Emp For Construction Phase

DESCRIPTION OF THE PROJECT

Environmental Regulations, Codes and Standards Extensive Regulations, Codes and Standards address environmental and construction matters and these are referred to as applicable in this document. Notwithstanding this document, compliance with them shall not discharge the contractor from complying with any other legislative requirements applicable at the time of construction. The Control of Pollution Act (COPA), 1974 gives Local Authorities power to control all noise during construction. Section 61 of COPA 1974 outlines the procedure to obtain consent for work on construction sites. If consent has not been obtained, and/or the required noise limits are not being met, the Local Authority may impose requirements according to Section 60. A Section 61 application would be made. BS 5228 Parts 1 and 2, 1997 Noise and Vibration Control on Construction and Open Sites and other relevant EC directives also cover noise emanating from work on building sites. Control of dust, smoke and air pollution is covered by the Clean Air Acts, 1993; Control of Substances Hazardous to Health (COSHH) Regulations 2002; Health and Safety at Work Act 1974, and the Environmental Protection Act 1990. The Health and Safety at Work Act, 1974 and associated Regulations and HSE Guidance Notes cover general safety of construction workers and passers-by. Monitoring of this would be the responsibility of the Planning Supervisor and the local HSE Officer. Section 80 of the Building Act, 1984 requires 6 weeks notice of intended demolition works. The local planning authority may then impose conditions appropriate to the scale of demolition. The Highways Act, 1980 requires Contractors to maintain free passage for pedestrians and vehicles around their work-sites and to obtain permission from the Local Authority’s Highway Authority, before the public highway can be opened up, excavated or built upon. The Act also requires contractors to obtain licences, permission for hoardings, fenced storage areas, scaffolding, gantries or strips in the public highway. The Road Traffic Regulation, Act 1984 contains provisions for the making of Traffic Regulation Orders (TRO), and other matters relating to the control of road traffic. Prior to any discharge of surface water or de-watering effluent to rivers/watercourses, soakaways, or sewers, consent must be obtained from the Environment Agency (EA). Discharge consents are based on the Water Resources Act 1991. The Environmental Protection Act, 1990 establishes the principle of integrated pollution control, reforms the management of waste disposal and updates the law on statutory nuisances likely to cause personal discomfort or be prejudicial to health. The Hazardous Waste (England and Wales) Regulations 2005 apply controls on movements of hazardous waste. The Landfill (England and Wales)(Amendment) Regulations 2004 place responsibility on the landfill operators and producers of waste to ensure the separation of different classifications of waste based upon waste acceptance criteria, prior to disposal to landfill. If specific types of waste such as hazardous waste exceed the criteria then pre-treatment is required prior to disposal. As of April 2008 Site Waste Management Plans (SWMPs) are a legal requirement for all projects over £250,000 in value. Existing guidance is provided in Site Waste Management Plans, Guidance for Construction Contractors and Clients, Voluntary Code of Practice, Department of Trade and Industry, 2004. The Ancient Monuments and Archaeological Act 1979, as amended by the National Heritage Act 1983, includes requirements for investigation of buildings or sites of historic or archaeological interest. A Watching Brief may be required under Planning

Policy Guidance 16 (PPG16): Archaeology and Planning 1990, whereby a professional archaeologist would be present during excavation work. This Act also required Scheduled Ancient Monument Consent for works affecting any Scheduled Monument. The Planning (Listed Buildings and Conservation Areas) Act 1990 imposes a system of control over works that affect Listed Buildings. It is an offence for any person to carry out any works comprising demolition, alteration or extension to a Listed Building without written consent from the Local Planning Authority or the Secretary of State, Babergh District Council (BDC) does not have definitive Code of Construction Practice standards and procedures.

1.0 Management of the EMP The following sections outline how this EMP document is to be managed by construction staff, including the General Contractor and BLPC personnel. This management section contains guidance on Roles and Responsibilities and Documentation. 3.1 Roles and Responsibilities to implement this EMP

