of any contaminated top-soil from the stripped portion of the ROW, pipe yard and camp area; Ensure removal of oil contaminated sub-soil from areas that will be excavated, e.g. during trenching; Run a toolbox talk for the contamination clearance team to reinforce the above points; Advise the Contractor of: The potential for discovery of contamination; The need to undertake a risk assessment if any contamination is found; and The requirement to remove contamination only to project approved facility and/or for treatment. Deliverables: DUSUP: Agreed methodology for treatment/disposal of oil contaminated soils; and Risk assessment and method statement for clean-up.
Construction Contractor: Risk assessment and method statement for clean-up if additional contamination is found; and Waste disposal records (to be transferred to Shell on completion of construction and kept for at least two years).
11.5.3 Ecology
The Construction contractor will produce a Method Statement detailing Piling operations. This will be review and approved by DUSUP before work begins. The Construction Contractor will: Consider using quieter method of piling, e.g. vibropiling; Initiate a soft start up of all piling operations; and
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Employ an ecological observer to monitor start up and with the power to halt piling operations if a marine mammal or turtle strays into the operational area.
Deliverables: Construction Contractor Piling Method statement; and Daily log of marine mammal/turtle activity during operations.
11.5.4 Employment, Training and Procurement

The construction and operational workforce at the LNG Terminal location will comprise fewer than 200 contractor personnel including the crews of piling rigs, the onshore pipeline preparation crew, the pipeline lay-barge crew and divers. The pipeline lay-barge crew will be accommodated on the barge. The remainder of the workforce will be sourced from staff that are routinely accommodated in construction contractors camps in the Jebel Ali area. DUSUP will: Implement Shell corporate diving procedures for managements of all diving activities.
The Contractor and Operations Project Manager will: Ensure the living conditions of the projects work force meets ILO standards; Ensure that all staff and subcontractors receive HSE induction training; Ensure all staff have the required PPE; Ensure that the relevant staff, receive toolbox talks; Maintain a log of attendees at all training sessions; and Maximize purchase of goods and services from local sources.
Deliverables: Shell corporate diving procedures; Recruitment statistics; and Training records.
11.5.5 Pollution Prevention and Control

The Construction and Operations Project Managers (assisted by the ES&H Officer) will prepare a Pollution Prevention and Control Plan, which will cover the prevention and control of pollution resulting from dust, noise, fuel/oils, hydrotesting, and chemicals. This will include the following as a minimum: The Construction and Operations Project Managers (assisted by the ES&H Officer) will: Ensure full implementation of the Pollution Prevention and Control Plan; Prepare and implement a Hydrostatic Test Procedure that shall be reviewed by, and agreed with, DUSUP;
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Ensure that all staff are trained in pollution prevention and control measures and the use of oil spill containment and clean up equipment; Locate oil spill clean up and containment equipment (granules, booms etc) at the all areas of construction and operational activity; and Develop additional mitigation measures, where relevant, e.g. the imposition of tighter speed limits, if necessary, to avoid causing nuisance to residents or land users.
All foremen (i.e. construction team leaders) will: Check all machinery on first arrival and reject it, or send it for maintenance, if it: o o o Emits visible smoke; Emits exhaust gases that smell of unburnt hydrocarbons; and Is leaking oil or fuel
Make daily visual observations of plant and vehicles for oil leaks and exhaust smoke/odour; Organize maintenance for, or replacement of, any plant or vehicles with oil leaks or emitting exhaust that is black or smells of unburnt hydrocarbons; Ensure that no hazardous chemicals (including fuels and oils) are stored within 30m of the shore or securely stored in an impermeable store; and Ensure that the points included in induction training for the entire workforce (see below) are implemented.
The entire workforce will be advised that: Plant and vehicles speeds will be restricted within construction areas and comply with the legal limit on roads; Equipment must be well maintained and adequately silenced to avoid causing nuisance; Additional noise attenuation measures (e.g. noise barriers) must be used where necessary to prevent nuisance; Equipment must be switched off when not in use; Mobile plant must not be refuelled within 30m of the shore line; Drip trays must be used under all static plant and equipment; If a spill occurs at a location that might lead to flow into the sea, cut off trenches should be dug to intercept it; and All spills must be cleaned up promptly and contaminated materials disposed to a project approved facility.
All drivers will: Observe all national and project speed limits; Ensure that plant and vehicles are maintained regularly; and Sheet vehicles carrying soil, spoil or other fine materials.
The hydrotest crew will:
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Implement all the requirements of the hydrostatic test procedure; Avoid the use of hydrotest chemicals if possible; and Filter and test the quality of the receiving water and hydrotest water before discharge to ensure the discharge does not adversely affect the quality of the receiving water.
The construction crew will: Damp down the working areas whenever necessary to prevent dust nuisance
Deliverables: Contractor Construction and Operation Pollution Prevention and Control Plans (to be reviewed and approved by DUSUP), to be included as an Appendix to the ESHMP; Hydrostatic test procedure; Log of vehicle/equipment maintenance and checks; and Record of quality of hydrostatic test water before discharge.
11.5.6 Emergency Response

The Construction and Operations Project Managers (assisted by the ES&H Officer) will prepare Emergency Response Plans detailing the procedure to follow in the event of an environmental emergency. This should include: Emergency contact numbers; Closest medical facility; Definitions of hydrocarbon spills, e.g. small spill <10 litres; and Procedures for responding to different spill sizes.
Deliverables: Construction and Operation Contractors: Emergency Response Plans (to be reviewed and approved by DUSUP) to be included as an Appendix to the ESHMP.
11.5.7 Traffic Management

