SPILL PREVENTION Doc. No.

: P1-CON-A03-420
Job No. : 2011020
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REVISION LOG

REV. NO. REV. DATE REVISED PAGE REVISION DESCRIPTION

A April 19, 2012 Issue for Approval

0 May 21, 2012 Issue For Construction
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TABLE OF CONTENTS

1 PURPOSE ............................................................................................................... 1

2 SCOPE .................................................................................................................... 1

3 REFERENCES ........................................................................................................ 1

4 ABBREVIATIONS ................................................................................................... 1

5 DEFINITIONS .......................................................................................................... 1

6 RESPONSIBILITIES ............................................................................................... 2

7 IDENTIFICATION OF POTENTIALLY POLLUTING SUBSTANCES:..................... 3

8 SPILL PREVENTION STRATEGIES AND GENERAL RESPONSE ACTIONS ...... 3

9 DISPOSAL .............................................................................................................. 6

10 COMMUNICATION, TRAINING AND DRILLS ........................................................ 7

11 SPILL REPOTING ................................................................................................... 7

12 ATTACHMENT ........................................................................................................ 8
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1 PURPOSE
The procedure defines the methods & strategies of preventing and controlling
chemical spills as well as relevant responsibilities at PTC JPP project.

2 SCOPE
This procedure is applicable to JPP Site and Camp Areas. Contractor shall follow
relevant PTC procedures and regulations.

3 REFERENCES
Key references for the present document are:
 Project HSE Plan (P1-CON-A03-120)
 Construction Environmental Procedure (P1-CON-A03-412)
 PROJECT HSE POLICY
 Royal Commission Environmental Regulations (RECR)
 Waste Management Procedure ( P1-CON-A03-419)
 Emergency Response Plan (P1-CON-A03-415)

4 ABBREVIATIONS
COMPANY POLYSILICON TECHNOLOGY COMPANY (PTC)
PROJECT PTC Jubail Polysilicon Project (PTC-JPP)
CONTRACTOR Hyundai Engineering Co., Ltd., KCC Engineering &
Construction Co. Ltd. and Hyundai Saudi Arabia Co., Ltd.
HSE Health, Safety & Environment
PM PROJECT Manager
SM Site Manager
SHSEM Site HSE Manager
EIA Environmental Impact Assessment
JIC Jubail Industrial City
MSDS Material Safety Data Sheet

5 DEFINITIONS

5.1 Spill/Leak
Any release of solid or liquid (pollutant) discharged into the Natural Environment,
releases into secondary containment with impermeable barriers are not considered a
release to environment, i.e.: Release into the bunded area without any impermeable
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ground liner allowing the spilled materials to seep into the ground below would be
considered us a release to environment and shall be reported.

6 RESPONSIBILITIES
HSE Organization in site and relevant environmental responsibilities are detailed in the
PROJECT HSE Plan and in the Construction Environmental Procedure.
Responsibilities of the site key functions concerning the provisions of the present
procedure are outlined

6.1 Project Manager (PM)

6.1.1 Responsible in ensuring the compliance with environmental requirements for local and
international laws and meeting Company’s requirements

6.1.2 Actively participate in and chair any meeting to discuss spill control measures

6.2 Construction Manager

6.2.1 Plan construction works in a manner that avoids or minimizes impact on the
environment.

6.2.2 Ensure construction personnel manage construction works in accordance with

statutory and legal requirements

6.2.3 Ensure environmental management procedures and protection measures are

implemented to an equivalent standard across all sites.

6.2.4 Ensures that Issued Environmental Management procedures are followed.

6.3 Site HSE Manager

6.3.1 Overall responsibility is for the implementation of the environmental matters of the
project.

6.3.2 Ensures environmental risks of the project or identified and appropriate remediation
measures are implemented on site.

6.4 Area Manager/Discipline Manager

6.4.1 Ensuring there is sufficient and appropriate spill response supplies in their area.

6.4.2 Ensuring that an adequate number of persons are trained in chemical spill response for
their area.

6.4.3 Take all necessary steps to minimize the chance of spills when working with chemicals

6.4.4 Cooperate with the Area Manager and the HSE Department to implement a spill
program in their area.
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6.4.5 Shall arrange for containment and control of the spill based on the requirements of the
relevant MSDS.

6.4.6 To Report the spill in case it was beyond the quantity stated in attachment 1.

6.5 Environmental Control Supervisor

6.5.1 Maintain records regarding inspections conducted, training conducted and spill kit
maintenance.

6.5.2 Provide assistance for developing site specific spill response procedures.

6.5.3 Assist spill response activities.

6.5.4 Participate in investigating Environmental Incidents according to the requirements of

Incident Reporting Investigation and Prevention procedure.