Construction staff will ensure that the environmental commitments of this document and the EIA will be met and that work proceeds in compliance with environmental regulations and construction specifications. The following sections outline the roles and responsibilities of construction staff with respect to environmental management: The principal contractor appointed by the applicant authority would have responsibility for: · Implementing the EMP; · Monitoring Sub-Contractor's performance to the EMP; · Developing and implementing mechanisms for dealing with problems; and · Acting as a point of contact for consultation and feedback with legal consultees, the public and other interested parties. The principal contractor would be responsible for establishing management procedures for compliance with: · All relevant legislation; · The environmental controls and mitigation measures contained in the EMP; and · Any environmental or other codes of conduct required by the applicant authority. c) The contractor will ensure that a copy of this EMP is available on-site and the site personal is familiar with its contents. The principal contractor would undertake monthly environmental inspections to audit compliance of the site works with the EMP and will records general inspection of site conditions. Compliance records would also be available for inspection by representatives of the JEC development authority and other government agencies as applicable. In addition, the contractor would submit monthly progress reports to the applicant authority following site inspections to provide continuous feedback on environmental performance at the site. 3.2 Documentation An important part in implementing the environmental practices during construction is ensuring that all relevant and pertinent documents are available to construction staff as well as regulatory agencies. The following measures should be implemented to ensure that all information is properly disseminated:

(a) All relevant project documentation shall be present on site at all times including, specifications, construction drawings, EMP, and all permits and approvals; (b) All practices, and procedures outlined in these documents shall be implemented and adhered to; and (c) The contractor will ensure that any reporting required by regulations or this EMP is conducted in a timely manner. 2.0 Environmental Procedures For Construction The procedures included in this section of the Construction EMP outline the Mitigative Measures and Best Management Practices (BMPs) that will be implemented throughout construction to minimize the potential effects on the environment. The procedures included in this document will be modified/updated to meet the changing needs of the project as it proceeds through the design and construction phases. Environmental management involves compliance with: local planning requirements and environmental regulations; PME guidelines, practices and procedures; and conformity with good management practices and standards of the industry. The environmental aspects of the construction of the development operations of the JEC are as follows: (a) Agricultural Soils; (b) Contaminated Soils; (c) Vegetation Clearing; (d) Erosion and Sediment Control; (e) Beach Construction; (f) Traffic Control; (g) Dust Control; (h) Equipment Maintenance; (i) Noise Control; (j) Petroleum, Oils, and Lubricants (POL) Storage, Handling and Disposal; and (k) Spills of Hydrocarbons and Hazardous Materials. 4.1 Agricultural Soils The conservation and maintenance of both agricultural and forest soils are of primary concern during construction. Construction activities have the potential to have long-term impacts by changing the physical and chemical properties of these soils and affecting productive capability and future land use. The most common impacts are loss of topsoil resulting from construction activity or erosion, mixing of subsoil and topsoil, and compaction. (a) Ensure that topsoil is removed from any agricultural work areas prior to grading or trenching; (b) Ensure that topsoil and subsoil piles are separated; (c) Ensure that topsoil is not used for trench backfill or padding; (d) Ensure that topsoil and subsoil and restored in the proper sequence; (e) All topsoil stripping shall be monitored by construction staff to ensure that topsoil in removed to the correct depth; (f) All stockpiled topsoil material shall be protected from erosion. 4.2 Contaminated Soils Soil excavation is required for the installation of the Plant facilities and its associated oil pipeline. During these activities, it is possible that soil or water suspected of contamination from known or unknown sources, may be encountered. The purpose of these environmental management practices, which includes detailed procedures, is to set out the recommended steps for consistent, safe and environmentally responsible handling of such soil or waters. It will assist construction personnel in: (a) Identifying soil suspected of contamination; (b) Identifying contaminated soil;

(c) Minimizing risk to human health and safety, and to the environment when such soils are encountered; (d) Handling such soil in a manner that is in compliance with the relevant environmental legislation; and (e) Minimizing risk to the construction schedule. The procedures outlined apply to situations either foreseen or unforeseen. Where excavations of soils suspected of contamination are anticipated prior to the project, the SITE ENGINEER should be contacted as early as possible in the planning stages. For the purposes of this EMP and for construction of the Project, some standard definitions for Suspect and Contaminated Soil is as follows: Suspect Soil: A soil suspected of being contaminated, based on either sight, smell, past or present land use, or a combination thereof. Contaminated Soil: A soil containing a substance or material whose concentration exceeds regulated limits, or may: (a) pose a threat to worker health or safety; (b) pose a threat to the environment; or (c) pose a threat to public safety. Contaminated Trench Water: Trench liquids; water and/or free product hydrocarbons, which by association with contaminated soils represent a risk similar to that of contaminated soil. In the event that contaminated areas are identified during construction activities (e.g., grading, trenching) the following general measures will be followed: (a) suspend all work in the immediate area; (b) notify the SITE ENGINEER of the situation; (c) the SITE ENGINEER will advise BLPC; (d) BLPC will conduct a preliminary site assessment to determine whether the soil in question could potentially be contaminated; (e) secure the area to prevent additional disturbance; (f) contact the landowner and the Environmental Protection Department for direction on appropriate mitigation; (g) a mutually acceptable restoration plan will be developed in consultation with the Environmental Protection Department; and (h) specialists will be deployed to the area to direct clean-up and disposal of contaminated materials, if applicable. In areas of foreseen contaminated soil or waters, circumstances and characteristics of the contaminated soil and/or waters will be known. For foreseen areas of contamination, previous reports or investigations will have, in most cases, collected the data necessary for handling and mitigation. In most, if not all cases, the Environmental Protection Department will have been consulted on the foreseen areas and the planned mitigation, if any, for these situations. In all cases of “Foreseen areas of Contamination” contaminated soils will be excavated and returned to the pipeline trench, unless directed otherwise. In the event of discovery of unforeseen suspected or contaminated soil and/or waters, the following detailed procedure will be implemented. The mitigation procedure consists of the following steps: A. Identification; B. Preliminary Assessment; C. Secure Suspect Soil and Excavated Area; and D. External Contacts Each of these steps is described in detail below: A. Identification: Suspect soil can usually be identified by sight and smell observations (dependent upon the contaminant present). Some obvious signs of contamination include, but are not limited to:

(a) Soil discoloration (b) Unusual or different soil texture (c) Unusual odour (d) Vegetation distress (e) Standing water or trench with a hydrocarbon sheen (f) Abandoned industrial waste (storage tanks and/or infrastructure) When either suspect or contaminated soils are encountered during excavation, work in the area will be suspended. The SITE ENGINEER will be informed immediately. B. Preliminary Assessment: BLPC has the responsibility for conducting a preliminary site assessment of the situation. Based on the evidence (sight, smell and land use), BLPC will assess whether the soil in question could potentially be contaminated. Some questions BLPC should answer when assessing the situation are: (a) What is the specific location where the suspect/contaminated soil was encountered? (b) What are the adjacent land uses? (c) Who encountered the suspect/contaminated soil? (d) How was it encountered? Was it dug, oozing, flowing, solid, etc.? (e) How much was excavated or encountered (volume of soil/liquids recorded)? (f) Can it be determined without a third party consultant whether or not the suspect soil is in fact contaminated? (g) Should boreholes or test-pits be installed and the soils sampled and tested? Being able to answer most or all of these questions will assist other internal/external parties (i.e., BLPC), in determining what course of action to take. As a precautionary approach, any suspected materials will be sampled by BLPC for laboratory analysis. Based on the preliminary assessment, and in conjunction with discussion with the work crews, and the Environmental Protection Department, BLPC may decide that continued delay of the work is not warranted, and work should continue. C. Secure Suspect Soil and Excavated Area: In the event that suspect/contaminated soil is encountered, the area will be secured and any unnecessary contact with the soil will be avoided. Work in the vicinity of these soil and/or waters will be moved to another location at the work site wherever possible. Any suspect/contaminated soil that has been excavated will be secured using the available resources. Potential securing methods will include: a) placing the soil on a plasticized tarp; b) covering the soil with a plasticized tarp to isolate if from other materials; c) storing the soil away from any watercourses, watersheds, crops, etc.; and d) placing berms around the tarp to isolate and contain the soil. If an excavation can be safely left open, the area will be secured as is, until further direction can be obtained. If the excavation cannot be safely left open, then it will be backfilled. Work will be suspended if: a) continuing to excavate in a suspect/contaminated site could pose a threat to the health and safety of the worker(s); b) installing pipe in contaminated soil may compromise the integrity of the pipe at a later date; or c) issues of non-compliance with environmental legislation may result from continuing to work in areas of contaminated soils. BLPC will ensure that situations involving suspect/contaminated soil are handled appropriately including the proper removal, treatment, and disposal of any soil and/or waters, if necessary. In most, if not all cases contaminated soils will be excavated and returned to the pipeline trench. In consultation with the Environmental Protection Department it is determined that their presence poses an increased environmental risk to adjacent “clean” properties, than previously occurred,