The Contractors Construction Manager will ensure that: A Traffic Management Plan (TMP) is developed. This will detail: o o o o All drivers will: Approved onshore routes to and from construction areas; Approved offshore routes to and from the construction area; Health and safety requirements at site entrances and areas where construction occurs adjacent to the roadway; and Adherence to Shells Road Safety standard August 2007.
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Use only defined access routes, identified within the TMP; Ensure all vehicles are adequately maintained so that all safety features including brakes, lights etc., are in good condition. Maintenance records to be held within the construction site office; All drivers and passengers to wear seatbelts at all times; Adhere to the construction site speed limits; and Adhere to national limits on other roads.
Deliverables: Construction Contractor Traffic Management Plan (to be reviewed and approved by DUSUP), to be included as an Appendix to the ESHMP.
11.5.8 Management
DUSUP will: Review of hazardous and non-hazardous waste disposal sites within 50km of Jebel Ali; and Identify the waste disposal sites that most closely meet the requirements of the EU Landfill Directive (1999/31/EEC). These sites referred to in are this document as the project approved landfills.
The Construction and Operational Contractors Managers (or nominated representatives) will ensure that: Wastes are minimized; Wastes are segregated; Wastes are reused or recycling in preference to being sent to a landfill site; Wastes are stored in a secure manner pending disposal; Hazardous wastes are stored separately in locked containers; Sewage disposal is to a local sewer, or septic tank that is emptied by a licensed contractor; All waste is disposed of promptly and is only taken to a project approved facility; and Maintain records of waste disposal including the volume, nature of waste(s), disposal site, date and time for each load.
Deliverables: DUSUP Review of waste disposal sites.
Construction and Operation Contractor: Waste Management Plans (WMP) (to be reviewed and approved by DUSUP), to be included as an Appendix to the ESHMP; and
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Waste disposal records (to be transferred to DUSUP on completion of construction, and kept for at least two years).
11.5.9 Change Control Procedure

Introduction During the course of a project, there will inevitably be changes to the planned methods of working. It is essential that these are not considered in isolation and that the potential impacts of proposed changes are reviewed in the context of commitments given in the ESHIA. The object of this Change Control Procedure is to control such changes to ensure that the associated environmental, social and health risks remain at an acceptable level and that the effects they have are advised around the project in a logical manner. Procedure Once a potential change is identified, the identifier is to advise his/her manager and start to complete the Change Notice (CN) form (to be written in consultation with the contractor), by completing the Scope and the Justification sections. The most usual justifications for changes include the following: Technical scope change; Health/safety/environmental/social the change will potentially affect the health and safety of persons, or protection of the environment and community, during fabrication, construction, commissioning, operations, maintenance or decommissioning. The change could be outside of the scope of approvals received and may require additional approvals/notifications; Constructability the section of the project cannot be fabricated or constructed as designed or specified; Statutory the change is necessary to comply with legislation or other mandatory requirements; Commercial allowing for the cost of the change, there is commercial benefit in making the change; Schedule the schedule may be at risk if the change cannot be accommodated; Procurement a supplier cannot meet previous commitments and obligations; and Security exposure to security risk is increased/decreased.
The CN Form, with any associated support documents, is raised and signed by the project manager of the Construction Contractor, and will include details of estimated costs, schedule, social and environmental impacts. Any extended comments and relevant backup documents should then be included with the CN and forwarded to the Shells Project Manager. Each CN will be assigned a unique number by the Shells Project Manager and circulated to the relevant personnel for review and signature. The ES&S officers of each company will review the ES&H implications of each CN and advise the project manager if any represent an acceptable risk. A CN is only accepted once it has signature from the ES&H Officers and Project Managers.
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Once approved, a CN must be circulated to all interested parties. Any instruction to the Contractor shall be made in writing. If at any stage the CN is not accepted, it shall be returned to the Shells Project Manager who will advise those involved. Environmental and Social Considerations From an environmental and social perspective the Management of Change process must address the following: Changes to the execution strategy and methodology that have the potential to affect implementation of mitigation measures agreed through the ESHIA process; Contract deviation requests which have the potential to impact environmental, social and health mitigation measures or the functioning of the ESHMP, such as 24-hour working; Design changes initiated which have the potential to impact the ability for the project to meet project environmental, social and health standards, e.g. emissions, discharges, noise; Changes to locations for temporary facilities to those contained in the ESHIA; New activities which have not been assessed as part of the ESHIA process; Route changes; and Major changes to construction planning such as an introduction of additional working areas and implications on training and resources.
Management of Change Process The Management of Change process should include the following elements: Identify identification of whether the change has the potential to have ES&H implications; Assessment evaluation of the potential impacts of the change in terms of environmental and social issues as well as the potential ramifications on schedule as a result of the ES&H implications; Decision three options: o o o Change accepted; Rejected; or Accepted with additional mitigations
Follow up if the change is accepted with mitigations then the follow up will consist of one or more of the following: o o o o o o Communicate the requirement for additional mitigations to persons responsible for implementation; Determine whether regulatory approval is required and time required for this; Document requirement through update of procedures; Implementation of additional mitigations; Communicate changes to stakeholders; and Track implementation of additional mitigations
Transparency regardless of the outcome of the change, the whole process must be transparent and auditable by ensuring adequate paper trail.
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11.6 Method Statements and Procedures