6.6 Subcontractors

6.6.1 Subcontractors are responsible to CONTRACTOR for respecting the provisions of this
Procedure and are subject to CONTRACTOR supervision.

6.7 All Employees

6.7.1 Subcontractors are responsible to CONTRACTOR for respecting the provisions of this
Procedure and are subject to CONTRACTOR supervision.

7 IDENTIFICATION OF POTENTIALLY POLLUTING SUBSTANCES:

Potentially polluting substances have been identified based on the various activities
performed in site. A tentative list is reported in the following:
 Diesel, Gasoline, etc.
 Hydraulic fluids and lubricants (Brake oil, Crude oil, engine transmissions fluids);
 Solvent and chemicals;
 Cement additives and residues;
 Lamination chemicals & Resins
 Paints;
 Battery acid;
 Contaminated Water; having contaminants such as oil, gasoline, chemicals, etc.)

8 SPILL PREVENTION STRATEGIES AND GENERAL RESPONSE ACTIONS

8.1 Spill Prevention Strategies

The general strategies described in the following subsections shall be adopted in order
to prevent the most critical spills and include;
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 Chemicals handling and storage;

 Hazardous materials handling and storage;
 Oil changes;
 Chemicals/fuel transfer;
 Construction equipment operation

8.1.1 Chemical handling and storage

 Provide initial and follow-up training in regular hse meetings (include proper
wearing of appropriate ppe, chemical handling and transferring techniques, etc);
 Properly labeled containers;
 Use appropriate chemical segregation practices;
 All chemicals storage tanks and drums shall be located on paved area or
contained within a suitably sized retention bund. All drainage valves shall be kept
closed. They shall be opened only after checking the absence of chemicals in
water to be discharged. In the event of a significant leakage from the tanks in the
bund the retained substance shall be pumped back into another tank.
 Keep material safety data sheets (MSDS) in the storage areas;
 Conduct periodic inspections in the storage areas to ensure compliance with
chemical storage requirements.

8.1.2 Hazardous material handling and storage

 Manual handling of hazardous materials shall be minimized and the use of
forklifts or cranes with pallet loads shall be preferred.
 Waste oils and other liquid wastes shall be stored in sealed drums within a
designated secondary containment area or in a temporary storage area
consisting of an earth bund lined with plastic sheeting;
 All fixed fuel storage tanks will be contained within a suitably sized concrete
retention bund; Additionally, fire-fighting equipment shall be interspersed around
the fuel storage tank as well as keep material safety data sheets (MSDS) in the
storage areas. Materials and vehicles also should not be located around the dike
 In the event of a significant leakage from a fuel tank in the bund the retained fuel
will be pumped back into another tank. Residual fuel on the bottom of the bund
will be soaked up using appropriate spill kits or sand and disposed of in
compliance with Waste Management Procedure (P1-CON-A03-419).
 Stationary fuel storage tanks and dispensing areas will have a containment
membrane underneath and a bund around;
 For transferring of fuel from a delivery tanker to a stationary storage tank:
- The hose coupling shall be compatible;
- The use of improvised connections shall not be permitted;
- Shut off valves shall be available and easily closable in the event of hose or
connection failure;
- The operation shall be supervised at all times.
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- Storage tanks shall be grounded to avoid fire cause by static electricity.

 During chemical / fuel transfer retention tanks or drip trays shall be placed below
all terminals and in line connections (e.g. drum taps, fuel hoses) to collect any
leak

8.1.3 Oil changes

 Place retention tanks or drip trays below drum taps and fuel hoses to collect
every drips and leaks
 Use portable tanks placed under engine drain points to prevent any spilling of oils
during oil changes. The contents of these tanks will be transferred immediately to
sealed drums within the designated waste oil storage areas;
 All oil changes will be carried out on a paved designed area;
 Trucks transporting oils, greases and fuels for the earthmoving machinery shall
be equipped with anti-spilling devices on distribution nozzles and pistols.