clean-up and remediation measures may be necessary. These measures will be developed in consultation with regulatory agencies in the event this occurs. D. External Contacts: The factors that determine which external parties should be involved in a suspect/contaminated soils incident include: (a) location (i.e., property owners) (b) nature of contamination (c) source of contamination Property owners will be considered as external contacts, whether they are private or public entities. BLPC will be responsible for determination of what external contacts will be made and when these contacts will be made. 4.3 Vegetation Clearing The removal of any trees, crops or vegetation from the proposed Project site and pipeline right of way will be required to facilitate construction activities. To minimize the potential impacts of vegetation removal the following environmental practices shall be implemented: (a) Larger woody material and agricultural crops shall be considered for salvage and use; (b) All other cleared material shall be disposed of in an appropriate manner that is approved by the SITE ENGINEER; (c) All clearing activities shall be confined to the approved working areas as approved by the SITE ENGINEER; (d) The clearing of large trees shall be minimized where possible. 4.4 Erosion and Sediment Control Erosion and sediment concerns can arise both during the construction phase of the Project and following construction when the site clean-ups have occurred. Suitable mitigative measures are therefore required for temporary site conditions which occur for a relatively short period during the construction phase as well as for the permanent conditions following the completion of the facilities and cleanup of the work sites. The grade or slope of the working areas that will be disturbed during the construction phase will determine the amount and complexity of the mitigative measures that will be required to ensure adequate erosion and sediment control. Generically, erosion and sediment control measures will include the application of structures such as: (a) Runoff Controls - diversion berms, cross trenches, chutes, check dams, interceptor swales; (b) Erosion Control - diversion ditch and dispersion aprons, gravel sheeting, mulch, erosion control blankets; and (c) Sediment Control - sediment fence, straw bale barriers, filter berms, sediment traps, settling ponds. The following points and definitions comprise the basic principles of erosion and sediment control. The CONTRACTOR shall implement these measures where there is a risk of surficial erosion and loss of soil: (a) Areas where soil or subsoil has been exposed shall be stabilized by: grading exposed areas to a slope which minimizes the potential for erosion; applying appropriate erosion and sediment control measures; and seeding, mulching or covering with erosion control matting where deemed appropriate by the on-site Inspector or Engineer. (b) Sediment and erosion control structures shall be installed prior to site disturbance and meet the quality as outlined in the construction or manufacturers specifications. These measures shall only be removed when the disturbed area is stabilized. (c) Sediment and erosion protection measures shall be inspected daily and also during or immediately following heavy rain events. Sediment fences and buffer “zones” shall be maintained in an effective working condition.

4.5 Beach Construction Should the CONTRACTOR choose to move equipment to the site via a barge from the port to the Arawak beach, a small roadway and beachhead will need to be constructed. The CONTRACTOR will implement the following procedures to ensure potential impacts from construction are minimized: (a) The CONTRACTOR will review any relevant conditions of the site approval in advance of the work with the SITE ENGINEER to plan the work needs; (b) Prior to any construction, the SITE ENGINEER will contact the University of West Indies to survey the beach for potential turtle nests and to relocate where possible; . (c) The access road and beachhead will be constructed using large boulders and rock for easy removal after use; (d) Construction of the road and beachhead will be restricted to the footprint of the former roadway used during the construction of the Arawak plant; (e) All barging operations must be completed with the utmost care to prevent spills to the marine environment; (f) Barges will be floated into position at high tide and secured; (g) All trucks and equipment will be restricted to the roadway and there will be no equipment allowed on the beach outside of the road footprint; (h) BLPC will have a representative present at all times during equipment offloading; (i) The CONTRACTOR will stop all work immediately if conditions are observed that may have an adverse environmental effect; and (j) The roadway will be removed and the beach will be restored to its original condition once shipments are complete. 4.6 Dust Control During dry conditions, excessive dust may be generated fro the work sites and access roads. This may have a detrimental impact on the local environment, construction safety or integrity, and may also cause disruption to the normal activities of nearby residences. The CONT RACTOR will implement the following procedures to ensure potential impacts from construction are minimized: (a) the CONTRACTOR will apply dust suppressants such as water, calcium chloride, or tree lignin based dust suppressant on the work sites as required (calcium chloride will not be used on agricultural fields); (b) the CONTRACTOR will ensure rock drills are equipped with dust collectors in good working order; (c) the CONTRACTOR will ensure adequate control of dust at work sites that are in proximity to nearby residences; (d) the SITE ENGINEER and the CONTRACTOR will consult with local road authorities prior to application of dust suppressants on public access roads; and (e) the CONTRACTOR will ensure that in areas of sensitive land use dust generation is monitored and controlled. 4.7 Traffic An important consideration during construction will be the impacts on traffic during the pipeline construction as much of the routing occurs along existing roads and residential streets. Where it will be necessary to modify the existing traffic flows in areas of construction, modifications may include partial lane closures, full lane closures, and road closures with detours. The CONTRACTOR will implement the following procedures to ensure potential impacts from construction are minimized: (a) Provide the Ministry of Public Works Traffic Division with the schedule for pipeline construction and road closures at least one month in advance to minimize conflicts with other road work. This schedule will be updated weekly; (b) Prior to commencing pipeline construction on a section of public road, a description of the road closures and estimated time of closure will be provided to newspapers to ensure the public is aware of the project; (c) The public will be provided with advance information on road closures through weekly announcements in the newspapers and through radio and television; (d) Road closures will be posted with detour signs and the detour routes will be fully sign posted throughout to