The Construction and Operations Contractor will produce method statements (MS) or procedures to address all key activities. Before works begins, Shell will review and approve all MS and procedures to ensure that they incorporate environmental requirements, as detailed in the ESHIA and summarized in Section 11.5.
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Appendix 1 Action Tracking Register/Monthly Audit Checklist
Key to Abbreviations: CC Construction Contractor ES&H Environmental Social & Health Officer MMO Marine Mammal Observer Audit Reference: (Day/Month/Initials of Auditor) Auditor: Auditee:
Action Levels: A1 A2 A3 Not compliant with legislation or Project standards Not compliant with the ESHMP Area where improvements could be made
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ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3)
COSTS Approximate Costs (AED)
A1 - Construct Jetty and Dolphins S1.1 Seabed disturbance (anchors, jack up rig, piles) Use of a jack up barge, ESHIA Construction Construction rather than an anchor Chap.10 Contractor Table 10.10 handled vessel to reduce seabed disturbance by anchor scars Once *
Minimize the number of times that the barge is required to be repositioned as far as possible S1.1 Seabed Positioning of jack-up disturbance barge primarily in (anchors, jack up areas where the rig, piles) seabed has recently been dredged, rather than in previously less disturbed areas to avoid unnecessary disturbance to more established benthic habitat S1.1 Seabed disturbance (anchors, jack up rig, piles)
ESHIA Construction Construction Chap.10 Contractor Table 10.10
Once
Construction Construction ESHIA Contractor Chap.10 Table 10.10
Once
Part of Construction Scheduling and Planning. No additional cost. Part of Construction Scheduling and Planning. No additional cost.
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ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Once
S1.2 Emissions Construction Construction Construction ESHIA (engines) contractor to prepare a Chap.10 Contractor Pollution Prevention Table 20.10 and Control Plan to address the prevention and control of pollution including exhaust emissions
18480 AED
S1.2 Emissions Contractor to maintain ESHIA Construction Construction (engines) engines Chap.10 Contractor Table 10.10 S1.2 Emissions Construction (engines) Contractor to inspect condition equipment before start of work S1.2 Emissions DUSUP to audit (engines) maintenance records S1.3 Discharges (piling cuttings) Method statement for discharge of pile cuttings to be approved by PCFC/DUSUP ESHIA Construction Construction Chap.10 Contractor Table 10.10
Monthly
Ongoing Construction Operations. No Additional Cost Ongoing Construction Operations. No Additional Cost 7392 AED (per monthly audit) Ongoing Construction Operations. No Additional Cost
As Required
Construction DUSUP ESHIA Chap.10 Table 10.10 ESHIA Construction DUSUP/PCFC Chap.10 Table 10.10
Monthly
Once
Page 11-23
ISSUE
COMMITMENT
SOURCE
S1.3 Discharges (piling cuttings) S1.4 Noise (pile driving hammer)
Use of non-harmful, water based drilling fluids Consider quieter method for installing piles (e.g. boring, vibropiling)
ESHIA Chap.10 Table 10.10
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Construction Construction Once Contractor
PHASE
Ongoing Construction Operations. No Additional Cost *
ESHIA Construction Construction Chap.10 Contractor Table 10.10 DUSUP
Once
S1.4 Noise (pile driving hammer) S1.4 Noise (pile driving hammer)
Soft start to pile driving ESHIA Construction Construction Contractor operations Chap.10 Table 10.10 Marine mammal/turtle ESHIA Construction Construction observers present Chap.10 Contractor/ while piling operations Table 10.10 DUSUP occur to monitor soft start and advise if animals stray into the construction area MMO
Weekly
Ongoing Construction Operations. No Additional Cost 2,698,080 AED (2 MMOs on 12-hour shifts, 365 days)
Daily
Page 11-24
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) DUSUP Once
S1.5 Socioeconomic and health
DUSUP to specify labour standards and conditions during contractor selection process - ensure that camps meet ILO/DM standards
ESHIA Planning Chap.10 Table 10.10
Cost dependant on works required to bring camps up to standard.
DUSUP to audit labour ESHIA Construction DUSUP standards among Chap.10 subcontractors and Table 10.10 construction workers, particularly conditions in workers camps.
Monthly
7392 AED (per monthly audit)
Page 11-25
ISSUE
COMMITMENT
SOURCE
PHASE
Contractor to be hired ESHIA Planning to be screened for best Chap.10 practice including Table 10.10 evidence that they promote good living conditions, pay regularly, provide proper accommodation and medical insurance and maintain internationally recognized standards
Ongoing Planning Operations. No Additional Cost
The provision of ESHIA Construction DUSUP recreational facilities in Chap.10 constructors labour Table 10.10 camps to DM standards to be monitored Shade and potable water to be provided during breaks ESHIA Construction Construction Chap.10 Contractor Table 10.10
Monthly
No additional costs.
S1.5 Socioeconomic and health S1.5 Socioeconomic and health
Weekly
Working schedules will ESHIA Construction Construction be adjusted during Chap.10 Contractor hottest months to Table 10.10 reduce heat exposure.
Maximum temperature for working will be agreed and work will be stopped when maximum
Page 11-26
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) temperature reached
Maintain records for conducting periodic medical examination for workers to ensure that they are not affected by occupational illness Maintain records for work injuries and accidents or occupational diseases when reported Ensure workers are provided with adequate welfare facilities as detailed in DMs Code of Construction Safety Practice Construction works to be carried out in accordance with relevant standards including DP World PCFC Health, Safety
Daily
Daily
Monthly
Weekly
Page 11-27
ISSUE
COMMITMENT
SOURCE
PHASE
and Fire Regulations and Standards S1.5 Socioeconomic and health Safety belts to be mandatory for all construction workers transport ESHIA Construction Construction Chap.10 Contractor Table 10.10 Weekly No additional costs.
Commercial drivers to ESHIA Construction Construction have first aid and Chap.10 Contractor defensive driving Table 10.10 training Vehicle conditions checked daily Maintenance records to be audited by DUSUP ESHIA Construction Construction Chap.10 Contractor Table 10.10 ESHIA Construction DUSUP =Chap.10 Table 10.10
Commercial Drivers
Monthly
S1.5 Socioeconomic and health S1.5 Socioeconomic and health S1.5 Socioeconomic and health
Monthly
No additional costs. 7392 AED (per monthly audit)
Monthly
Contractor to optimize ESHIA Construction Construction local employment and Chap.10 Contractor deliver training as Table 10.10 required
Monthly
Page 11-28
ISSUE
COMMITMENT
SOURCE
PHASE
A2a Export Pipeline Installation (tow out) S2.1a Seabed Pipeline route to ESHIA Planning Chap.10 disturbance follow close to the (excavation of corridor of existing Table 10.10 pipeline trench) pipelines, rather than running a new course across previously less disturbed seabed
Part of Construction Scheduling and Planning. No additional cost.
S2.1a Seabed disturbance (excavation of pipeline trench)
ESHIA Consider shallow Planning trench excavation, Chap.10 Table 10.10 that allows the pipeline to partially self bury into the soft surface sediments, thus reducing the amount of displaced seabed sediments and overall area of impact
DUSUP
Once
Page 11-29
ISSUE
COMMITMENT
SOURCE
PHASE
S2.2a Emissions (welding sets, excavator, lay barge and winch, vehicle engines)