8.1.4 Chemical/fuel transfer

 All vehicle will be re-fuelled at designated re-fuelling areas
 Place retention tanks or drip trays below all terminals and in-line connections (e.g.
drum taps, fuel hoses, etc.) to collect drips and leaks;
 Properly connect delivery pipes. Ensure the integrity of all terminal and in-line
connections;
 Operator shall control the dispenser at all times

8.1.5 Construction equipment operation

 All stationary diesel and petrol operating construction equipment will have drip
trays placed under them during operation (any spillage will be collected and
disposed of as hazardous waste)
 Heavy vehicles and cranes shall be assisted during maneuvering to avoid
incidents;
 All plants and vessels shall be maintained in an efficient state, efficient working
order and in good repair;
 Pre start check up and visual checks to be carried out to ensure the integrity of
the plants/equipment.
 SPILL RESPONSE KITS (e.g. absorbent pads, disposable bags, booms) shall be
made readily available in the hazardous substances storage areas and in the
areas where potentially leaking equipment are used, in any refueling area, on
board a vessel, etc

8.2 General Response Actions

Any incidents where pollutant spills are involved require immediate response to stop
the source of the discharge, to limit the spread of material, to ensure the safety of
personnel, and to protect the environment in the area where the spill occurs.
The spill response emergency procedure to be applied in site and all spills shall be
reported. Refer to (P1-CON-A03-415) Emergency Response Plan.
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During response operations, priority shall be given to the protection of health and
safety of the personnel involved. Therefore, appropriate PPE shall be worn during the
response activities.
The pollutant materials, arisen by clean-up actions, shall be disposed of in compliance
with Waste Management Plan and Construction Environmental Procedure.

8.3 Containment Methods

The main containment techniques are:

8.3.1 Surface Containment

The method for surface containment of fuels, solvents, chemicals, and other
dangerous or hazardous toxic materials on impermeable ground may consist of:
 Block inlets/outlets to drains, pipes, sewage systems, and cable ducts to prevent
explosion risk or contamination of sewage treatment plants or water courses (if
any in the area);
 Use sorbents to limit spreading and concentrate the material, e.g. by brushing it in
to a collecting area so that it may be transferred to a container

8.3.2 Sorbent Barriers

Sorbent materials may be stacked or piled to form a continuous barrier across the
entire edge of the advancing pollutant mass to contain minor flow and recover a
portion of the hazardous substance. Collected pollutant may be recovered by physical
removal of spent sorbents or by vacuuming or pumping when quantity exceeds
absorption capabilities of the sorbents

8.4 Clean-up, Recovery and Removal Methods

For smaller spills, storage containers, such as lined drums or lined hauling trucks, will
typically be sufficient for collection and transport of the recovered and waste materials.
For larger spills or if insufficient storage containers are available, the removed material
may be held, prior to disposal or treatment, in a lined excavated ditch prepared for the
scope.
Recovery pump system may be used to remove pollutant from the water table. This
strategy is generally applied to a site when the depth of the groundwater table is not
significant.

9 DISPOSAL

9.1 Contaminated soil with oil:

Oily debris and oily rags includes sorbents, sand, and other materials contaminated
with oil as a result of an oil spill. Recovery of such waste during response activities
must be disposed of in accordance with local regulations and with environmental
responsible manner according to the National Legal Requirements

9.2 Hydrotest Wastewater:

Hydrotest water may be disposed by a number of methods including to dewatering
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basins/soakaways, evaporation ponds or direct to water courses. In all cases, an

environmental and social assessment will need to be undertaken including mitigation
measures to minimize impacts and appropriate standards are met.

10 COMMUNICATION, TRAINING AND DRILLS

 Each subcontractor representative, in his turn, shall hold a meeting in order to
inform and train his employees about the application of this plan and other
environmental plans
 All workers in site who will be involved with hazardous substances handling shall
be provided with basic and/or specific information and training about most
significant issues related to spill prevention and response activities.
 Personnel involved in the spill response shall be specifically trained in pollution
contingency response strategies and proper disposal of recovered chemicals and
materials.
 Spill emergency drills shall be planned and periodically carried out. Emergency
scenarios shall be prepared for these drills.

11 SPILL REPORTING
Any spill above the relevant quantities stated down in Attachment- 1 shall be reported
according to INCIDENT REPORTING INVESTIGATION AND PREVENTION
PROCEDURE AS an Environmental Release Incident for which Preliminary
Incident Report must be filled in and distributed according to the above procedure
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12 ATTACHMENT
Spill Quantities beyond which the spill must be reported as “ENVIRONMENTAL
RELEASE “according to Incident Reporting Investigation and Prevention Procedure.

Spill Reporting Guidance

Spilled Material Quantity

Oil
5 liter
(including oil emulsions)

Chemicals 5 liter
(Including water based solutions)

Sewage 100 liter

(Waste water coming from toilets, etc.)