ensure traffic follows the correct routing; and (e) Where partial and full lane closures, proper road signs, flag persons and/or temporary traffic lights will be utilized to assist traffic movement. 4.8 Noise Control During construction, excessive noise from construction equipment may become a nuisance to nearby residents. The following procedures will be implemented to ensure potential impacts from construction are minimized: (a) the CONTRACTOR will use noise abatement equipment, in good working order, on all heavy machinery used on the project; and (b) wherever possible, the CONTRACTOR shall minimize noise levels during construction. 4.9 Petroleum, Oils, and Lubricants (POL) Storage, Handling and Disposal By implementing proper handling storage and disposal of POLs during construction, the likelihood of accidental events that result in impacts to the environment are greatly reduced. The following procedures will be implemented to ensure the proper handling, storage and disposal of these materials:(a) Fueling and lubrication of equipment shall occur in designated and approved locations;(b) Regular inspections of hydraulic and fuel systems on machinery shall be done, and leaks shall be repaired immediately upon detection;(c) Washing, servicing and fueling of mobile equipment shall not be allowed within 30 m of a waterway or drainage systems;(d) Waste oils and lubricants shall be retained in a tank or closed container and disposed of in an approved manner;(e) Greasy or oily rags or materials subject to spontaneous combustion shall be deposited and stored in an appropriate receptacle. This material shall be removed from the work site on a regular basis and shall be disposed of in an approved existing waste disposal facility; and (f) All hazardous materials shall be stored with secondary containment and properly signed. 4.10 Fuel and Hazardous Material Spills This Contingency Plan presents a detailed response system to deal with accidents such as the release of petroleum, oils, or lubricants (POLs) or other hazardous liquids. The objectives of the Plan are to minimize: (a) danger to persons; (b) pollution of land and water; (c) extent of affected area; (d) degree of disturbance during clean-up; and (e) degree of disturbance to wildlife. In addition to these Project specific response plans, the “National Oil Spill Contingency Plan for Barbados” provides a coordinated approach of key government agencies and the petroleum sector to spill response. It covers oil spills to land and to the marine environment. The pIan: (f) Assigns duties and responsibilities to government personnel and the petroleum sector in responding to a spill; (g) Identifies the location, acquisition, and maintenance of equipment and supplies available for containment and cleanup in the event of a spill; (a) Provides a system of surveillance and reporting for early notification of spills; (b) Establishes a national response centre from which to coordinate resources and response personnel; (c) Provides oil spill response procedures for containment, dispersal, cleanup and disposal; and (d) Provides a link to international agencies for assistance and resources, should this be necessary. The primary responsibility for the clean-up and associated costs lies with the discharger. However, the Director of the Central Emergency Relief Organization (CERO) will act as the National Coordinator for the spill and has the overall responsibility for monitoring the cleanup operations. To provide advice and resources to deal with spills the Barbados National Response Team has been formed, which includes government agency and industry membership. This team is chaired by the Chief Environmental Engineer of the Ministry of Physical Development and recommends policy for emergency preparedness in dealing with spills. The National Coordinator will activate the Barbados National Response Team upon notification of a spill. The response to a spill is described in five phases: 1. The discharger should immediately provide notification of a spill. In some cases, the spill may be discovered and reported by others. The spill report should be as complete as possible and include:

(a) Name, address and telephone number of reporting source; (b) On-scene telephone number; (c) Exact location and time of spill; (d) Estimated amount and type of pollutant; (e) Source of pollutant and cause of spill; (f) Actions being taken to control spill; (g) Wind Speed and direction; and (h) Speed and direction of current; damage observed. 2. The spill will be investigated for severity and impacts. Based on this assessment, the resources of the Barbados National Response Team will be deployed as necessary. For more serious spills additional assistance from external resources may also be requested. 3. Measures will be taken to contain the spill and reduce the spread or impact. Under some circumstances dispersants may be necessary. 4. The clean up activities will be undertaken to recover as much oil as possible. Disposal of the recovered materials will be done to the satisfaction of the Environmental Protection Department of the Ministry of Physical Development and Environment. 5. Documentation of the incident will be provided including any sampling results and costs for cleanup Response Action Plan (a) Training of personnel is the responsibility of the CONTRACTOR and all appropriate personnel will be trained before commencement of work on the Project. (b) The individual who discovers a leak or spill shall immediately attempt to stop and contain the leak or spill as per instructions received during personnel training courses. (c) Work in the immediate area of a spill or leak shall be halted and the spill shall be reported to the SITE ENGINEER; (d) BLPC will report spills to the Environmental Engineering Department and the Coordinator for the National Oil Spill Response Team as per applicable regulatory requirements. (e) The CONTRACTOR will submit a written report to the Environmental Engineering Department as required by applicable legislation. A copy will be provided to BLPC. (f) The CONTRACTOR will have the full authority to take appropriate action without unnecessary delay. (g) The CONTRACTOR shall assume the overall responsibility of coordinating a clean-up which will include the following actions: (i) deploy onsite personnel to contain the spilled material using a dyke, pit, absorbent material or booms, as appropriate; (ii) assess site conditions and environmental impact of various clean-up procedures; (iii) choose and implement an appropriate clean-up procedure; (iv) deploy on-site personnel to mobilize pumps and empty drums (or other appropriate storage) to the spill site; (v) apply absorbents as necessary; (vi) remove any contaminated soil as directed by the Site Engineer; (vii) dispose of all contaminated debris, water, soil, cleaning materials, and absorbents by placing in an approved disposal site; and (viii) take all necessary precautions to ensure that the incident does not recur. (h) During the construction activities, the following spill response resources shall be available at an appropriate location in readiness to respond to accidental releases of fuels and/or hazardous materials: (i) Absorbent materials (e.g., sorbent pads, Sorb-All, vermiculite). (ii) Small equipment such as shovels, rakes, tool kit, sledgehammer, buckets, stakes, tarpaulins, one empty drum, protective equipment. (iii) Fire extinguisher.

1.1.1 Adherence to the Environmental Management Plan The Project Manager will be responsible for monitoring compliance with the Environmental Management Plan. The Contractor shall ensure that all construction staff, sub-contractors, suppliers, etc. are familiar with, understand and adhere to, the Environmental Management Plan. Failure by any employee of the Contractor, Subcontractors, Suppliers etc. to show adequate consideration to the environmental aspects of this contract shall be considered sufficient cause for the Project Manager to have the employee removed from the site. Project Manager will also order the removal of equipment form the site that is causing continual environmental damage (e.g. leaking oil or diesel). Such measures will not replace any legal proceedings the Developer may

institute against the Contractor. The Project Manager shall order the Contractor to suspend part or all of the works if the Contractor and/or any Sub-contractors, Suppliers, etc., fail to comply with both the Environmental Management Plan and construction procedures supplied by the Contractor. The suspension will be enforced until such time as the offending procedure or requirement is corrected and/or if required remedial measures put in place. No extension of time will be granted for such delays and all costs will be borne by the Contractor. 1.1.2 Contractors Boards The Contractor may only erect temporary construction boards in areas agreed by Municipality. 1.1.3 Construction Procedures The Contractor shall submit written procedures for all activities that could be potentially harmful to the environment. Such construction procedures shall include timing of activities, equipment and materials to be used (where applicable), visual screening, protection of the site, methods for cleaning the site both during construction and on completion of the works, disposal of waste and any other information deemed necessary. Construction procedures shall be submitted to the Project Manager at least five working days prior to commencing work on an activity. The Contractor shall not commence work on any activity until such time as the construction procedure has been scrutinized and agreed to in writing by the Project Manager. In addition, the Contract Manager may call for emergency construction procedures to be submitted within 24 hours of work commencing on activities that are deemed harmful to the environment and for activities of which the developer was previously unaware. If absolutely necessary, changes may be made to construction procedures once construction has commenced. In such instances the proposed changes must be agreed to in writing by the Project Manager prior to commencing with the change.

1.2 ENVIRONMENTAL AWARENESS TRAINING The Project Manager will provide a general environmental awareness session for all employees of the Contractor, sub-contractors, suppliers etc. The initial training session will be held prior to any work commencing on site. The Contractor shall ensure that all construction personnel, including senior site staff, sub-contractors and suppliers, etc attend an environmental awareness training session prior to commencing work on site. The Contractor shall allow two hours for this initial session. The Contractor shall provide the Project Manager with the names of construction personnel, and the activities in which they will be engaged to enable the scheduling of the awareness session. Additional staff, sub-contractors and suppliers coming onto the site must be informed of all environmental requirements prior to them commencing their duties. 1.3 SITE ESTABLISHMENT 1.3.1 Demarcation of the Site The “site” here refers to all areas required for construction purposes. The boundary of the site will be agreed with the Project Manager. The Project Manager will be responsible for the demarcation of the outer perimeter of the construction site. The method of

demarcating the boundaries shall be determined by the Contractor and agreed to by the Project Manager prior to any work being undertaken. The method of demarcation consists of steel droppers placed at regular intervals, with nylon rope between the markers where this prove to be safe, but where people move closely pass construction work, netting should be provided preventing building material from falling into these paths. The Contractor shall maintain the demarcation line and ensure that materials used for construction on the site do not blow on or move outside the site and environs, or pose a threat to people. The boundaries of the site shall be demarcated prior to any work commencing on the site. The site boundary demarcation fence shall be removed when the site is established. The Contractor shall ensure that all his plant, labour and materials remain within the boundaries of the site, unless otherwise agreed in writing with Project Manager. Failure to do so may result in the Project Manager requiring the Contractor to fence the boundaries of the site with wire mesh at his own expense to the satisfaction of the Project Manager and municipality. It will be the responsibility of the Contractor to decide on an appropriate system of protective fencing for the site. The Contractor shall be responsible to ensure that building materials such as sand is not blown away and take the necessary precautions to prevent sand from blown by the wind. 1.3.2 Ablution Facilities The Contractor shall provide the necessary ablution facilities for all site personnel. The siting of toilets shall be agreed with the Project Manager. The Contractor shall supply an adequate number of chemical or other suitable and approved toilets throughout the site where construction personnel will be operating. Toilets shall be easily accessible and where applicable shall be capable of being relocated. The toilets shall be secured to prevent them from blowing over, and the doors shall be provided with an external closing mechanism to prevent toilet paper form being blown out. Toilet paper dispensers shall be provided in all toilets. Toilets shall be cleaned and serviced regularly. The Contractor shall ensure that any chemicals and/or waste from the toilets are not spilled on the ground at any time. Should there be spillage of chemicals and/or waste, the Project Manager shall require the Contractor to place the toilets on a solid base with a sump. The contractor will be required to provide a suitable and approved and to remove accumulations of chemicals and waste from the site and dispose of it at an approved waste disposal site or sewage plant base at his own expense. Abluting anywhere other than in the toilets shall not be permitted. The Contractor shall be responsible for cleaning up any waste deposited by personnel. 1.3.3 Provision of Water The Contractor shall be responsible for providing construction, drinking and washing water for his staff and the professional supervisory staff. Construction water shall be obtained from locations as agreed with the Municipality. 1.4 MATERIALS HANDLING AND STORAGE 1.4.1 Petroleum, Chemical, Harmful and Hazardous Materials The Contractor shall comply with all relevant national, regional and local legislation with regard to the storage, transport, use and disposal of petroleum, chemical, harmful and hazardous substances and materials. The Contractor shall obtain the advice of the manufacturer with regard to the safe handling of such substances and materials. 1.5 CEMENT AND CONCRETE OPERATIONS

The Contractor is advised that cement and concrete are regarded as materials that are potentially damaging to the natural environment on account of the very high pH of the material, and the chemicals contained therein. The Contractor shall ensure that all operations that involve the use of cement and concrete are carefully controlled. Water and slurry from concrete mixing operations shall be contained to prevent pollution of the ground surrounding the mixing points. Old cement bags shall be placed in wind and spill proof containers as soon as they are empty. The Contractor shall not allow closed, open or empty bags to lie around the site. 1.6 SOLID WASTE MANAGEMENT Waste here refers to all construction debris and domestic waste. The Contractor shall supply waste bins/skips throughout the site at locations where construction personnel are working. The bins shall be provided with lids and an external closing mechanism to prevent their contents blowing out. The Contractor shall ensure that all personnel immediately deposit all waste in the waste bins for removal by the Contractor. Bins shall be emptied on a daily basis and the waste removed to the construction camp where it shall be properly contained in a scavenger, water and wind-proof containers until disposed of. The bins shall not be used for any purposes other than waste collection. Petroleum, chemical, harmful and hazardous waste throughout the site shall be stored in enclosed, bunded areas, the location of which shall be determined on site in conjunction with the Project Manager. The bunded areas shall be clearly marked. Such waste shall be disposed of off-site at a hazardous waste disposal site. 1.7 WASTE WATER MANAGEMENT 1.7.1 Discharge of Construction Water Construction water refers to all water affected by construction activities. The Contractor shall construct and operate the necessary collection facilities to prevent pollution. The Contractor shall dispose of collected waste water in a manner that complies with municipal regulations. 1.7.2 Prevention of Ground, Groundwater and/or Water Pollution The Contractor shall comply with the Water Act, Act 36 of 1998 and other national, regional and local legislation. The Contractor shall notify the Project Manager and the Municipality, immediately of any pollution incidents on site. The Contractor shall obtain Drizit pads and booms, or similar designed products or materials to soak up oil, petrol and diesel. These materials shall be readily available for use wherever construction equipment is working, fuel and lubricants is being offloaded and stored and equipment is filled and serviced. The Contractor shall ensure that he is familiar with the correct use and disposal of any materials designed to soak up petroleum products. 1.8 SITE CLEAN UP AND REHABILITATION 1.8.1 Site Clean Up The Contractor shall ensure that all temporary structures, equipment, materials, waste and facilities used for construction activities are removed upon completion of the project. The Contractor shall clear and clean the construction site to the satisfaction of the Project Manager upon completion of the project. 1.10.2 Accidents on Site The Contractor shall comply with the Occupational Health and Safety Act, National Building Regulations and any other national, regional or local regulations with regard to

safety on site. The Contractor shall ensure that contact details of the local medical services are available to the relevant construction personnel prior to commencing work. 1.10.3 Petroleum, Chemical, Harmful and Hazardous Materials The Contractor shall ensure that he is familiar with the requirements for the safe handling and disposal of petroleum, chemical, harmful and hazardous materials. The Contractor shall be responsible for establishing an emergency procedure for dealing with spills of release of these substances. He shall also ensure that the relevant construction personnel are familiar with these emergency procedures. The Contractor shall submit his emergency procedure to the Project Manager prior to bringing on site any such substances.

3.10 Performance Monitoring Environmental Monitoring A monitoring programme of the environmental effects of the demolition and construction works would be implemented to agreed BDC requirements. This would: • Evaluate the effectiveness of environmental mitigation, and identify environmental problems and appropriate responses at an early stage; • Ensure that the works are carried out in accordance with the provisions of the CEMP; and • Identify and implement any environmental improvements that would contribute to the overall environmental performance of the project. Safety Monitoring The requirements of the Management of Health and Safety at Work Regulations 1992, the Construction (Design and Management) Regulations 1994 and the Construction (Health, Safety and Welfare) Regulations 1996 would be adhered to. There would be continuous monitoring of safety standards on-site during all demolition and construction activities. To ensure that compliance with all existing and forthcoming 11 statutory requirements and industry good practice is adhered to, the Principal Contractor would issue a Health and Safety Plan in line with Construction (Design and Management) Regulations 1994. In doing so, regard would be had to the features listed below to ensure that no compromises are made which might jeopardise the safety of employees, contractors, or the public: • Construction work on-site; • Hazardous materials and chemicals; • Operating procedures; • Work permits; and • Emergency response. The health and safety performance of the Principal Contractor would be the subject of regular reviews, in accordance with the Applicant’s Corporate Health and Safety Policy. Inspection and Auditing The Applicant would wish to reassure itself that the CEMP is being adhered to by the Principal Contractor. To this end, Site inspections and more formal audits by the EVM would be undertaken. These are likely to use a checklist pro-forma, which would cover the environmental issues addressed in the CEMP. Where a problem is identified, corrective action would be identified by the EVM in conjunction with the Site Manager and Principal Contractor. This could take the form of, for example, further direct mitigation, changes to procedures or additional training. It is envisaged that BDC would have direct access to the EVM’s representative to ensure that any non-compliances with the requirements of the CEMP are speedily rectified. Contingency Planning

Although a serious incident is unlikely to occur during the demolition and construction phase, it is necessary to have procedures in place to deal with emergencies and incidents. Environmental incidents can be defined as unexpected events that lead to, or could in different circumstances have led to, adverse effects on people, property or on environmental resources such as habitats or historic features. The Principal Contractor would develop a series of plans, which would set out the response in the unlikely event of an incident occurring during demolition and construction such as a fuel spillage or an episode of unexpectedly elevated noise and/or dust levels. The procedures would include provision for incident reporting. Appropriate equipment and training would be provided for emergency response to spillages.