Construction contractor to prepare a Pollution Prevention and Control Plan to address the prevention and control of pollution including exhaust emissions
18480 AED
S2.2a Emissions Contractor to (welding sets, maintain engines excavator, lay barge and winch, vehicle engines) S2.2a Emissions (welding sets, excavator, lay barge and winch, vehicle engines)
Monthly
Ongoing Construction Operations. No Additional Cost Ongoing Construction Operations. No Additional Cost
Construction ESHIA Construction Construction Contractor to inspect Chap.10 Contractor condition equipment Table 10.10 before start of work
As Required
S2.2a Emissions DUSUP to audit (welding sets, maintenance excavator, lay records barge and winch, vehicle engines)
ESHIA Construction DUSUP Chap.10 Table 10.10
Monthly
Page 11-30
ISSUE
COMMITMENT
SOURCE
PHASE
S2.3a Discharge Water to be used as ESHIA Construction Construction (hydrotest water) hydrotest fluid with Chap.10 Contractor pH regulated with Table 10.10 NaOH or bicarbonate S2.3a Discharge Contractor to avoid (hydrotest water) use of dye in hydrotest water S2.3a Discharge Hydrotest water to (hydrotest water) be dewatered from the jetty to the DUGAS control station, with collection and disposing of the hydrotest water onshore ESHIA Construction Construction Chap.10 Contractor Table 10.10 ESHIA Construction Construction Chap.10 Contractor Table 10.10
Ongoing Construction Operations. No Additional Cost Ongoing Construction Operations. No Additional Cost *
Once
Once
S2.3a Discharge Discharges to water ESHIA Construction Construction (hydrotest water) to be approved by Chap.10 Contractor DM/PCFC Table 10.10
Once
Page 11-31
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) DUSUP Once *
S2.4a Disturbance (traffic, emergency access road)
Planning DUSUP to explore ESHIA options in Chap.10 consultation with Table 10.10 DUGAS and DUBAL that ensure access to sites remains open, including a) pipeline construction in short sections, b) building bridges over the pipeline, c) welding in a different location and floating/towing the pipeline into position, d) directional drilling with pipeline welding from offshore barge and pull-to-shore through carrier pipe
Traffic Management ESHIA S2.4a Construction Construction Disturbance (traffic, Plan to specify Chap.10 Contractor emergency access transport routes Table 10.10 road) S2.4a DUSUP to audit plan ESHIA Construction DUSUP Disturbance (traffic, to ensure Chap.10 emergency access compliance Table 10.10 road)
Once
25872 AED
Daily
Ongoing Construction Operations. No Additional Cost
Page 11-32
ISSUE
COMMITMENT
SOURCE
PHASE
S2.5a Socio Economic
DUSUP to specify ESHIA Construction DUSUP Chap.10 labour standards and conditions Table 10.10 during contractor selection process ensure camps meet ILO/DM standards
DUSUP to audit ESHIA Construction DUSUP labour standards Chap.10 among Table 10.10 subcontractors and construction workers, particularly conditions in workers camps
Monthly
Page 11-33
ISSUE
COMMITMENT
SOURCE
PHASE
Contractor to be hired to be screened for best practice including evidence that they promote good living conditions, pay regularly, provide proper accommodation and medical insurance and maintain internationally recognized standards The provision of recreational facilities in constructors labour camps to DM standards to be monitored Contractor to optimize local employment and deliver training as required
ESHIA Planning Chap.10 Table 10.10
ESHIA Construction DUSUP Chap.10 Table 10.10
Monthly
Monthly
Page 11-34
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Maximum temperature for working will be agreed and work will be stopped when maximum temperature reached Daily
Working schedules will ESHIA Construction Construction be adjusted during Chap.10 Contractor hottest months to Table 10.10 reduce heat exposure.
Maintain records for conducting periodic medical examination for workers to ensure that they are not affected by occupational illness Maintain records for work injuries and accidents or occupational diseases when reported Ensure workers are provided with adequate welfare facilities as detailed in DMs Code of Construction Safety Practice Construction works to be carried out in
Daily
Monthly
S1.5 Socioeconomic and
ESHIA Chap.10 -
Construction Construction Contractor
Weekly
Page 11-35
ISSUE
COMMITMENT
SOURCE
PHASE
health
accordance with relevant standards including DP World PCFC Health, Safety and Fire Regulations and Standards S2.6a Health Use of divers to be (divers / working minimized wherever over water) possible
Table 10.10
Once
Part of Construction Scheduling and Planning. No additional cost. 7392 AED (per monthly audit)
S2.6a Health Commercial diving (divers / working activity to be over water) undertaken in accordance Shell standards
ESHIA Construction Construction Chap.10 Contractor / Table 10.10 DUSUP
Monthly
S2.6a Health Working over water to ESHIA Construction Construction (divers / working be undertaken in Chap.10 Contractor / over water) accordance Shell Table 10.10 DUSUP standards A2b - Export Pipeline Installation (HDD & pull-in) S2.1b Land Take Footprint of the ESHIA Planning drilling rig to be Chap.10 minimized as far as Table 10.10 possible consistent with capability to bore required hole
Monthly
Construction Contractor
Once
Part of Construction Scheduling and Planning. No additional cost.
Page 11-36
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Once *
S2.1b Land Take Both the rig and winch sites to be restored following the completion of HDD work S2.2b Emissions (drilling rig, welding sets, lay barge and winch engines) Construction contractor to prepare a Pollution Prevention and Control Plan to address the prevention and control of pollution including exhaust emissions
Once
18480 AED
S2.2b Emissions Contractor to (drilling rig, welding maintain engines sets, lay barge and winch engines) S2.2b Emissions (drilling rig, welding sets, lay barge and winch engines)
Monthly
Ongoing Construction Operations. No Additional Cost Ongoing Construction Operations. No Additional Cost
ESHIA Construction Construction Construction Contractor to inspect Chap.10 Contractor condition equipment Table 10.10 before start of work
As Required
Page 11-37
ISSUE
COMMITMENT
SOURCE
S2.2b Emissions DUSUP to audit (drilling rig, welding maintenance sets, lay barge and records winch engines)
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Construction DUSUP Monthly
PHASE
S2.3b Discharge Water to be used as ESHIA Construction Construction (hydrotest water, hydrotest fluid with Chap.10 Contractor drilling fluid) pH regulated with Table 10.10 NaOH or bicarbonate
Once
S2.3b Discharge Contractor to avoid (hydrotest water, use of dye in drilling fluid) hydrotest water
Once
Ongoing Construction Operations. No Additional Cost *
S2.3b Discharge Hydrotest water to ESHIA Construction Construction (hydrotest water, be dewatering from Chap.10 Contractor Table 10.10 drilling fluid) the jetty to the DUGAS control station, with collection and disposing of the hydrotest water onshore S2.3b Discharge A simple waterESHIA Construction Construction (hydrotest water, Contractor based drilling fluid to Chap.10 drilling fluid) be used Table 10.10
Once
Once
Page 11-38
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Once *
S2.3b Discharge Only additives that (hydrotest water, are considered as drilling fluid) being environmentally acceptable to be allowed
S2.3b Discharge Method statement ESHIA Construction Construction Chap.10 (hydrotest water, for the control of Contractor / drilling fluid) drilling muds to be Table 10.10 DUSUP agreed with DM and PCFC prior to construction
Once
S2.4b Waste (drilling cuttings)
HDD cuttings with ESHIA Construction Construction simple water-based Chap.10 Contractor drilling fluid Table 10.10 disposed as inert waste DUSUP to specify ESHIA Construction DUSUP labour standards Chap.10 and conditions Table 10.10 during contractor selection process ensure camps meet ILO/DM standards
Monthly
Once
Page 11-39
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Monthly
ESHIA DUSUP to audit Construction DUSUP Chap.10 labour standards among Table 10.10 subcontractors and construction workers, particularly conditions in workers camps ESHIA Contractor to be Planning hired to be screened Chap.10 for best practice Table 10.10 including evidence that they promote good living conditions, pay regularly, provide proper accommodation and medical insurance and maintain internationally recognized standards DUSUP
Once
The provision of ESHIA Construction DUSUP recreational facilities Chap.10 in constructors Table 10.10 labour camps to DM standards to be monitored
Monthly
Page 11-40
ISSUE
COMMITMENT
SOURCE
Contractor to optimize local employment and deliver training as required
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Construction Construction Monthly Contractor
PHASE
A3 Deploy and Commission FSRU S3.2 Emissions Operations (engines) contractor to prepare a Pollution Prevention and Control Plan to address the prevention and control of pollution including exhaust emissions S3.2 Emissions (engines) S3.2 Emissions (engines) Contractor to maintain engines
ESHIA Operation Chap.10 Table 10.10
Operations Contractor
Once
18480 AED
Monthly
Ongoing Operations. No Additional Cost Ongoing Operations. No Additional Cost 7392 AED (per monthly audit)
Construction ESHIA Construction Construction Contractor to inspect Chap.10 Contractor condition equipment Table 10.10 before start of work DUSUP to audit maintenance records ESHIA Construction DUSUP Chap.10 Table 10.10
As Required
S3.2 Emissions (engines)
Monthly
Page 11-41
ISSUE
COMMITMENT
SOURCE
PHASE
S3.2 Discharge Low rate not cold ESHIA Operation (water from open water stream during Chap.10 Table 10.10 loop regasification commissioning process, boiler blowdown) S3.3 Socio Economic (vessel movements, landscape and visual) S3.3 Socio Economic (vessel movements, landscape and visual) Contractor to optimize local employment and deliver training as required ESHIA Operation Chap.10 Table 10.10
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Weekly Contractor
Ongoing Operations. No Additional Cost
Once
Crew based onESHIA Planning board ship full time, Chap.10 living standards to Table 10.10 be specified by DUSUP in line with SIGTTO and audited quarterly
DUSUP
Quarterly
22176 AED
S3.3 Socio Economic (vessel movements, landscape and visual)
Harbour Master to ESHIA Operation Chap.10 control vessel Table 10.10 movements and implement necessary spacing between LNG carriers (including the FSRU) and other traffic when entering port
Monthly
Page 11-42
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Contractor Monthly
A4 Deliver LNG and Operate FSRU S4.1 Emissions Emissions ESHIA Operation Monitoring of FSRU Chap.10 to be undertaken for Table 10.10 one year to verify emissions model S4.2 Discharges (warm regasification process water, boiler blow down water, ballast water, de-oiled bilge, boiler blowdown, grey water and treated water from STU) S4.2 Discharges (warm regasification process water, boiler blow down water, ballast water, de-oiled bilge, boiler blowdown, grey water and treated water from STU) Water discharged to ESHIA Operation Port to be in Chap.10 accordance with Table 10.10 IFC, PCFC and DM requirements
266,112 AED
Daily
Monitoring points to ESHIA Operation be installed for all Chap.10 discharge points and Table 10.10 daily recorded kept
Daily
Page 11-43
ISSUE
COMMITMENT
SOURCE
PHASE
S4.2 Discharges (warm regasification process water, boiler blow down water, ballast water, de-oiled bilge, boiler blowdown, grey water and treated water from STU) S4.2 Discharges (warm regasification process water, boiler blow down water, ballast water, de-oiled bilge, boiler blowdown, grey water and treated water from STU)
Discharges subject ESHIA Operation to compliance with Chap.10 PCFC/DM standard Table 10.10 for discharge to harbour
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Monthly Contractor
Bilge water to be ESHIA Operation transferred to Chap.10 barges for transport Table 10.10 to appropriate onshore disposal facilities.
Monthly
Page 11-44
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Contractor Monthly *
S4.2 Discharges (warm regasification process water, boiler blow down water, ballast water, de-oiled bilge, boiler blowdown, grey water and treated water from STU) S4.2 Discharges (warm regasification process water, boiler blow down water, ballast water, de-oiled bilge, boiler blowdown, grey water and treated water from STU) S4.3 Discharges (cold water from regasification process)
FSRU will be equipped with an STU. If necessary, the treated water may be contained and transported for onshore disposal
Grey water may ESHIA Operation require treatment by Chap.10 a separator before Table 10.10 discharge to meet PCFC/DM consent conditions
Monthly
Discharged water to ESHIA Operation meet WBG Chap.10 Table 10.10 guidelines for a temperature decrease from ambient, of no more than 3 degrees 100m from the discharge point
Daily
Page 11-45
ISSUE
COMMITMENT
SOURCE
PHASE
S4.3 Discharges (cold water from regasification process) S4.3 Discharges (cold water from regasification process) S4.3 Discharges (cold water from regasification process)
Daily monitoring of water discharge temperature to be undertaken
Monitoring in ESHIA Operation harbour to be Chap.10 undertaken to verify Table 10.10 dispersion model Monitoring of ESHIA Operation baseline water Chap.10 Table 10.10 quality to be undertaken in accordance with DMs Administration Order 211 (1991) (Article 9) under Local Order 61 (1991) Segregate plastic ESHIA Operation from domestic waste Chap.10 Table 10.10 Food waste will be ESHIA Operation collected weekly and Chap.10 disposed of onshore Table 10.10
Monthly
266,112 AED
266,112 AED
S4.4 NonHazardous Waste (Domestic) S4.4 NonHazardous Waste (Domestic)
Operations Contractor Operations Contractor
Monthly
Ongoing Operations. No Additional Cost Ongoing Operations. No Additional Cost
Monthly
Page 11-46
ISSUE
COMMITMENT
SOURCE
PHASE
S4.4 NonHazardous Waste (Domestic)
General solid waste ESHIA Operation will be collected and Chap.10 disposed of onshore Table 10.10
S4.5 Noise (boilers, turbines, pumps, compressors)
Noisy equipment is ESHIA Planning expected to be Chap.10 below decks, so that Table 10.10 the FSRU will comply with noise standard Contractor to optimize local employment and deliver training as required ESHIA Operation Chap.10 Table 10.10
Operations Contractor/ DUSUP
Once
S4.6 Socio Economic (vessel movements, landscape and visual) S4.6 Socio Economic (vessel movements, landscape and visual)
Once
Crew based onESHIA Planning board ship full time, Chap.10 living standards to Table 10.10 be specified by DUSUP in line with SIGTTO and audited quarterly
DUSUP
Quarterly
22176 AED
Page 11-47
ISSUE
COMMITMENT
SOURCE
PHASE
S4.6 Socio Economic (vessel movements, landscape and visual)
Harbour Master to ESHIA Operation control vessel Chap.10 movements and Table 10.10 implement necessary spacing between LNG carriers (including the FSRU) and other traffic when entering port
A5 Maintenance ESHIA S5.1 Waste Segregate scrap Operation (scrap metal, oily metal and recyclable Chap.10 materials for Table 10.10 rags, paint) disposal onshore
Monthly
S5.1 Waste (scrap metal, oily rags, paint)
Collect oily waste for ESHIA Operation disposal onshore in Chap.10 accordance with DM Table 10.10 waste regulations Consider reuse, ESHIA Operation recycle, reduce of all Chap.10 waste streams Table 10.10
Monthly
S5.1 Waste (scrap metal, oily rags, paint)
Monthly
Accidental Scenarios
Page 11-48
ISSUE
COMMITMENT
C1. Failure to contain domestic waste C1. Failure to contain domestic waste C1. Failure to contain domestic waste C1. Failure to contain domestic waste C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel
Covered waste containers
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) ESHIA Construction Construction Monthly Chap. 12 - and Contractor/ Table 12.3 Operation Operations Contractor Monthly
SOURCE
PHASE
Ongoing Operations. No Additional Cost Ongoing Operations. No Additional Cost Ongoing Operations. No Additional Cost 7392 AED (per monthly audit)
Label containers for ESHIA Construction Construction segregated waste Chap. 12 - and Contractor/ Table 12.3 Operation Operations Contractor Routine litter collection activities ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation /Operations Contractor ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation /Operations Contractor ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation
Monthly
Audit waste management system Vehicles to be equipped with fire extinguishers
Monthly
Monthly
Maximize recycling ESHIA Construction Construction of vehicle parts and Chap. 12 - and Contractor scrap metal Table 12.3 Operation
Monthly
Page 11-49
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Commercial Drivers Monthly *
C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel
First aid and ESHIA Construction Construction defensive training Chap. 12 - and Contractor for company drivers Table 12.3 Operation /Operations Contractor Implement and enforce Shell Drugs and Alcohol Policy ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation /Operations Contractor
Monthly
Require contractors ESHIA Construction Construction and employees to Chap. 12 - and Contractor observe PCFC and Table 12.3 Operation /Operations UAE speed limits Contractor DUSUP and contractors to log accidents and near misses Vehicles to be inspected weekly ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation /Operations Contractor and DUSUP ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation
Monthly
Monthly
Weekly
Mandatory use of seat belts for all drivers and passengers
ESHIA Construction Construction Chap. 12 - and Contractor Table 12.3 Operation /Operations Contractor
Weekly
Page 11-50
ISSUE
C2. Road traffic accident during transport of materials or personnel C2. Road traffic accident during transport of materials or personnel
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Contractors to ESHIA Construction Construction Once provide medical Chap. 12 - and Contractor insurance cover for Table 12.3 Operation /Operations all construction Contractor workers ESHIA Construction Construction A medical Contractor emergency plan will Chap. 12 - and /Operations be provided by the Table 12.3 Operation Contractor contractors for construction workers including use of private local hospitals. Posttreatment management and rehabilitation requirements will also be made explicit FSRU and Jetty designed for 100year return worst wave ESHIA Planning Chap. 12 Table 12.3 DUSUP Once
COMMITMENT
SOURCE
PHASE
C3. Extreme weather, wave height exceeds FSRU design specification. C3. Extreme weather, wave height exceeds FSRU design specification.
Once
FSRU operations ESHIA Planning can be shut down in Chap. 12 extreme weather Table 12.3
Once
Page 11-51
ISSUE
COMMITMENT
SOURCE
PHASE
C3. Extreme weather, wave height exceeds FSRU design specification.
FSRU equipped with ESHIA Planning facilities to Chap. 12 accommodate and Table 12.3 cater for staff if weather too rough for launches to approach FSRU equipped with ESHIA Planning sick bay and first aid Chap. 12 equipment Table 12.3
C3. Extreme weather, wave height exceeds FSRU design specification.
Once
C4. LNG Carrier PCFC will monitor looses power vessel movements turning in the port in the port and collides with FSRU or third party at low speed (LNG tanks not ruptured).
ESHIA Operation Chap. 12 Table 12.3
C4. LNG Carrier Advance notification ESHIA Operation looses power of LNG carriers Chap. 12 turning in the port arrival in port Table 12.3 and collides with FSRU or third party at low speed (LNG tanks not ruptured).
Monthly
Page 11-52
ISSUE
COMMITMENT
SOURCE
PHASE
C4. LNG Carrier looses power turning in the port and collides with FSRU or third party at low speed (LNG tanks not ruptured). C4. LNG Carrier looses power turning in the port and collides with FSRU or third party at low speed (LNG tanks not ruptured). C4. LNG Carrier looses power turning in the port and collides with FSRU or third party at low speed (LNG tanks not ruptured). C4. LNG Carrier looses power turning in the port and collides with FSRU or third party at low speed (LNG tanks not ruptured).
LNG carriers entering port to be accompanied by tugs to prevent collisions
FSRU located away ESHIA Planning from routes to port Chap. 12 berths alongside a Table 12.3 breakwater so that high angle or highspeed impact with FSRU is unlikely LNG carrier double ESHIA Operation hulled so LNG tanks Chap. 12 will not rupture in Table 12.3 low speed low angle collision
DUSUP
Once
DUSUP
Once
LNG carrier and FSRU to be equipped with first aid equipment and trained first aiders
Monthly
Page 11-53
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Contractor Once *
C5. Small deck spill FSRU equipped with ESHIA Planning of LNG during protective hull water Chap. 12 Table 12.3 transfer to storage spray systems for leak prone areas and aluminium or stainless steel spill pans to prevent hull plating fracture C5. Small deck spill FSRU will have ESHIA Operation of LNG during written procedures Chap. 12 transfer to storage for use of loading Table 12.3 arms and control of LNG transfer
Monthly
C5. Small deck spill FSRU will have of LNG during written procedures transfer to storage for routine inspection of transfer equipment C5. Small deck spill FSRU will have of LNG during programmed transfer to storage maintenance of FSRUs loading arms
Monthly
Monthly
Page 11-54
ISSUE
COMMITMENT
SOURCE
PHASE
C5. Small deck spill FSRU control room, ESHIA Operation of LNG during LNG carrier and Chap. 12 transfer to storage deck operatives will Table 12.3 be equipped with gas safe communications equipment C5. Small deck spill FSRU is subject to of LNG during Classification transfer to storage regulations and inspections ESHIA Operation Chap. 12 Table 12.3
Monthly
C6. Failure of LNG FSRU will have solid ESHIA Planning storage tank state LNG insulation Chap. 12 insulation Table 12.3 C6. Failure of LNG FSRU will have ESHIA Operation storage tank programmed Chap. 12 Table 12.3 insulation inspection and maintenance of LNG storage tanks and insulation including adherence to Classification regulations
Once
Once
Page 11-55
ISSUE
COMMITMENT
SOURCE
PHASE
C6. Failure of LNG FSRU will have ESHIA Planning storage tank vents capable of Chap. 12 insulation releasing Table 12.3 /depressurizing the LNG storage tanks if LNG boil-off is above boiler and compressor capacity
C7. Power failure on FSRU
FSRU will have automatic emergency safe shut down procedures for regasification process and LNG transfers FSRU will have separate venting systems for the LNG storage and for the HP regasification equipment
ESHIA Planning Chap. 12 Table 12.3
Once
ESHIA Planning Chap. 12 Table 12.3
Once
Page 11-56
ISSUE
COMMITMENT
SOURCE
PHASE
ESHIA FSRU will have Planning Chap. 12 diesel emergency generators Table 12.3 supplying power to essential users, such that power will be quickly restored
C7. Power failure on FSRU C7. Power failure on FSRU
LNG storage does not rely on power Primary power for jetty will be from FSRU. Backup power to be provided by FSRU or temporary generator on jetty
ESHIA Planning Chap. 12 Table 12.3 ESHIA Planning Chap. 12 Table 12.3
Once
Once
C8. Boiler Feed Water system failure on FSRU
Phased close down ESHIA Planning procedures closes Chap. 12 system and stops Table 12.3 regas process
Once
Page 11-57
ISSUE
COMMITMENT
SOURCE
PHASE
C8. Boiler Feed Water system failure on FSRU
ESHIA Planning FSRU will have Chap. 12 automatic emergency safe Table 12.3 shut down procedures for regasification process and LNG transfers opening high pressure safety valves and boil-off safety valves to the vent system Marked vessel ESHIA Planning exclusion zone Chap. 12 around offshore Table 12.3 pipeline route, so no shipping will cross the pipeline
C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure
DUSUP
Once
Concrete coating ESHIA Construction Construction designed to protect Chap. 12 Contractor pipeline against Table 12.3 probable worst-case impact
Once
Page 11-58
ISSUE
COMMITMENT
SOURCE
PHASE
C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure
DUSUP will consider ESHIA Planning additional protection Chap. 12 (mattresses/rock Table 12.3 dump) during detailed project design work
FSRU control room ESHIA Operation will monitor pressure Chap. 12 in export line Table 12.3
Daily
Emergency shut ESHIA Operation down system for Chap. 12 Table 12.3 export pipeline closes block valves at either end of pipeline (8km length) if rupture/sudden pressure loss detected
DUSUP
Once
Page 11-59
ISSUE
COMMITMENT
SOURCE
PHASE
C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure C9. Item dropped on pipeline damages concrete coating, leading to corrosion and eventual pipeline failure
DUSUP visual inspection of onshore pipeline condition (monthly)
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) DUSUP Monthly
DUSUP annual inspection of pipeline condition.
DUSUP
Annually
22176 AED
Pipeline pressure ESHIA Operation will be reduced to a Chap. 12 minimum agreed Table 12.3 with DUSUP when the FSRU is not in operation ESHIA Operation Chap. 12 Table 12.3
DUSUP
Annually
C9. Item dropped Intelligent pipeline on pipeline pigging annually damages concrete coating, leading to corrosion and eventual pipeline failure
DUSUP
Annually
Page 11-60
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Contractor Monthly
C10. Gas loading Programmed ESHIA Operation arm rupture and fire inspection and Chap. 12 on jetty maintenance of the Table 12.3 gas loading arm C10. Gas loading Procedures to ESHIA Operation arm rupture and fire ensure loading arm Chap. 12 on jetty uncoupled before Table 12.3 moving off C10. Gas loading Routine use of gas arm rupture and fire leak detection on jetty equipment ESHIA Operation Chap. 12 Table 12.3
Monthly
Monthly
C10. Gas loading Jetty/FSRU will have ESHIA Operation arm rupture and fire automatic Chap. 12 emergency safe Table 12.3 on jetty shut down procedures ESHIA Operation C10. Gas loading Export pipeline arm rupture and fire pressures monitored Chap. 12 on jetty continuously. Export Table 12.3 pipeline shuts down automatically in emergency
Monthly
Continuously
Page 11-61
ISSUE
COMMITMENT
SOURCE
PHASE
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) DUSUP Monthly *
C10. Gas loading Jetty will have ESHIA Planning arm rupture and fire several gas loading Chap. 12 on jetty arms Table 12.3 C10. Gas loading FSRU will have fire- ESHIA Planning arm rupture and fire fighting equipment; Chap. 12 Table 12.3 on jetty jetty will have facilities to isolate and blowdown export infrastructure C10. Gas loading Fire response arm rupture and fire training for FSRU on jetty and Jetty crews ESHIA Operation Chap. 12 Table 12.3
Monthly
FSRU Crew
Monthly
ESHIA Operation C10. Gas loading DUSUP will have arm rupture and fire written procedure Chap. 12 on jetty with crisis Table 12.3 management plans
DUSUP
Once
C10. Gas loading FSRU will have sick ESHIA Planning arm rupture and fire bay/first aid post Chap. 12 on jetty Table 12.3 C10. Gas loading DUSUP/FSRU arm rupture and fire operator will run on jetty safety exercises simulating fire and explosion ESHIA Operation Chap. 12 Table 12.3
Operations Contractor Operations Contractor / DUSUP
Monthly
*l
Quarterly
Page 11-62
ISSUE
COMMITMENT
SOURCE
PHASE
C10. Gas loading Scrap metal will be arm rupture and fire segregated for on jetty recycling C11. Heavy cargo vessel loses steering causing high angle collision with LNG carrier turning from the port approach channel, and rupturing one of its LNG storage tank. Natural gas cloud ignites C11. Heavy cargo vessel loses steering causing high angle collision with LNG carrier turning from the port approach channel, and rupturing one of its LNG storage tank. Natural gas cloud ignites PCFC will monitor vessel movements in the port
ESHIA Operation Chap. 12 Table 12.3 ESHIA Operation Chap. 12 Table 12.3
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Monthly Contractor Operations Contractor
Ongoing Operations. No Additional Cost No additional costs.
Advance notification ESHIA Operation of LNG carriers Chap. 12 arrival in port Table 12.3
Monthly
Page 11-63
ISSUE
COMMITMENT
SOURCE
PHASE
C11. Heavy cargo vessel loses steering causing high angle collision with LNG carrier turning from the port approach channel, and rupturing one of its LNG storage tank. Natural gas cloud ignites C11. Heavy cargo vessel loses steering causing high angle collision with LNG carrier turning from the port approach channel, and rupturing one of its LNG storage tank. Natural gas cloud ignites
LNG carriers entering port to be accompanied by tugs to prevent collisions
ESHIA ESHIA Chap. 12 Table 12.3
During LNG fire, vessel will stay moored, as berth provides adequate safety zone
Monthly
Page 11-64
ISSUE
COMMITMENT
SOURCE
PHASE
Location of FSRU in ESHIA Planning a remote location Chap. 12 away form main port Table 12.3 entrance
No vessel traffic ESHIA Operation allowed in port entry Chap. 12 channel when an Table 12.3 LNG carrier enters the port
Monthly
Page 11-65
ISSUE
COMMITMENT
SOURCE
PHASE
Provision and ESHIA Operation maintenance of Chap. 12 FSRU with suitable Table 12.3 fire resistant covered rapid launch escape boats
Operation ESHIA Operation contractors will be Chap. 12 required to establish Table 12.3 appropriate medical emergency response systems in line with Shell Medical Emergency Response Plan (MER)
Once
Page 11-66
ISSUE
COMMITMENT
SOURCE
PHASE
ESHIA An emergency Operation evacuation plan will Chap. 12 be put into place Table 12.3 taking into consideration the closest available hospitals and the congested roads of Dubai
IMPLEMENTATION STATUS RESPONSIBILITY TRAINING MONITORING Complete (C); OnTarget audience &/or going (O); action (crew) INSPECTION LEVEL (A1, A2 or FREQUENCY A3) Operations Once Contractor
The emergency response plans will be exercised annually
Annually
Page 11-67
ISSUE
COMMITMENT
SOURCE
PHASE
C12. Terrorist attack on FSRU with LNG carrier moored alongside
DUSUP to develop ESHIA Operation Emergency Chap. 12 Response Plans and Table 12.3 Medical Response Plans in conjunction with PCFC and DM
C12. Terrorist attack on FSRU with LNG carrier C12. Terrorist attack on FSRU with LNG carrier
Security procedures ESHIA Operation to be implemented Chap. 12 for visitors Table 12.3 Crew to be security ESHIA Operation screened Chap. 12 Table 12.3
Operation Contractor
Monthly
Operation Contractor
Monthly
Note: * cost to be determined during completion of relevant BDPs
Page 11-68

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Dubai LNG Regasification Project Draft ESHIA Report

11 Environmental Social and Health Management Plan (ESHMP) Overview

An overview of the project ESHMP is provided in Figure 11.1.

P180005 November 2007 Rev 03

Dubai LNG Regasification Project Draft ESHIA Report

Figure 11.1: Dubai LNG Regasification Project ESHMP Structure

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Dubai LNG Regasification Project Draft ESHIA Report

11.1.1 Project Outline

11.1.2 Commitments and Action Tracking Registers

11.1.3 Management Approach

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Dubai LNG Regasification Project Draft ESHIA Report

Monitoring efficacy of controls; and Auditing of performance.

11.1.4 Corporate HSE Policy

11.1.5 Project Organization, Roles and Responsibilities

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Dubai LNG Regasification Project Draft ESHIA Report

Toolbox Talks ESMP Pocket Guide Audits/Monitoring Monthly audits

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Dubai LNG Regasification Project Draft ESHIA Report

Daily observations Reports Daily Observations Diary

Record Maintain jointly with Shell

Implement Prepare, implement and audit

P180005 November 2007 Rev 03

Dubai LNG Regasification Project Draft ESHIA Report

Figure 11.2: Project Environmental, Social and Health Organogram

11.1.6 Code of Conduct

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Dubai LNG Regasification Project Draft ESHIA Report

11.1.7 Record Keeping

11.1.8 Impacts and Mitigation Measures

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Dubai LNG Regasification Project Draft ESHIA Report

11.2.1 Senior Management Briefings

11.2.3 Toolbox Talks

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Dubai LNG Regasification Project Draft ESHIA Report

11.2.4 ESHMP Pocket Guide

11.3 Audits, Inspections and Observations

11.3.1 Monthly Audits

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Dubai LNG Regasification Project Draft ESHIA Report

11.3.2 Weekly Inspections

11.3.3 Daily Observations

11.4.1 Incident & Near-Miss Reports

11.4.2 Audits, Inspections and Observations

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Dubai LNG Regasification Project Draft ESHIA Report

11.4.3 Monthly Environmental & Social Report

11.5 Plans and Procedures

11.5.1 Community Liaison

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Dubai LNG Regasification Project Draft ESHIA Report

11.5.2 Contaminated Land

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Dubai LNG Regasification Project Draft ESHIA Report

11.5.4 Employment, Training and Procurement

11.5.5 Pollution Prevention and Control

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Dubai LNG Regasification Project Draft ESHIA Report

The hydrotest crew will: