Environmental and Social Standards Manual · EPA Environmental Protection Agency EPML Environmental Protection and Management Law ESIA Environmental and Social Impact Assessment FDA

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

Environmental and Social Standards Manual

VERSION DATE: 5 NOVEMBER 2014

ArcelorMittal Liberia Ltd.

P.O. Box 1275 Tubman Boulevard at 15

th Street

Sinkor, Monrovia Liberia

T +231 77 018 056

www.arcelormittal.com

Nimba Western Range Iron Ore Project, Liberia

Environmental and Social Studies, 2008-2015 Environmental and Social Standards Manual

Version: 5 November 2014 Page 2 of 161

Contents

List of Abbreviations ................................................................................................................................ 4

DOCUMENT REVISIONS ....................................................................................................................... 5

CHANGES FROM THE PREVIOUS VERSION ...................................................................................... 5

INTRODUCTION ..................................................................................................................................... 6

1. WORK SITE STANDARDS ............................................................................................................. 7 1.1 Standard for Safety Gear Provision to Site Staff and Workers ............................................... 7 1.2 Standard for Pit Latrines ......................................................................................................... 7 1.3 Standard for Sewage Disposal................................................................................................ 8 1.4 Standard for Burning or Burial of Rubbish at Temporary Camps ........................................... 9 1.5 Standard for Conduct by Employees in Railway Operation .................................................. 10 1.6 Standard for the Management of Waste ............................................................................... 11 1.7 Standard for Operation of Airstrips for Fixed Wing Aircraft ................................................... 16

2. FOREST PROTECTION STANDARDS ........................................................................................ 17 2.1 Standard for Bush Clearance, Tree Felling and Use of Chainsaws ..................................... 17 2.2 Standard for Bushmeat Hunting, Dealing, Transporting and Use ......................................... 25 2.3 Standard for Clearance of Caves, Adits and Tunnels ........................................................... 27

3. COMMUNITY RELATIONS STANDARDS ................................................................................... 28 3.1 Standard for Community Engagement .................................................................................. 28 3.2 Standard for Identification of Land Access and Community Interaction ............................... 29 3.3 Standard for Acquiring Land and Other Assets .................................................................... 31 3.4 Standard for Employment of Temporary Construction Labour ............................................. 33 3.5 Standard for Staff Behaviour ................................................................................................. 35 3.6 Standard for Handling Grievances ........................................................................................ 36 3.7 Standard for Unexpected Cultural Sites and Archaeological Finds ...................................... 39 3.8 Standard for Warning of Blasting at Mines and Quarries ..................................................... 41

4. AIR QUALITY STANDARDS ......................................................................................................... 42 4.1 Standard for Air Pollution Prevention and Control at Mine and Quarry Sites ....................... 42 4.2 Standard for Emissions Limits from Heavy Diesel Engines .................................................. 45 4.3 Standard Fuel Specifications for Project Phase 2................................................................. 46

5. WATER AND SOIL QUALITY STANDARDS ................................................................................ 47 5.1 Standard for the Control of Water Pollution .......................................................................... 47 5.2 Standard for Water Quality .................................................................................................... 49 5.3 Standard for Water Effluent Quality ...................................................................................... 50 5.4 Standard for Soil Contamination Screening .......................................................................... 53

6. EROSION CONTROL AND REVEGETATION STANDARDS ...................................................... 56 6.1 Standard for Mine Drainage and Sediment Capture ............................................................. 56 6.2 Standard for Settlement and Attenuation Ponds................................................................... 57 6.3 Standard for Mine Spoil Tips ................................................................................................. 59 6.4 Standard for Topsoil Stripping, Stockpiling and Restoration ................................................ 60 6.5 Standard for Constructing and Maintaining Earth Tracks ..................................................... 65 6.6 Standard for Simple Drainage Systems ................................................................................ 65 6.7 Standard for Slope Protection by Stone Pitching .................................................................. 66 6.8 Standard for Spillways and Check Dams Lined with Soil-filled Bags ................................... 67 6.9 Standard for Stone-filled Gabions ......................................................................................... 68 6.10 Standard for Check Dams ..................................................................................................... 70 6.11 Standard for Selection of Revegetation Techniques for Erosion Prevention ........................ 73 6.12 Standard for Revegetation using Planted Grasses ............................................................... 74 6.13 Standard for Revegetation using Hardwood Cuttings (Brush Layers) .................................. 75 6.14 Standard for Revegetation using Shrub and Tree Seedlings ............................................... 77 6.15 Standard for Drainage Systems on Major Roads ................................................................. 78 6.16 Standard for Slope Cutting Grades ....................................................................................... 80




7. NOISE, VIBRATION AND RADIATION STANDARDS ................................................................. 81 7.1 Standard for the Limitation of Noise Emissions .................................................................... 81 7.2 Standard for Radio and Microwave Emissions ..................................................................... 83 7.3 Standard for the Limitation of Vibrations and Air Overpressure ........................................... 84 7.4 Standard for Use of Instruments with Sources of Ionising Radiation .................................... 86

8. VISUAL APPEARANCE STANDARDS ........................................................................................ 87 8.1 Standard for the Colours of Structures ................................................................................. 87 8.2 Standard for Night-time Lighting of Work Sites ..................................................................... 87

9. POLLUTION PREVENTION STANDARDS .................................................................................. 90 9.1 Standard for the General Prevention of Pollution at Work Sites ........................................... 90 9.2 Standard for Avoiding and Treating Spills ............................................................................. 96 9.3 Standard for Action to Clean Up Spills .................................................................................. 97 9.4 Standard for Pollution Prevention from Ships ....................................................................... 99 9.5 Standard for Ships‟ Ballast Water Management ................................................................. 106 9.6 Standard for Ship to Ship Transfers .................................................................................... 109

10. HAZARDOUS MATERIALS STANDARDS ............................................................................. 118 10.1 Standard for the Storage, Dispensing and Disposal of Hazardous Materials ..................... 118 10.2 Standard for the Cleaning-up of Pollution by Hazardous Materials .................................... 119 10.3 Standard for Operation of the ArcelorMittal Liberia Incinerators ......................................... 120 10.4 Standard for the Use of Wood Preservative ....................................................................... 124 10.5 Standard for the Use of Pesticides (Herbicides and Insecticides) ...................................... 125 10.6 Standard for the Removal of Paint from Steel Bridges ....................................................... 128 10.7 Standard for the Disposal of Waste Containing Asbestos .................................................. 129 10.8 Standard for the Use of Explosives in Quarries and Mines ................................................ 130

11. FUEL HANDLING STANDARDS ............................................................................................ 134 11.1 Standard for Bunding Fuel Tanks ....................................................................................... 134 11.2 Standard for Dispensing Fuel at Site Camps ...................................................................... 134 11.3 Standard for Pollution Prevention from Above Ground Oil Storage Tanks ......................... 135 11.4 Standard for Oil Separators in Surface Water Drainage Systems ...................................... 139 11.5 Standard for Preventing Pollution from Refuelling Facilities ............................................... 143 11.6 Standard for Pollution Prevention in Vehicle and Plant Workshops ................................... 145 11.7 Standard for the Remediation of Oil-contaminated Soil ...................................................... 147

12. ENVIRONMENTAL EDUCATION STANDARDS .................................................................... 150 12.1 Standard for Briefing Site Crews ......................................................................................... 150 12.2 Standard for Briefing Professional and Technical Staff ...................................................... 152 12.3 Standard for Safety Awareness .......................................................................................... 157

13. ENVIRONMENTAL POLICIES ................................................................................................ 158 13.1 ArcelorMittal Corporate Environmental Policy .................................................................... 158 13.2 Government of Liberia‟s Environmental Principles ............................................................. 159 13.3 ArcelorMittal Liberia‟s Policy on Caring for Nature ............................................................. 160




List of Abbreviations AML ArcelorMittal Liberia

BWM Ballast Water Management (International Convention)

CEMP Contractor‟s Environmental Management Plan

CLO Community Liaison Officer

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPA Environmental Protection Agency

EPML Environmental Protection and Management Law

ESIA Environmental and Social Impact Assessment

FDA Forestry Development Agency

FONSI Finding of No Significant Impact

H&S Health and Safety

HSE Health, Safety and Environment

ICAO International Civil Aviation Organisation

IMO International Maritime Organization

IMSBC International Maritime Solid Bulk Cargoes (Code)

ISPS International Ship and Port Security (Code)

LAA Liberian Airports Authority

LAMCO Liberia American-Swedish Minerals Company

LCAA Liberian Civil Aviation Authority

MARPOL Maritime pollution (International Convention)

MDA Mineral Development Agreement

M/V Motor Vessel

OGV Ocean-going Vessel

SOLAS Safety of Life at Sea (International Convention)

SOPEP Ship Oil Pollution Emergency Plan

TV Transhipment Vessel




DOCUMENT REVISIONS

Series Title Date

1 ESIA for Phase 1 (DSO), Volume 6: Some Important Standards for Implementation of the Environmental and Social Management Plan

September 2010

2 ArcelorMittal Liberia Environmental Standards Manual 10 June 2011

3 ArcelorMittal Liberia Environmental Standards Manual 9 November 2011

4 ArcelorMittal Liberia Environmental Standards Manual 16 July 2012

5 ArcelorMittal Liberia Environmental Standards Manual 12 December 2012

6 ESIA for Phase 2 (Concentrator), Volume 6, Part 2: Environmental Standards Manual

1 March 2013

7 ArcelorMittal Liberia Environmental Standards Manual 5 March 2014

8 ArcelorMittal Liberia Environmental Standards Manual 5 November 2014

CHANGES FROM THE PREVIOUS VERSION The following changes are incorporated in this version, from the material given in the previous version (which was dated 5 March 2014).

Standard Summary of changes

Title Changed from “Environmental Standards Manual” to “Environmental and Social Standards Manual” to reflect inter-connectedness, and the existence already of key social standards in the manual.

1.7 Standard for Operation of Airstrips for Fixed Wing Aircraft: new standard added.

5.1 Standard for the Control of Water Pollution: section on protection and conservation of riparian zones rationalised and made more explicit.

5.3 Standard for Water Effluent Quality: biological guideline quality standard added.

6.2 Standard for Settlement and Attenuation Ponds: guideline rainfall duration and intensity figures updated.

6.12 Standard for Revegetation using Planted Grasses: guidelines clarified on source locations for grass planting material.

7.4 Standard for Use of Instruments with Sources of Ionising Radiation: new standard added.

8.2 Standard for Night-time Lighting of Work Sites: external uses of LED modified; aviation-related lighting guidelines added.

10.5 Standard for the Use of Herbicide changed to Standard for the Use of Pesticides (Herbicides and Insecticides); standard modified to include insecticide use; a table added of all approved pesticides plus some banned pesticides widely available in the Liberian market.




INTRODUCTION This document gives the environmental standards and guidelines that underlie the Environmental Management Plans that are devised and implemented by ArcelorMittal Liberia. These apply equally to work by the Company, and its Contractors and Suppliers. The standards contained in this version derive from four main sources.

Standards derived directly by ArcelorMittal Liberia to form the basis for the implementation of its infrastructure development and mining works.

Standards attached to regulations in draft by the Environmental Protection Agency.

Other Government of Liberia standards.

Standards adapted from international sources, such as the UK Environment Agency, where none so far exist in Liberia.

Further details of working procedures are given in other Company documents. In particular, the ArcelorMittal Liberia Resettlement Manual gives the full details of procedures to be followed in that respect. The standards given in this document replace all previously issued standards.




1. WORK SITE STANDARDS

1.1 Standard for Safety Gear Provision to Site Staff and Workers The site in-charge or contractor shall supply high quality personal protective equipment (PPE) meeting international standards, as appropriate to the needs for each work site and worker‟s task. The necessary equipment is to be provided to all staff and workers entering the site, irrespective of rank and level of seniority. The equipment is to be comfortable for prolonged use, and is to be replaced as soon as it loses its effectiveness. The site in-charge or contractor is responsible for ensuring that all staff and workers use appropriate safety gear during all hours of work on each site. Fluorescent jackets shall be worn when on any construction or operational site, or in the proximity of other workers operating machines or tools, or engaged in potentially dangerous activities such as erecting structures. Helmets shall be worn when on any construction or operational site, or whenever there is a danger of head injury from falling or moving items, such as loose formwork, unsecured overhead structures and the tools of other workers. Goggles shall be worn whenever there is a risk of flying debris, from the use of hammers, drills or other fast-moving or impact-creating tools and machines. Gloves shall be worn whenever there is a risk of hand injury from hard or sharp materials such as wood or metal, or sparks; they shall also be worn when handling caustic materials such as cement. Boots with steel toe and side protection shall be worn when on any construction or operational site, or whenever there is a risk of foot injury from fast-moving or impact-creating tools and machines, such as drills, sledge hammers and pick axes. Ear protection shall be worn whenever a person is within 20 metres of any machine making a loud noise, including generators, drills, compressors, power saws, grinders, or earth-moving and compacting machines. No individual shall be exposed to noise levels in excess of 85 dB without wearing ear protection. Environmental Department staff can measure site noise on request. Further details of essential safety procedures are given in the ArcelorMittal Mining Department‟s global Safety, Health and Environmental Rules for Operations and Contractors. Additional material is provided periodically and specifically by ArcelorMittal Liberia‟s Health, Safety and Environment Department. Source: ArcelorMittal Liberia.

1.2 Standard for Pit Latrines Where temporary toilets are required on site, earth pit latrines are the preferred option. These shall consist of a simple pit with a well-ventilated shelter over the top. Pit latrines shall be sited in locations that meet the following criteria:

Within the right of way of the railway or service road.

At least 50 metres from a water course or water body of any description.

At least 100 metres from a drinking water source. This shall be determined by asking members of local communities to show their sources of drinking water before siting a latrine.

At least 50 metres from a house.

Where neither surface nor ground water is likely to collect in the pit.




Holes should be around 1.5 metres deep, and certainly not less than 1 metre, and approximately 1 metre in diameter. They shall be completely enclosed by a sound wooden platform over the top, apart from:

A small hinged cover that allows use of the latrine but can be closed when not in use; and

A vertical vent pipe at least 2 metres long, with mosquito mesh over the top, made of bamboo or plastic.

A short burst (10 seconds) of disinfectant or insecticide should be sprayed, or a small amount of lime thrown into the latrine every 2 to 3 days, to stop mosquitoes from breeding in water collected in the pit. The latrine shall be moved to a new location if it becomes unpleasant to use due to excessive smell, becomes full, or a month of use time elapses. When this is done, the pit must be carefully backfilled and the soil compacted. The ground surface over and around the pit shall be regraded and made good, and if necessary revegetated. Source: ArcelorMittal Liberia.

1.3 Standard for Sewage Disposal Introduction Wherever possible, sewage should be sent to a properly designed and constructed sewage treatment works. These should employ a Fluidised Aerobic Bio (FAB) Reactor or equivalent, whereby raw sewage is treated by bacteria which render it sterile. Outlying housing areas and camps should use appropriately-sized septic tank systems, with the liquids drawn off into an underground soakaway (see below). For temporary purposes, liquids from septic tanks may be drawn off by tanker and discharged into a sewage treatment plant. Soakaway standard for septic tanks The following guidelines are to be followed to provide for the underground soaking away of liquids emanating from septic tanks.

Select an area for the soakaway that is at least 50 metres down gradient, at least 250 metres laterally and at least 500 metres up gradient of any boreholes or water supplies.

Excavate a trench for the underground soakaway (2 metres deep by 1.5 metres wide by 50 metres long).

Line the large trench for the soakaway with permeable geotextile.

Place a layer of clean stone of 50 to 100 mm size to 100 mm that is 600 mm thick throughout the trench.

Lay a UPVC pipe of 150 mm diameter perforated with at least 100 holes of 8 mm diameter per metre of pipe. The upper end shall be connected to the outlet from the septic tank and the lower end shall be covered over with permeable geotextile.

Fill the trench with clean stone of 50 to 100 mm size to 1 metre below ground level.

Place a sheet of permeable geotextile over the stone and then backfill the trench to ground level with 1 metre thickness of soil. This shall be lightly compacted by running an excavator track over the backfilled trench.

Other designs and sizes are permitted if supported by appropriate civil engineering calculations and design. Soakaway for “grey” water only “Grey” water is used water derived from kitchens, showers, laundries and other washing areas, but not from toilets. It should normally be sent to a sewage treatment plant or septic tank. If no sewerage




system is available or the soil has low permeability (making it difficult to dispose of large volumes of water in a soakaway), then a reed bed system may be used. A reed bed system uses a minimum of three and preferably five separate ponds in series, for the biological treatment of water. Water should be resident in the system for at least 7 days. This usually requires 3 m

2 of reed bed surface area per person using the system, with an outlet pipe height of 0.5

metre. When the pond series is constructed, local swamp reeds should be transplanted into the ponds. During use, it must be ensured that the reeds are healthy and growing vigorously. If the reeds are dead, the system must be stopped until new reeds have been established. Discharge from the final pond may go into an open water course. Samples should be tested regularly for bacterial quality if there is a water supply known to exist downstream. Chemical toilets The use of chemical toilets is strongly discouraged. They may only be used on ArcelorMittal Liberia‟s projects and operations where it is proven that neither a standard water closet and septic tank system, nor a pit latrine, are practical. There are two main risks involved in chemical toilets: (a) damage to soils, plants, animals and water from the chemicals used in the toilets; and (b) health dangers to people in the vicinity from the sewage being disposed. Waste from chemical toilets shall not be poured into a foul drain leading into one of the company‟s sewage treatment plants at either Buchanan or Yekepa. This is because the sewage treatment plants rely on biological aerobic digesters, and the bacteria would be killed by the discharge from chemical toilets; and this would ruin the treatment process. Chemical toilets should also not be discharged into septic tanks, since the chemical used in toilets can have an adverse effect on the sewage digestion process in this situation as well. A disposal hole must be excavated to receive waste from chemical toilets. A suitable hole must be situated at least 100 metres from any dwelling and at least 100 metres from a water course, spring or well. Wherever possible, it should be on a permeable but not sandy soil. Holes shall be two metres deep when first excavated. When full or nearly full, chemical toilets shall be transported to the approved emptying point for careful disposal under proper supervision. Once emptied, the toilet shall be sluiced down with plenty of water. The toilet receptacle shall also be well washed out with water and disinfectant, all of which shall also be discharged into the disposal hole. Each time a toilet is emptied into the hole, the waste shall be covered with 100 mm of soil. When the hole has only 0.5 metre of depth remaining, it shall be completely filled and a new hole started. Source: ArcelorMittal Liberia.

1.4 Standard for Burning or Burial of Rubbish at Temporary Camps This standard shall apply only to domestic rubbish at temporary site camps and not to permanent establishments, which shall have formal, long term procedures for waste disposal. All industrial and hazardous waste shall be returned to one of the main project facilities (Buchanan or Yekepa) for proper disposal. This shall include batteries, waste oil, tyres, used vehicle parts, and any form of hazardous chemicals or their containers. All rubbish that is combustible shall be burnt. This shall be done only in a designated area, one per camp, on the downwind side of the living and working areas.




Before starting a bonfire, all vegetation shall be cleared in a radius of 5 metres around the fire site. If possible, rocks shall be placed in a circle to mark the location of the fire. Burning shall be for a limited and defined period each day (e.g. 8 to 10 am). One individual shall be made responsible for burning, and for ensuring that the fire is completely dead before he leaves it. The individual shall be provided with the means to control the fire if it starts to spread (e.g. buckets of water ready at the burning site). Residues of bonfires and non-combustible items (e.g. glass) shall be buried in a designated and landfill site approved in advance by the company‟s Environmental Department. When finished, the buried material shall be underneath at least one metre of soil. Source: ArcelorMittal Liberia.

1.5 Standard for Conduct by Employees in Railway Operation The Company shall maintain and enforce a comprehensive set of strict operating rules for its railway. This standard summarises only the key messages of conduct to be observed by Company of Contractor employees involved in the operation of the railway. Safety and a willingness to obey the rules are of the first importance in the performance of duty for all employees. If in doubt, the safe course must be taken. Every employee in any service connected with the movement of trains, aligning main track switches, protection of track work and operation of track units shall:

be subject to and conversant with these rules, special instructions and general operating instructions and have passed the required examinations for their duties;

have a copy of the rule book, the general operating instructions, current time table and any supplements in effect, accessible while on duty;

provide every possible assistance to ensure every rule, special instruction and general operating instruction is complied with and shall report promptly to the proper authority any violations thereof;

communicate by the quickest available means to the proper authority any condition which may affect the safe movement of a train and be alert to the Company‟s interest and join forces to protect it;

obtain assistance promptly when it is required to control a harmful or dangerous condition;

be conversant with and be governed by every safety rule and instruction of the Company pertaining to their duties;

seek clarification from the proper authority if in doubt as to the meaning of any rule or instruction; and

conduct themselves in a courteous and orderly manner. Further and more detailed instructions will be found in time tables, general operating instructions and time table supplements. Employees must:

be vigilant to avoid the risk of injury to themselves or others;

expect the movement of a train, engine, wagon or track unit at any time, on any track, in either direction;

not stand in front of an approaching engine or wagon for the purpose of boarding such equipment;

not ride the side or the roof of a moving engine or wagon when passing side or overhead restrictions;

not be on the roof of a moving engine or wagon, or on the lading of a moving ore wagon;

not be on the end ladder of a wagon while in motion except for the purpose of operating a hand brake.




While on duty employees must not:

engage in non-railway activities which may in any way distract their attention from the full performance of their duties;

sleep or assume the position of sleeping;

use personal electronic devices other than authorised communications equipment relevant to the task in hand.

Overhead and side clearance may be restricted on a track at a locomotive or wagon shop. Employees must not ride on top or side of equipment when on any locomotive shop or wagon shop track, whether or not the overhead and side clearance is restricted. The use of intoxicants or narcotics by employees subject to duty, or their possession or use while on duty, is prohibited. The use of mood altering agents by employees subject to duty, or their possession or use while on duty, is prohibited except as prescribed by a doctor. The use of drugs, medication or mood altering agents, including those prescribed by a doctor, which, in any way, will adversely affect their ability to work safely, by employees subject to duty, or on duty, is prohibited. Employees must know and understand the possible effects of drugs, medication or mood altering agents, including those prescribed by a doctor, which, in any way, will adversely affect their ability to work safely. Prior to commencing work, employees must advise their supervisor of any physical disability or illness that may affect their ability to complete their tour of duty. Source: ArcelorMittal Liberia Railway Operating Rules.

1.6 Standard for the Management of Waste Introduction The principles of pollution prevention are provided in Standard 9.1. This includes the following key messages.

Everyone should minimise waste production to save money and resources.

A review of the options for minimising waste will usually help to find ways to save money on raw materials and waste disposal costs.

Reuse your waste or buy in products that can be reused many times – it will save money in the long term.

Recycle as much waste as possible. This Standard provides guidance on how different types of waste should be managed. Waste management in general A waste management strategy is to be managed on the principles of reduction, recovery, recycle and reuse. Recycling and waste reduction campaigns shall be conducted whenever there is evidence of unnecessary waste generation. A distinction will be made between waste materials that have a potential commercial value – which shall be classed as assets – and those with no value – which shall be considered non-assets. Waste materials shall be collected and segregated at the source. Care shall be taken to avoid spills during storage and handling. Workers must use appropriate personal protective equipment when handling all forms of waste.




Full records shall be maintained of the types and quantities of waste generation, storage, transfers and disposals. Landfill sites should be selected with care and the location and details approved by the Environmental Protection Agency. They should be in areas that are not prone to slippage, cannot leach to surface water and groundwater, and are a suitable distance (at least 400 metres) from settlement. They should be located down gradient of any water supply boreholes. The base of a landfill site should be lined with an impermeable membrane and seepage water piped to a sewage treatment plant. As it is filled, the site should be progressively compacted and buried with soil. Always ensure that landfill sites are in secure compounds. Waste materials that are assets Topsoil. Waste topsoil generation should be minimised by disturbing the soil only where it is necessary to do so. Topsoil is to be removed carefully, by scraping it off in thin layers. It will be stored in shallow stockpiles, which must not be compacted. Stockpiles shall be planted with grass to prevent erosion and maintain soil quality. Once the work has been completed, the topsoil must be returned to rehabilitated areas. Under no circumstances shall topsoil be sent to spoil tips, allowed to erode or be contaminated with other substances. Traffic must not be allowed to run on topsoil, causing it to become compacted, either in its natural state or in stockpiles. Topsoil is the source of almost all food, and its protection means the protection of life itself. Scrap iron and steel. Metallic objects and machinery should be re-used as far as it is practicable and safe to do so. Scrap shall be stockpiled in a safe and secure area. Once accumulated, large batches of scrap shall be sent to an appropriate steel plant within the ArcelorMittal Group or auctioned under company rules. Under no circumstances shall scrap be placed into landfill sites, allowed to be stolen by informal scrappers or sold without following Company guidelines. Non-ferrous metallic scrap (e.g. aluminium, copper and lead). Metallic objects and components should be re-used as far as it is practicable and safe to do so. Scrap items shall be segregated and kept in safe, dry locations, such as shipping containers. Aluminium items, especially used drink cans, shall be crushed to reduce storage volume. Once accumulated, batches of scrap metals shall be sold by the Company to an authorised dealer. Used commercial and industrial machines (vehicles, trucks, generators etc). Wastage should be reduced by using machines for their full design life, and repairing rather than replacing them. Once defunct, they should be stripped of re-usable parts and stored securely, in a bunded and covered area. Machines shall be decommissioned thoroughly, all fuel and lubricants removed, moving parts degreased and components with valuable materials such as copper and lead removed for separate disposal as described above. Remaining usable scrap shall then be sold as a Company asset, as described above. Under no circumstances shall machines be placed into landfill sites, allowed to be stolen by informal scrappers or sold to unauthorised companies, uncertified small enterprises or individuals who might re-use their components without proper disposal of unwanted parts. Used oil drums. Used oil drums shall be stored securely, in a bunded and covered storage area. They shall be recycled for waste oil or other appropriate uses. They are not to be sold to unauthorised companies or uncertified small enterprises. If they need to be cleaned, they shall be washed in an area with a full oil separator drainage system.




Non-asset waste Vegetation. The cutting of vegetation shall be minimised by only cutting plants or plant parts that are in the way of approved activities. This means plants that are in the direct area required for access tracks, mining areas or other purposes. Vegetation shall be cut into small pieces and stacked beside the working area to decompose slowly. It shall not be burnt, either standing or cut. Plantation trees and agricultural plants shall not be cut without following the procedures given in the Resettlement Manual. Pit sawing is forbidden in areas influenced by the Company, and any evidence of this activity shall be reported to the ArcelorMittal Liberia Health, Safety and Environment Department. Spoil (overburden). Damage to land and wasted energy shall be minimised by removing spoil only where it is essential to do so. Spoil shall be placed only in designated and approved spoil tip sites, which must be prepared in advance. Preparation shall include the installation of drainage blankets and slope toe retaining walls as necessary to ensure permanent stability. Spoil shall be placed in shallow layers, not more than 2 metres in thickness, compacted and shaped as they are developed. Erosion protection shall be provided as necessary to ensure that there is no sediment washed into water courses; this will usually be done using planted grasses. The water regime and stability of spoil tips shall be monitored and action taken as required to resolving any problems that are identified. Spoil tips will be kept away from watercourses and seasonal drainage channels unless adequate through-flow has been provided. The use of any spoil tip will be discontinued when the designated area has been used up. Contaminated soils. The contamination of soil will be avoided by adhering to the hazardous materials storage and handling standards (see Standards in sections 9, 10 and 11). Any soil that has become contaminated will be excavated and removed to a level and secure area, surrounded by an earth bund. The contaminated soil shall be treated fully using an approved bioremediation agent. The area affected will be fully rehabilitated, either using appropriate topsoil from a stockpile, or by replacing the remediated soil as soon as it has been decontaminated. This process will be used in every case where there has been any spill of hydrocarbons or other chemicals. Under no circumstances will contaminated soils be dumped untreated. Used lubricants. Waste from excessive used oils shall be reduced by using lubricants for their full design life. Used lubricants shall be stored securely, in strong, leak-proof drums in either a double-walled container or in a bunded and covered storage area. Spill kits will be maintained ready and serviceable in all storage and handling areas, and carried in transporting vehicles. Used oil may be sold to large rubber factories for use in the boilers, or to disposal companies with valid certification from the Environmental Protection Agency and approved by the ArcelorMittal Liberia Health, Safety and Environment Department. Under no circumstances may any form of used lubricant be poured away, either into the soil or into water, or sold to chain saw operators. Oily water from workshops and fuelling stations. Industrial oil-water separators shall be installed as part of the drainage system at every mechanical workshop and every fuelling station. Drainage shall be arranged such that all spillages and rainwater drain through the separator. All separators shall be maintained according to the manufacturer‟s instructions. Standard 11.4 provides guidelines for oil separators. Oily water from ships. If quantities of water are too great to be poured through an existing oil-water separator, contaminated water from ships shall be stored until the dry season. It shall then be placed in a sealed pond and the water evaporated off. The dried residues shall then be scraped up and incinerated in an industrial high temperature incinerator. Used grease. Waste from excessive used grease shall be reduced by using it for its full design life. Used grease shall be stored securely, in strong, leak-proof drums in a bunded and covered storage area. Grease shall be incinerated at a high temperature in a proper industrial incinerator.




Used engine filters (fuel and oil filters). Waste from excessive used filters shall be reduced by using them for their full design life, and if possible ensuring this is reached by appropriate cleaning. Used filters shall be stored securely, in strong, leak-proof drums in a bunded and covered storage area. Used filters may be sold to disposal companies with valid certification from the Environmental Protection Agency and approved by the ArcelorMittal Liberia Health, Safety and Environment Department. Alternatively, filters may be crushed to remove residual fuel or oil, and incinerated at a high temperature in a proper industrial incinerator. Used hazardous containers (paint tins, pesticide containers, etc). Used containers shall be stored securely, in strong, leak-proof drums in a bunded and covered storage area. Used paint tins and pesticide containers shall be crushed as far as possible and sent to an approved landfill site. Under no circumstances shall containers or any parts of them be sold to unauthorised companies or uncertified small enterprises. Containers must not be washed in open water courses or areas that do not drain to a proper sewage treatment plant. Used tyres. Wastage shall be reduced by using tyres for their full design life (usually until the tread is less than 1.2 mm for road vehicles). Used tyres shall be stored securely, in a recognised storage area. They may be sold to companies that will recycle them for non-road uses, and which are approved by the ArcelorMittal Liberia Health, Safety and Environment Department. Where there is doubt about the future use of tyres, they should be slashed before sale to make them useless for road vehicles. Tyres should also not be sold to people who will use them for quarrying, since this involves air pollution from low temperature burning. Tyres may also be formed into compressed bales and used to construct barriers or slope stabilisation structures. They may also be chipped and sent to approved companies that can burn them in furnaces at high temperatures or sent to an approved landfill site. Used batteries (12-volt lead-acid and gel-filled batteries). Where possible, batteries should be purchased under a buy-back policy from the suppliers to avoid the storage and handling of waste batteries. Wastage should be minimised by using batteries for their full design life, servicing and recharging them where feasible. Used batteries shall be stored securely, in strong, leak-proof containers in a bunded and covered storage area. Batteries containing lead shall be sold for recycling by companies with valid certification from the Environmental Protection Agency and approved by the ArcelorMittal Liberia Health, Safety and Environment Department. Under no circumstances shall batteries be sold to unauthorised companies, uncertified small enterprises or individuals who might re-use their components without proper disposal of acid or other unwanted parts. Used personal protective equipment (PPE). Wastage should be reduced by using PPE for its full design life. Used PPE should be stored securely, in strong, leak-proof containers in a bunded and covered storage area. PPE shall be sorted into chemically contaminated (e.g. overalls and gloves stained with creosote from handling rail ties) and non-contaminated items. Chemically contaminated PPE shall be incinerated at high temperature in an industrial incinerator or, if this is not possible, in a purpose-dug pit. Residues shall be placed into an approved landfill site. Non-contaminated PPE shall be placed into an approved landfill site. Used workshop clothing and rags (i.e. oily waste). Wastage should be reduced by using clothing and rags for as long as it is safe to do so. Oily waste should be stored securely, in strong, leak-proof containers in a bunded and covered storage area. It shall be incinerated at high temperature in an industrial incinerator or, if this is not possible, in a purpose-dug pit. Residues shall be placed into an approved landfill site. Household waste. Awareness programmes shall be undertaken to encourage waste minimisation. The use of throw-away plastic bags shall be discouraged inside the concession. Households shall be given the necessary waste bins to segregate their waste into aluminium (e.g. foil and drink cans), steel (e.g. food tins), glass, plastics, cardboard, compostable and other waste. The segregated waste shall be collected for disposal as follows.

Aluminium, steel, glass, plastics and cardboard shall be sold for recycling by companies with valid certification from the Environmental Protection Agency and approved by the ArcelorMittal Liberia Health, Safety and Environment Department.




Compostable waste shall be composted and, once fully decomposed and sterile, spread to land as fertiliser or mulch.

The remaining waste shall be sent to an approved landfill. Food waste. Wastage shall be minimised by ensuring that canteens do not over-cook. Canteen staff shall be encouraged to use uneaten food for themselves and their families if it is still safe. Arrangements shall be made for farmers of domesticated animals to collect food waste for feeding to their stock. Any unused vegetable material shall be composted and unused animal products sent to an approved landfill site. All food waste shall be stored and transported in containers that are proof against dogs, crows and rodents. Hospital waste. All biomedical waste shall be stored in appropriate sealed containers. Wastes shall be segregated in the hospital or clinic into different categories, in the appropriate colour bins; it is important to ensure staff involved in the handling of waste are equipped with appropriate PPE. Biomedical waste shall be incinerated at a temperature of 800 to 1600ᵒC in an approved specialist incinerator. Incinerator ash and residues shall be placed into an approved landfill site. Only appropriately trained staff shall handle hospital wastes and operate incinerators. Used Domestic Machines (refrigerators, air conditioners, washing machines etc) and IT Equipment (computers, printers, UPS etc). Wastage shall be reduced by using machines for their full design life, and repairing rather than replacing them. Used machines shall be stored securely, in a bunded and covered storage area. Re-usable parts should be stripped out for repairing other equipment. Machines shall be sold for recycling by companies with valid certification from the Environmental Protection Agency and approved by the ArcelorMittal Liberia Health, Safety and Environment Department. Under no circumstances shall machines be sold to unauthorised companies, uncertified small enterprises or individuals who might re-use their components without proper disposal of unwanted parts. Recording hazardous waste management and disposal Workshops, operational departments and contractors are required to record the accumulation, storage and transfer of potentially hazardous waste (including materials that may be used for environmentally unsound purposes after transfer). This shall include, but not necessarily be limited to, the following:

Used commercial and industrial machines (vehicles, trucks, generators etc);

Used lubricants;

Oily water of any kind;

Used engine filters (fuel and oil filters);

Used hazardous containers (paint tins, pesticide containers etc);

Used tyres;

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

Hospital waste (biomedical and clinical). The unit generating the waste must keep a Waste Materials Record Book. This must contain as a minimum, full records of the following:

Weekly or monthly estimate of the quantities of each type of hazardous waste;

The location of storage and any special storage measures employed;

Each disposal of waste, including the type, quantity, date and location of each transfer;

The destination of all disposed waste, including the details of any waste management contractor, the method of transport and the point of transfer of responsibility;

Where a waste contractor is involved, a copy or details of the contractor‟s Environmental Permit for waste handling and disposal; and

Any accident or loss involving hazardous or potentially hazardous waste materials. Waste Materials Record Books may be inspected at any time as part of environmental audits. Source: ArcelorMittal Liberia.




1.7 Standard for Operation of Airstrips for Fixed Wing Aircraft The airstrips shall be operated in accordance with the rules of the Liberian Civil Aviation Authority (LCAA). The company is to agree with the LCAA a set of protocols, procedures and ground rules. Visibility, cloud height, wind and rainfall limits shall be followed as agreed with the LCAA. An Airstrip Manager and Deputy Manager shall be appointed by the company at each site. These individuals may have other roles within the company, but are required to authorise the use of the airstrip before any aircraft movement may take place. Either the manager or their deputy must be present on the site throughout any operations. The airstrips shall be used for daytime operations only. This means that there will be flights only between 0700 and 1800 hours. Flights shall be avoided on Sundays to the greatest extent possible. Before any aircraft movement can be undertaken, the following activities must be fulfilled.

1. The Airstrip Manager or Deputy Manager must check that the visibility, cloud height, wind and likely rain patterns are all within the limits agreed with the LCAA. These data shall be noted and communicated to the pilots before approving any aircraft movement.

2. Once the operating conditions have been approved as acceptable, the airstrip can be prepared for use.

3. A security team must be deployed to the airstrip. This team shall be responsible for clearing any people and animals from the airstrip and securing all barriers to prevent any entrance. Once this has been done, the Security Supervisor must report to the Airstrip Manager or Deputy Manager that the security measures are complete.

4. The fire crew must be deployed to the airstrip. Once this has been done, the Fire Supervisor must report to the Airstrip Manager or Deputy Manager that the fire readiness measures are complete.

5. An ambulance and paramedics must be deployed to the airstrip. Once this has been done, the senior Paramedic present must report to the Airstrip Manager or Deputy Manager that the medical readiness measures are complete.

6. The Airstrip Manager or Deputy Manager must ensure that all fuel handling personnel, passengers and baggage staff are present and correct in the designated safe areas. Baggage must be weighed and the passenger and cargo manifest checked and agreed with the pilot or aircraft operator‟s representative.

7. Any passenger or cargo security measures required by the company‟s Security Manager, the LCAA or the Liberian National Police (LNP) must be completed and reported by the appropriate responsible officer to the Airstrip Manager or Deputy Manager.

8. Aircraft movements can then be authorised by the Airstrip Manager or Deputy Manager.

9. A warning siren will be sounded five minutes before the landing or taking off of an aircraft.

10. The Airstrip Manager or Deputy Manager shall declare that aircraft movements are complete either when an arriving aircraft has parked and stopped its engines, or when five minutes has elapsed after the departure of an aircraft. At this time a siren shall be sounded again, and the security, fire and medical teams can stand down unless instructed by the Airstrip Manager or Deputy Manager to remain on stand-by for a further aircraft movement.

This standard may be modified following further engineering and certification work in the event that the airstrips are upgraded to a higher operational category. [Source: ArcelorMittal Liberia]




2. FOREST PROTECTION STANDARDS

2.1 Standard for Bush Clearance, Tree Felling and Use of Chainsaws Overview This standard provides guidance on the clearing of bush and trees. It is assumed that all larger plants will normally be cleared using chainsaws, and detailed guidance is given on this aspect. General The clearance of vegetation is permitted in certain areas in preparation of earthworks or for access to facilities. The swathe that may be cut is limited to the minimum required for the purpose in hand. In the case of roads, the swathe is to cover only the width of the road and its immediate drainage works. No vegetation may be cleared unless it is explicitly covered in the conditions of the relevant Environmental Permit. This may be allowed for in the ESIA Report, the Project Brief or the Environmental Management Plan. Vegetation shall normally be cleared only by cutting. The use of fire, herbicides or other poisons is not permitted. The use of earth-moving equipment is permitted only if the works require the grubbing out of plant roots. Otherwise all roots and stumps shall be left in the ground. Vegetation may be cut using either hand or machine tools. In all cases, appropriate personal protective equipment shall be used by the workers involved. The vegetative debris shall be laid down to rot, thereby acting as mulch and helping to mitigate damage to the soil. Where clearance is for construction, then the debris may be removed to a suitable approved dump site. If a bare sloping area is created by vegetation clearance, then appropriate erosion control measures shall be implemented. Separate standards are provided to cover this. No tree of more than five metres in height should be felled using a standard bulldozer or excavator. An axe or saw should be used. Chainsaws should only be used by trained operators (see guidance below). Even with manual saws, trees taller than 8 metres in height should be felled only by experienced workers. Where specialist large machines (see below) are available and slopes are less than 20 degrees and tree roots are to be grubbed out, then trees more than five metres in height may be felled by machine. However, no tree greater than 25 metres in height may be felled except by use of a chainsaw. Pre-felling safeguards Before any tree felling starts on a worksite:

contact the owners of any overhead power lines within a distance equal to twice the height of any tree to be felled to discuss whether the lines need to be lowered or made dead;

check whether there are underground services such as power cables or water pipes which could be damaged when the tree strikes the ground;

if there are roads or public rights of way within a distance equal to twice the height of the tree to be felled, ensure that road users and members of the public do not enter the danger zone – you may need to arrange warning notices, diversions or traffic control;

do not start work until agreement has been reached and all necessary precautions have been taken.

Safe tree felling using large machines Circumstances. Where it is intended that tree roots will be grubbed out as part of a land clearance and earthworks operation, trees up to 25 metres in height may be felled using specialist machines.




This option may only be attempted in gently rolling and non-swampy terrain. It must not be undertaken if slopes exceed 20 degrees in any part of the site to be cleared. Equipment. The specialist equipment that may be used for this operation must fall into one of the three following categories.

Large bulldozers fitted with heavy duty protection for the engine and operator‟s cab, and specifically modified for use in logging operations.

Large excavators with extended booms that are fitted with heavy duty protection all around the operator‟s cab.

Tree harvesting machines, which usually have a cutting blade on a grab arm, and are fitted with heavy duty protection all around the operator‟s cab.

Normal contractors‟ earth-moving bulldozers and excavators should never be used for felling trees more than five metres in height, even if they have safety cages. Site evacuation. Tree felling using large machines is an extremely dangerous operation. The site supervisor must ensure that the site to be cleared plus a safety zone of 100 metres all around has been evacuated and remains clear of people throughout the operation. The machine operator must be in radio contact with the site supervisor. No one is to be allowed into the cleared operational area until the machine operator has been contacted and has verified that he has stopped working and is ready for a person to approach. Under no circumstances are machines to be permitted to fell trees any closer than 100 metres to each other. Tree felling. The machine operator should push the tree over according to the best practice method for his particular machine. If a tree cannot be felled by the machine, then it should be left until it can be felled using a chainsaw. Particular care must be taken with springy trunks and hung-up trees. Once one or more trees have been felled, the machine should be stopped to allow a chainsaw operator to de-limb and cross-cut them to allow the timber to be removed from the site for use as agreed with the Company and the local community. Safe tree felling procedure using chainsaws Timing. Only start to fell a tree when there is adequate time to do so safely. Tree felling is inherently dangerous and should not be rushed. Once cutting is started, the tree must not be left alone until it has been safely felled and the branches trimmed out. Condition of the tree. Check if the butt of the tree is affected by rot. In addition, be especially careful to check for dead or broken crowns and branches which might fall during the operation. Check both the tree to be felled and those nearby which might be hit by the tree being felled. Line of fall. Assess what could affect the direction of fall, such as wind conditions and whether the tree is leaning, has uneven growth or branches which could foul other trees. A tree should always be felled along its natural line of fall. Attempts to fell it in another direction should be aided by equipment such as wedges for small trees and winches for larger trees (see below). Clearing the area. The area around the base of a tree should be cleared of vegetation for a minimum of two to three metres. An escape route should be made clear on the side of the tree where the operator will be when making the final cut. The escape route should be in the 45-degree quadrant between 90 and 135 degrees from the line of expected fall. Any tripping hazards should be removed.




Where to cut. Trees should always be cut as low to the ground as possible. No tree should be cut more than 500 mm above the level of the surrounding ground. This might require the removal of buttresses and trimming of a splayed tree trunk to form a regular cylinder. Dip, scarf or wedge cut. As low as possible, make a horizontal cut one third of the way through the tree on the side where it is expected to fall. Then make another cut, cutting down at 15 to 30 degrees from the horizontal, to remove a wedge of wood from above the first cut. Clean out the dip to ensure that an even, open wedge is formed, facing exactly the direction of felling. Final cut or backcut. Do a final check that the area all around is clear and that there is no danger of anyone entering the felling zone. Make the final cut 50 to 75 mm above the base of the dip cut, starting on the opposite side of the tree and working towards the dip. Keep it horizontal and keep the cut face parallel to the thin end of the dip cut. As the cut is approaching the dip, look closely for signs of movement in the trunk of the tree. Once it starts to fall, remove the saw from the cut and move away from the tree without rushing. You should normally move at rightangles to the direction of fall in case the butt jumps backwards off the stump. Keep watching the tree in case it twists or starts to fall in an unexpected direction.

Trimming out. Once the tree is down, the branches should be trimmed out to ensure that the trunk is lying along the ground and that it cannot roll over. Especial care is needed in cutting the branched on the underneath of the lying trunk, as these will be under tension. Additional tools and equipment. Operators may need to use aid tools such as alloy or plastic wedges, a breaking bar, a cant hook, a winch, or high-lift wedges and a sledgehammer. They should understand when it is important to use additional equipment, and it is the manager‟s responsibility to make sure operators have the right equipment available and the skills to use it correctly. This is in any situation where there is any doubt as to whether a tree can be felled safely using only a saw. Additional equipment introduces different forces, however, and always complicates the process of felling. Hung-up trees. If a tree is likely to become hung-up on another during felling, operators will need to have the knowledge and the equipment to bring the hung-up tree down safely. Dealing with leaning trees or wind-blown trees also requires special skills. Use of chainsaws The following part of this standard provides guidelines on using portable, hand-held, petrol-engine chainsaws for clearing bush and felling trees. It is aimed at both operators and those who control the use of work equipment, and includes basic information on safe working practices which operators should follow.




Fitness to operate a chainsaw To use a chainsaw safely, the operator needs to be reasonably fit, both physically and mentally. People with disabilities need not necessarily be excluded from work with chainsaws, but medical advice may restrict the tasks they can do and require increased supervision. It is recommended that workers undertake pre-employment screening when selecting chainsaw operators. Seek further medical advice if prospective operators have any condition affecting:

mobility (e.g. arthritis, stroke);

alertness (e.g. diabetes or alcohol/drug dependency);

physical strength (e.g. heart conditions);

vision (which cannot be corrected by glasses or contact lenses);

manual dexterity/grip strength (e.g. vibration white finger);

balance (e.g. vertigo or giddiness). Operators should inform their supervisor when they are taking prescribed medication. Check with the operator‟s medical practitioner if the medication can affect a person‟s ability to operate a chainsaw safely. Health risks Chainsaws expose operators to high levels of noise and hand-arm vibration which can lead to hearing loss and conditions such as vibration white finger. These risks can be controlled by good management practice including:

purchasing policies for low-noise/low-vibration chainsaws (e.g. with anti-vibration mounts and heated handles);

providing suitable hearing protection;

proper maintenance schedules for chainsaws and protective equipment;

giving information and training to operators on the health risks associated with chainsaws and use of personal protective equipment (PPE) etc.

Encourage existing chainsaw operators to report any signs or symptoms which may affect their ability to use a chainsaw safely or may indicate adverse health effects from noise and/or vibration. Training and competence: all chainsaw use Chainsaws are potentially dangerous machines which can cause major injury if used by untrained people. Anyone who uses a chainsaw at work should have received adequate training and be competent in using a chainsaw for that type of work. The training should include:

dangers arising from the chainsaw itself;

dangers arising from the task for which the chainsaw is to be used; and

the precautions to control these dangers, including relevant legal requirements. Training for use of chainsaws in tree work All workers who use a chainsaw should be competent to do so. Before using a chainsaw to carry out work on or in a tree, a worker should have received appropriate training and obtained a relevant certificate of competence, unless they are undergoing such training and are adequately supervised. This means everyone working with chainsaws on or in trees should hold such a certificate or award. Training provision Training should be carried out by specialist instructors at organised training courses. Where training is being consolidated through workplace-based experience, the trainee should be supervised by a person competent in the use of a chainsaw for the work being done by the trainee and who holds the relevant competence certificate or award.




It is recommended that all chainsaw operators have regular refresher training to ensure they work to industry best practice and maintain their levels of competence. The suggested intervals for such training are:

occasional users – every two to three years;

full-time users – every five years. Supervision of trainees at training courses and training at work Instructors need to organise training to maintain a suitable ratio of trainees to instructors. Factors to be considered include:

the level of experience of trainees;

the content of the training;

the location and terrain where the training is being carried out. Selecting a chainsaw There are two basic designs of chainsaw – „rear-handled‟ and „top-handled‟. Rear-handled chainsaws. These have the rear handle projecting from the back of the saw. They are designed always to be gripped with both hands, with the right hand on the rear handle. Select chainsaws which will be suitable for the intended work. It may be necessary to have a range of saws with different guide bar lengths available. As a general rule, choose a chainsaw with the shortest guide bar suitable for the work. Training in how to use chainsaws will identify the type and size of saw most suited to a range of operations. Top-handled chainsaws. These saws have the rear handle over the top of the engine. They are only suitable for use off the ground by trained competent arboriculturists. They are not designed for use on the ground or as a substitute for small, rear-handled chainsaws. Maintaining a chainsaw Proper maintenance is essential for safe use and protection against ill health from excessive noise and vibration. The saw must be maintained in its manufactured condition with all the safety devices in efficient working order and all guards in place. It should be regularly serviced by someone who is competent to do the job. Operators need to be trained in the correct chain-sharpening techniques and chain and guide bar maintenance to keep the saw in safe working condition. Operators should report any damage or excessive wear from daily checks on the following:

on/off switch;

chain brake;

chain catcher;

silencer;

guide bar, drive sprocket and chain links;

side plate, front and rear hand guards;

anti-vibration mounts;

starting cord for correct tension.




Features of a good chainsaw

Personal protective equipment Suitable personal protective equipment (PPE) should always be worn, no matter how small the job. Protective clothing must comply with high international standards to provide a consistent level of resistance to chainsaw cut-through. Other clothing worn with the PPE should be close fitting and non-snagging. However, note that no protective equipment can ensure 100% protection against cutting by a hand-held chainsaw. The following PPE are obligatory:

Safety helmet

Hearing protection;

Eye protection – mesh visors or safety glasses;

Gloves;

Leg protection;

Chainsaw boots – knee-length safety boots with steel shin guards and toe caps. In addition, upper body protection (i.e. a cut-proof chainsaw jacket) is recommended. Lone working Avoid working alone with a chainsaw. Where this is not possible, establish procedures to raise the alarm if something goes wrong. These may include:

regular contact with others using either a radio or telephone;

someone regularly visiting the worksite;

carrying a whistle to raise the alarm;

checks to ensure operators return to base or home at an agreed time. First aid Anyone working with chainsaws needs to understand how to control major bleeding and to deal with crush injuries, so it is recommended that operators hold an emergency first-aid certificate. Make sure operators always carry a personal first-aid kit (incorporating a large wound dressing) with them and have reasonable access to a more comprehensive kit.




Working with chainsaws: fuelling and lubrication Make sure petrol containers are in good condition and clearly labelled, with securely fitting caps. Use containers which are specially designed for chainsaw fuelling and lubrication. Fit an auto-filler spout to the outlet of a petrol container to reduce the risk of spillage from over-filling. Operators should:

avoid getting dirt in the fuel system (this may cause the chainsaw to be unreliable);

securely replace all filler caps immediately after fuelling/oiling;

wipe up any spilt petrol/oil;

during starting and use, keep fuel containers well away from fires and other sources of ignition, including the saw itself (at least 4 m is recommended).

Do not allow operators to use discarded engine oil as a chain lubricant – it is a very poor lubricant and may cause cancer if it is in regular contact with an operator‟s skin. Pre-use checks and starting a chainsaw When preparing to use a chainsaw, operators should check:

all nuts, screws etc are tight;

the saw chain is correctly tensioned;

the throttle cannot be squeezed unless the throttle lock-out is pressed; and

they are wearing the correct PPE. When starting the saw, operators should maintain a safe working distance from other people and ensure the saw chain is clear of obstructions. When starting a chainsaw with a cold engine, operators should:

place the saw on level ground;

secure the saw firmly, e.g. put a foot on the rear-handle base plate and a hand on the front handle;

set the controls as recommended by the manufacturer;

pull the starter cord firmly. Once the saw has started, operators should rev the throttle to warm up the engine and check:

the saw chain stops moving when the engine revs return to idle;

the chain brake is effective when applied at maximum revs or according to the manufacturer‟s specification;

the engine continues to run when the saw is turned through 90° in any direction;

the stop switch works correctly;

lubrication to the guide bar and chain is working properly. These checks should be repeated at regular intervals throughout the day. When starting a chainsaw with a hot engine, operators may use the same method as above. Alternatively, they can grip the rear handle firmly between the knees and the front handle with their left hand, pulling the starter with their right hand. Once the saw is running, operators should apply the chain brake before moving off with the saw. Most modern chainsaws will allow hot starting with the chain brake applied. Kickback Kickback is the sudden uncontrolled upward and backward movement of the chain and guide bar towards the operator. This can happen when the saw chain at the nose of the guide bar hits an object. Kickback is responsible for a significant proportion of chainsaw accidents, many of which are to the face and parts of the upper body where it is difficult to provide protection. A properly maintained chain brake and use of low-kickback chains (safety chains) reduces the effect, but cannot entirely prevent it.




Make sure operators use the saw in a way which avoids kickback by:

not allowing the nose of the guide bar to accidentally come into contact with any obstruction, e.g. branches, logs, stumps;

not over-reaching;

keeping the saw below chest height;

keeping the thumb of the left hand around the back of the front handle;

using the appropriate chain speed for the material being cut. Using the chainsaw Whatever the job, check the worksite thoroughly to identify any potential hazards. This is particularly important when carrying out felling or demolition work. Wherever possible maintain a clear working area on the site. For any work with a chainsaw ensure:

the risks from the work have been assessed and controlled;

the operator is competent to do the job;

the operator wears the appropriate PPE;

the operator either stops the engine or applies the chain brake when not cutting with the saw. The risks from manual handling must be considered: operators can suffer serious back injuries from handling timber incorrectly. Training in good manual handling techniques and using handling aids and appropriate tools should reduce the risk of these injuries. Working with chainsaws off the ground Chainsaws should not be used off the ground unless the operator has been adequately trained in safe working techniques. Always use a purpose-built platform. Ensure operators have received adequate training in the safe operation of the platform and safe use of a chainsaw from a work platform. Avoid using a chainsaw from a ladder. Chainsaws require both hands to be operated safely: work on a ladder requires one hand to hold the ladder to maintain a steady working position. Work from a ladder should only be done by an arboriculturist trained in and equipped for tree climbing. When operating from a ladder, the climber must establish an independent anchor to the tree using a rope and harness and obtain a stable and secure work position. Using a chainsaw from a rope and harness requires special skills. This should only be done by people who have obtained the relevant competence certificate for arboricultural work. Source: ArcelorMittal Liberia, incorporating UK Health and Safety Executive Guidelines.




2.2 Standard for Bushmeat Hunting, Dealing, Transporting and Use Responsibility It is the responsibility of all staff of the Company and its Contractors to uphold the rules regarding bushmeat. Any person having knowledge of another person infringing these rules is required to report the matter immediately to the ArcelorMittal Liberia Senior Manager responsible for that part of the Company‟s operations. Statutory regulations The Draft Hunting Regulations of Liberia, drawn up under the National Forestry Law (2006) proposed the following provisions.

1 A person with a valid hunting licence issued by the Forestry Development Authority may hunt during the Open Hunting Season, from 1 October to 31 March.

2 No hunter may take more than 3 wild animals per week. 3 No bush meat trader may carry more than 20 pieces (quarters) of meat at a time.

Permitted bushmeat No person is permitted to hunt for bushmeat on Company property or within designated mine and industrial areas, including the railway right-of-way. No staff member of the Company or its Contractors who is also a licensed hunter is permitted to hunt during working hours or on Company property or within designated mine and industrial areas, including the railway right-of-way. Any non-local staff member of the Company or its Contractors who is found to be hunting bushmeat without a licence or to be purchasing, dealing in, transporting or consuming bushmeat of permitted species obtained from a non-licensed hunter may be reported to the civil authorities. Local staff of the Company and Contractors will be interviewed to determine the circumstances, and action taken as deemed appropriate. The legally permitted take per licensed hunter on non-Company land of common non-protected species is as follows.

Animal Number per week

Black deer (black duiker) 2

Blue tongue (Maxwell‟s duiker) 2

Red deer (bush buck) 1

Black backed (bay duiker) 2

Porcupine (crested porcupine) 3

Hedge hog (brush-tailed porcupine) 3

Ground hog (cane rat) 3

Opassum (giant rat) 3

Ground squirrel 3




Prohibited bushmeat The following animals are fully protected and may not be hunted at all. All Company staff and Contractors‟ employees are absolutely forbidden from hunting, dealing in, transporting and using these animals or any products associated with them (including eggs). Baboon (West African chimpanzee) Ant bear (tree pangolin) King monkey (black and white colobus) Sea cow (West African manatee) Red monkey (red colobus) Alligator (Nile crocodile) Olive colobus Alligator (African slender-snouted crocodile) Diana monkey Crocodile (African dwarf crocodile) Jackal (sooty mangabey) Boa constrictor (rock python) Lesser galago Boa constrictor (ball python) Clawless otter All sea turtles Bosman‟s potto All birds of prey (ospreys, falcons, buzzards, kestrels) Forest elephant All hornbills Elk deer (bongo) Bare-headed rockfowl Bush galago (demidoff‟s dwarf galago) Grey-necked rockfowl Black back (Ogilby‟s duiker) White-necked rockfowl White antelope (Jentink‟s duiker) Guineafowl (white-breasted guineafowl) Marking deer (zebra duiker) Little egret Water deer (water chevrotain) Cattle egret Water cow (pygmy hippopotamus) Secretary bird Leopard Jabiru or saddle bill Liberian mongoose Sacred ibis Bush cat (golden cat) Hadada Big ant bear (giant pangolin) Goliath heron Ant bear (long-tailed pangolin) Partially protected animals The following animals are fully protected between 1

st August and 1

st December in any year and may

not be hunted during this period. The young and adults with young of these species are fully protected at all times. All Company staff and Contractors‟ employees are absolutely forbidden from hunting, dealing in, transporting and using these animals or any products associated with them (including eggs) except in accordance with these rules. Mona monkey Serval Lesser spot-nosed monkey African civet White coloured mangabey Two spotted palm civet Bush cow (forest buffalo) African python Yellow back (yellow-backed duiker) All turacos Tricky jack (royal antelope) All bushfowl Bay duiker Stone partridge Red hog (red river hog) All parrots Black hog (giant forest hog) All doves and pigeons Forest genet Hartlaub‟s duck Bush genet White faced duck Wild cat Fulvous duck Gambian mongoose Pygmy goose Side striped jackal Knob billed goose Lynx Non-local staff of the Company and Contractors found to be engaged in any form of dealings with these animals during working hours or on company property will have their contract terminated and be reported to the civil authorities. Local staff of the Company and Contractors will be interviewed to determine the circumstances, and action taken as deemed appropriate. The Company may report to




the civil authorities any person found to be engaged in any form of dealings with these animals outside working hours or company property. Source: ArcelorMittal Liberia based on FDA draft hunting regulations and Regulation 25 of the Forest reform Law (2006).

2.3 Standard for Clearance of Caves, Adits and Tunnels The Nimba mountains contain at least 31 species of bats, including at least eight that are globally threatened. Many of these are cave-dwelling, and inhabit natural caves, former LAMCO adits, and tunnels in rock and concrete structures. Some colonies of bats number in the hundreds in a single location. Existing adits are known to be in dangerous conditions. No one is permitted to enter them unless they have been checked and certified safe b a suitably experienced and qualified underground mining engineer. All project activities that disturb the environment of caves, adits and tunnels must be preceded by a full survey of the site. Surveys are to be conducted by an expert on chiroptera biology. If bats are found, then they must be humanely trans-located before any physical work is started in the site (i.e. anything other than surveying and non-destructive prospecting). Trans-location is also to be undertaken by an expert on chiroptera biology. It is normally done by netting the bats at the entrance to the site. They will then be taken to an equivalent habitat for release, and kept confined for a few days until they are habituated to the new location. After the bats have been removed from a site, the entrance must be fitted with an excluder screen (i.e. a screen that allows bats to come out, but not to go back in) for a few weeks. This will ensure that any bats that have been missed, or other bats looking for a roosting site, do not enter the site. After this, a complete screen of fine wire mesh must be used to prevent bats from entering the site. The screen is to be kept in place from one hour before sunset until one hour after sunrise until such time as the works are complete and the cave, adit or tunnel has been permanently abandoned by the project. Source: ArcelorMittal Liberia.




3. COMMUNITY RELATIONS STANDARDS

3.1 Standard for Community Engagement This Standard provides local-specific guidance conforming to corporate level policy on interaction with communities. It must be followed to ensure compliance with ArcelorMittal policy and Liberian laws, current socially acceptable practice as well as industry best-practice (as defined in the IFC guidelines). Principles Communities will be included in the consultation and participation process throughout the project life in all parts of the concession areas, be treated with respect and engaged with according to current social practice. Scope This Standard is to assist the Community Liaison Officer, Contractors, Sub-contractors and others recruited individually to inform, communicate and negotiate with communities and individuals in a culturally acceptable manner. The communication process covers issues and items of interest to both sides to promote awareness, agreement on project modalities and needs, transparency of actions and enable smooth and appropriate mitigation measures to be identified and implemented. This protocol is designed to apply to all work in the project concession areas. Guidelines Communities have the right to be informed and consulted about project activities which affect their land, assets, access to natural resources, the wider environment and household livelihoods. Traditional patterns of social etiquette exist and must be respected. Cultural behaviour in Liberia respects age and experience, is communal in that elders and leaders are expected to speak on behalf of individuals in the first instance and that the information dissemination process is hierarchical and pyramidal with low status individuals being approached or informed last. The local administrative hierarchy through the chiefdom system is to be used as the gateway to community discussions, Chiefs are to be informed and met prior to individual discussions. There is great emphasis on communal agreement, especially on access to resources and land allocation.

Procedures

Step Action Notes

1 Contractor defines contact requirements with communities and schedules a programme of community consultation visits. Use Standard for Identification of Land Access and Community Interaction.

Precise map data are required for all activities and locations.

2 Discussion with CLO to identify previous contact points, key individuals and local relations

Important to include County Administration as well as local chiefs etc. and to maintain inclusion/ consultation




Step Action Notes

3 Community sensitisation is undertaken to inform communities about projected visits. This is through a visit to the local chief to request a meeting and to agree meeting logistics. Use of the clan boundaries to define meeting groups of chiefs etc. CLO to introduce all parties, agree dates and subjects to be discussed. See Company Policy on Community Consultation.

CLO to assist in initiating community meetings with Contractor and to use standardised process. Contractor to provide information for and participate in all media information programme and participate in LCFs as required. Copies of minutes to community leaders, Company, Contractors and local administration as required. CLO to keep records of agreements, actions and outcomes.

4 Public information campaign activated in relevant areas on appropriate topics and media.

Use suitable media for the subject matter, use materials for literate and non-literate people, ensure women, elderly, disabled get properly informed, consider regular radio spots and use notice boards.

5 Local Consultative Forums programme adapted where required. See Company Local Consultative Forum Process.

Adapt LCF agenda.

6 Community meetings held.

CLO/ Contractor to hand over a written summary of information to be discussed.

Minutes of meetings taken and copies disbursed as soon after meeting as possible.

Company to inform Contractor and CLO

7 Meetings with affected and concerned individuals, resolution of grievances.

Negotiations and payments to be made in public at open meetings as far as is possible and recorded in writing and photographed.

8 Monitoring of Contractor activity by local people.

Company to hire and deploy monitors at its discretion.

Source: ArcelorMittal Liberia.

3.2 Standard for Identification of Land Access and Community Interaction This Standard provides local-specific guidance conforming to corporate level policy on interaction with communities. It must be followed to ensure compliance with ArcelorMittal policy and Liberian laws, current socially acceptable practice as well as industry best-practice (as defined in the IFC guidelines). Principles Interaction with communities must be identified and planned, so that social impacts can be identified, environmental permission obtained and agreements made between the Company and the communities before site works are started. Scope This Standard is intended to assist Contractors, Sub-contractors and others recruited individually to:

Identify the community interaction needs of each component of the work they intend to undertake;

Build into work schedules the time required to implement community interaction identified; and

Provide sufficient input to the environmental permit application to enable permission to proceed to be given.




Guidelines All work in the concession areas will have impacts on the wider community members owning or with communal access rights or squatter rights to the land or assets needed for the project. The communities must therefore:

Be informed about the likely scale of impacts;

Have losses fairly assessed; and

Be paid compensation or be assisted to relocate and restore livelihoods. Under Liberian law, acquisition and payment of compensation can be made by the Company or be devolved to a Contractor, but land ownership is held by the Government. Appropriate mitigation measures need to be in place, agreed and funded by the Company. This process must be completed before site access and work can be permitted, and consequently it has time delay implications for scheduling work. Contractor performance will be monitored according to the Company‟s Social Monitoring Plan. Contractors are expected to identify the potential for community impacts at the outset by clearly identifying activities, their locations, land take boundaries and resource needs. Use of or loss of community assets requires the payment of compensation to those losing usage or suffering other loss, and therefore it is important to clarify exactly what land and assets are needed and to programme their acquisition into work programmes. This information will be used to undertake social impact assessment by Company, to obtain environmental clearance from the Liberian government and to implement mitigation measures before contractors can proceed. Procedures

Step Contractor Action Notes

1 Notify the Community Liaison Unit at the outline design stage, so that a preliminary assessment can be made of the scale of the work required, for planning and budgeting.

Provide the Community Liaison Unit with a map to facilitate this process.

2 Identify Activities in contract:

List all work programme activities in detail by task and site;

List the location of proposed work sites in detail;

Provide plotted map co-ordinates of sites, access routes, etc.

3 For each task, identify sites for:

Sites of work camps,

Stores,

Depots,

Workshops,

Ancillary activities.

4 Identify sources of:

Food,

Fuel or power,

Forest resources,

Clean water,

Sanitation disposal,

Waste and refuse management.




Step Contractor Action Notes

5 Identify communities and households:

owning or using the areas that are required, or

as potential sources of unskilled or semi-skilled labour, or

which can provide support resources or services. Draw boundaries on a map and discuss with the CLO.

CLO to check with communities who owns/ uses/ accesses which assets.

6 Information has to be included into the environmental permit application or environmental management plan, or both.

Documentation must be provided to identify all land use and resource sources.

7 Application for environmental permit is to be submitted by the Company and agreed by the EPA.

No activity can be undertaken until permission is given and mitigation measures implemented.

8 Community sensitisation and a public information programme. Use the Standard for Community Engagement.

Contractor to liaise with CLO to agree information to be disseminated.

9 Community negotiations for access and compensation where appropriate. Use the Standard for Acquiring Land or Other Assets.

Mitigation measures will have to be planned in detail well in advance of works.

10 Livelihood restoration. Ongoing programmes of income and livelihood restoration are required to be in place.

11 Access to land and resources is permitted only after payment has been made and relocation achieved.

The Resettlement Manager must sign to certify that this has been done.

12 Use Standard for Employment of Temporary Construction Labour through the CLO to identify workers and to ensure a fair distribution of work among affected communities.


3.3 Standard for Acquiring Land and Other Assets This Standard provides local-specific guidance conforming to corporate level policy on interaction with communities. It must be followed to ensure compliance with ArcelorMittal policy and Liberian laws, current socially acceptable practice as well as industry best-practice (as defined in the IFC guidelines). It provides a very brief overview of the Company‟s approach to resettlement, as described in detail in the Resettlement Manual. Objectives To comply with ArcelorMittal policy and Liberian laws as well as industry best practice (as defined in the IFC guidelines). Principles Land potentially used or owned by communities cannot be accessed until ownership and use has been researched and clarified, and full and fair compensation has been made for losses. Scope This Standard is to assist the Resettlement Team or Community Liaison Unit to negotiate for and make payment or other forms of compensation to communities and individuals for loss of land, assets,




usage rights or access routes on communities, and to design and implement mitigation measures. This Standard applies to all work in the project concession areas. Guidelines Whilst ArcelorMittal has the right to use the land in the concession area, it is largely populated. People have legal title to parts of the area and very many communities have communal or traditional customary rights to use of the land and resources in the area. Squatters and displaced persons have equal right to compensation. Communities have the right to be informed and consulted about asset acquisition and to be treated fairly and considerately. Under Liberian law and International Finance Corporation guidelines, communities and individuals are entitled to full and fair compensation at market prices for all losses incurred, and for income and livelihood restoration to at least previous standards. Compensation has to have been paid, relocation must have been achieved and livelihood restoration must be in progress before access by the Company or a Contractor is allowed. Community and household interviews are required to assess losses and impacts on livelihoods, and these take some time to undertake. Under Liberian law, acquisition and payment of compensation can be made by the Company or can be delegated to an agent, but land ownership is devolved back to the Government. The procedures below are required to be followed. A single Company resettlement and compensation policy applies throughout the concession areas, as defined in the Resettlement Manual. Appropriate mitigation measures need to be in place, agreed and funded by the Company before work can start in areas where people are adversely affected. Procedures

Step Action Notes

1 Contractor asset requirements are identified.

Produce precise map data for all activities and locations.

2 Compensation process discussed and agreed with County Land Commissioner.

It is important to include local administration and to maintain inclusion and consultation

3 Community sensitisation is undertaken to make communities aware of potential land and asset needs. A public information campaign is activated in relevant areas. Local Consultative Forums are set up.

CLO to initiate and to use standardised process. Contractor to provide information for and participate in all media information programmes and LCFs, as required

4 Community and household surveys of asset loss and livelihood sources are undertaken – the needs and rights of men and women are assessed individually within households; the needs of the elderly and disabled are also to be addressed individually.

Household interviews and community surveys to be undertaken as defined by the Company‟s Resettlement Manual. This activity can be sub-contracted to an authorised NGO. Loss of assets affect men and women separately, therefore interviews at household level require multiple approaches.




Step Action Notes

5 Compensation values are negotiated through community meetings with local chiefs, and appropriate mitigation programmes are agreed

Entitlement matrix is provided. Any individual negotiations outside of this which change the provisions in the matrix must be agreed with the CLO and the affected person.

6 Agreement through the environmental permitting process to continue with land, asset and resource acquisition.

Company to apply and inform Contractor and CLO.

7 Payment of cash compensation or implementation of land for land etc.

Payments to be made in public at open meetings and recorded in writing with signatures, and the recipient photographed with the compensation or meeting record confirming alternative compensation.

8 Livelihood restoration activities are implemented.

Ongoing programmes of income and livelihood restoration are required to be in place. An NGO can be hired to undertake any such work.

9 Access to land and resources is permitted only after payment has been made and relocation achieved.

Work can commence after all compensation is verified as paid and alternatives are in place. The Resettlement Manager must sign to certify that this has been done.

10 Monitoring of Contractor activity and of compensation management etc by local people.

At its discretion, the Company may hire and deploy monitors to oversee impact mitigation and to assist CLO.


3.4 Standard for Employment of Temporary Construction Labour This standard is intended as local-specific guidance conforming to corporate level policy on working conditions. It should also be guided by other EMP recommendations. Objectives To comply with ArcelorMittal policy and Liberian Labour Law and other relevant legislation as well as industry best-practice (as defined in the International Finance Corporation guidelines and in particular Performance Standard 2 pertaining to Labour and Working Conditions). Principles Recruitment will be based on the principle of equal opportunity except in that priority will be given to individuals from communities in the vicinity of the work sites. In accordance with the ILO and UN Declarations, ArcelorMittal will not use forced labour, bonded labour or child labour (under 16 years). Scope This protocol is intended to cover the recruitment, hiring, employment and working conditions relating to ArcelorMittal contractors requiring non-permanent manual or low-skilled labour for construction or other works. It is designed specifically for construction works but may, with adaptation, be extended to permanent labour.




Procedures

Step Action Notes Responsibility

1 Identify Labour Requirements Checklist: 1. Type of work/skills 2. Number of workers 3. Expected duration of work 4. Work hours/ days week 5. Location of work

Need sufficient warning of when and where they are required

Contractor to provide to CLO

2 Identify Potential Labour Sources

The Resettlement Plan may prioritise labour source communities (e.g. all households losing a high proportion of their land are eligible for a minimum of one year‟s unskilled employment).

Contractor to inform CLO

3 Discuss Labour Needs in source communities May need to inform relevant County Labour Commissioners Use Protocol for Community Engagement

CLO to lead community discussions about the distribution of work Need to give advance warning and from the outset be clear about the work involved, location of work, work days, expected duration and methods of remuneration. Selection policy to be outlined. Include trial period, dismissal, illness and grievance procedures.

CLO

4 Labour Recruitment & Contracting

Documentation according to Liberian Labour Law provisions and records available for inspection by Government Inspectors. Contractor to register all workers with Ministry of Labour and to get Social Security Number.

Contractor to recruit, CLO to enforce process

5 Training requirements -1 Technical -2 H&S -3 HIV/AIDS -4 Health and Sanitation

Technical training on the job. Health & Safety including the need for and use of personal protective equipment. Also HIV/AIDS and basic health and sanitation education (free from ArcelorMittal hospitals).

Contractor, assisted by ArcelorMittal where appropriate

6 Work & Welfare conditions Both for accident prevention and response

Minimum set wage to be paid. Ensuring H&S at work. Third Party employee liability insurance. Safety equipment. Health services entitlement (workers have the right to health care at the Contractor‟s expense). Provision of first aid boxes on site. First Aid training for supervisors. Accident records. In work camps, check on quality/ quantity of food, water/ shelter/ clean water and sanitation provision.

Contractor, enforced by ArcelorMittal where appropriate

7 Payment Use of Labour cards and storage of paid up labour cards. Payment to be at least equal to or above the Liberian minimum wage and enable the worker‟s household to live above the poverty level of US$1/ day/capita. Payment at fortnight intervals as a maximum. Ensure transparency of payments. Provision for advances. Payment in cash.

Contractor, enforced by ArcelorMittal where appropriate

8 Termination Records of employee and recommendation for future work/ references for work elsewhere.





3.5 Standard for Staff Behaviour

CODE OF PRACTICE FOR BEHAVIOUR AT ARCELORMITTAL TOWNSHIPS Requirement ArcelorMittal and all contractors‟ managers must ensure that their staff uphold this Code of Practice at all times. Introduction ArcelorMittal and its contractors are guests of the communities in which they are living and working. They must fit with local customs and laws. Many staff are from other parts of Liberia and from other countries, and some will be in the company townships for only short periods. Cultural differences and poor behaviour of workers can lead to tension between local communities and workers housed in townships and camps. This Code of Practice demands moderate and tolerant behaviour of all people associated with ArcelorMittal and its company townships. Code of Conduct for Behaviour ArcelorMittal requires that all its employees, the employees of its contractors and visitors to townships, camps and work sites, abide by the following rules to ensure harmonious co-existence.

Adhere to Liberian laws and regulations.

Respect local communities, religions and customs.

Respect all groups within the towns and camps.

Behave in a moderate, modest and tolerant manner.

Avoid causing disturbance or undertaking any unruly or anti-social behaviour at any time.

Do not hunt, fish, keep animals or gather forest products, except in line with the law and the rules of local communities.

Bring no firearms, ammunition, dangerous weapons or fireworks in the towns, camps or work sites.

Use vehicles safely at all times.

Use security passes as required for different areas. Zero Tolerance ArcelorMittal shall maintain a zero tolerance policy towards the following.

Infringement of any Liberian law.

Bribery, fraud or attempts at these.

Racist or anti-religious behaviour.

Involvement in prostitution on company property or in company vehicles.

Any form of sexual exploitation or abuse.

Involvement in violence of any sort.

Repeated excessive consumption of alcohol.

Intoxication on any work site.

Dealing with proscribed bush meat.

The use of any non-prescribed or illegal narcotic substance. ArcelorMittal reserves the right to require intoxication or controlled substance testing at any time.





3.6 Standard for Handling Grievances Introduction ArcelorMittal uses a grievance management system that tracks grievances from the point of reporting to the point of redress and finality. This is laid out in the Stakeholder Engagement Programme which makes provision for exactly such a process. This Standard systematises the implementation of investigation and response, and states the methodology for managing complaints systematically and effectively throughout the company.

These complaints vary widely and can include, for example, allegations of:

Adverse environmental impact by contractors or sub-contractors;

Damage to property;

Payments for employment access;

Disagreements over compensation assessment;

Unfair allocation of contracts;

Poor quality of work in communities;

Culturally inappropriate behaviour;

Etc… This process draws on the following ArcelorMittal Policies, plans and programmes and complies with international standards of commitment towards grievance management:

Stakeholder Engagement Policy;

Community Engagement Standard;

Code of Business Conduct;

Environmental Policy (and ArcelorMittal Liberia Policy on Caring for Nature);

Health and Safety Policy; and

Human Rights Policy (and ArcelorMittal Liberia Policy for Prevention of Sexual Exploitation and Sexual Abuse).

Methodology The tools for documenting and reporting on grievances are the Community Grievance Matrix and the Stakeholder Engagement Matrix. The following grievance management structures are in place at the community level:

Local Consultative Forums, which discuss general grievance and conflict resolution issues;

Grievance Redress Committees for resettlement compensation, which handle issues of resettlement compensation; and

Mine Resettlement and Coordination Committee, which is specific to Nimba County and is responsible for monitoring resettlement and social mitigation programmes.

This methodology for community grievance redress is expandable to cover wider issues concerned with company impacts. It applies equally to the Government Relations, Corporate Responsibility, Environmental and Procurement Departments, as well as construction contractors and sub-contractors, and the Company‟s Projects and Operations Offices.

The mechanism described here provides a system for recognising and responding coherently to a complaint through identifying a person responsible for investigating the complaint and co-ordinating the response.

The methodology covers:

Receiving complaints through any of the above offices;

Assessing information needs;

Allocating responsibility for investigation;

Recording the process;

Contacting the complainant;

Determination of the facts;




Agreeing responsibility and action where required;

Informing the complainant;

Dealing with disagreements over response and outcome;

Implementing action;

Researching complainant satisfaction;

Monitoring and evaluating the outcome; and

Ensuring transparency through the Company‟s website and publically accessible material. Grievance procedures A grievance is any actual or perceived problem that might give grounds for a complaint. A grievance mechanism allows internal and external stakeholders to ask questions and raise issues, with the knowledge that they will be handled properly. As such it is clear proof of our commitment to deal quickly and carefully with all reasonable concerns and queries that people bring to us. The grievance procedure must fulfil all of the following criteria.

Legitimate, in that it should be managed in a way that is credible to stakeholders, and immune from interference or undue influence.

Accessible: it must be well publicised, and open to all, regardless of language, literacy, financial means, or physical location.

Consistent: there must be absolute clarity about how the process works, how long it takes, and what it can (and cannot) achieve.

Equitable: everyone must be able to engage in the process on fair and equal terms. People must also be confident that there will be no adverse consequences or reprisals.

Sensitive to international standards: both the mechanism and the results should conform to internationally recognised standards for engaging with stakeholders.

Transparent: every aspect of the process should be as open and as candid as possible. However, this may be waived in agreement with the complainant, in cases where the complainant or another victim is put at personal risk through the nature of the complaint.

Process

Step Responsibility Action

1 Receiving a complaint: Complaints can be delivered verbally, by written letter, email, in a newspaper, on radio or on the internet

Any AML officer or Contractor or sub-Contractor employee

The receiving person must ensure that all the facts:

Complainant(s), group, body

Details of the complaint

Accompanying papers if any

Date and place of complaint delivery Are recorded on the complaint matrix form

2 Forwarding the Complaint

The recipient of the complaint

The complaint materials and complaint details form should be forwarded to the CEO, COO, CTO or Project Director, External Affairs & CR Manager and the Communication Manager depending on site, , E

3 Allocating responsibility for investigation

CEO, COO, CTO or Project Director, External Affairs & CR Manager and the Communication Manager

The CEO, COO, CTO or Project Director, External Affairs & CR Manager and the Communication Manager will allocate responsibility to a named team member for leading the investigation, setting the time frame for response and analysing the facts

4 Recording the Process Responsible Investigator as appointed by above

A designated office for recording complaints should be established. The designated investigator will record all actions, requests for information from other departments and units on the stakeholder engagement grievance matrix and be responsible for recording all actions by all parties. In resettlement issues, The matrix holder is responsible for keeping records of such complaints on the stakeholder engagement grievance matrix and including details in monthly reports.




Step Responsibility Action

5 Contacting the complainant Responsible Investigator

The designated investigator will contact the complainant(s) and inform them that their complaint is being investigated, that there is a process and how the complaint will be dealt with. The Stakeholder and Community Engagement Standards are to be used to make this contact. The CLU can lead or assist the responsible investigator unless the complaint is about that Unit

6 Determination of the facts Responsible Investigator

The responsible investigator must conduct a balanced inquiry into the allegations bearing in mind the rights, responsibilities and obligations of all parties. The investigator shall record the facts and outline appropriate lines of action.

7 Agreeing action CEO, COO, CTO or Project Director, External Affairs & CR Manager and the Communication Manager

The CEO, COO, CTO or Project Director, External Affairs & CR Manager and the Communication Manager will determine the response required, agree actions to be taken and assign responsibility for implementation and for communication of the result to the complainant

8 Informing the complainant Nominated Informing Officer

The nominated informing officer will contact the complainant and inform them of the outcome of the complaint. Where action is required to mitigate valid impacts the nominated implementation officer will liaise with the team responsible for the agreed outcome work.

9 Dealing with disagreements over response and outcome

Nominated Informing Officer

In the event that the complainant is unsatisfied with the analysis or outcome, the complaint should be referred to the Government Liaison Officers in the Corporate Responsibility Department who may include the Community Liaison Unit to assist in negotiations. The issue may well be escalated to discussion with the District and County Superintendents if no local resolution is possible.

10 Implementing action Nominated Informing Officer

The officer, contractor or sub-contractor designated to perform remedial actions where these are agreed, appropriate and justified shall arrange for a budget and materials and labour for the remedial works or actions to be carried out.

11 Researching complainant satisfaction

Nominated Informing Officer

The nominated informing officer is responsible for following up with the complainant to ascertain satisfaction with the works and for informing the CEO, COO, CTO or Project Director, External Affairs & CR Manager and the Communication Manager if the remedial action is unacceptable.

12 Monitoring and evaluating the outcome

Nominated Department, usually Corporate Responsibility Department (CRD)

Responsibility for monitoring and evaluating the outcome of the Grievance Process is by the CRD and recorded in the Stakeholder Engagement Matrix by the CRD and included in that Department‟s reporting.

13 Ensuring transparency through the Stakeholder Engagement Policy

Corporate Responsibility Department

The CRD will ensure transparency in making the process and outcome of the complaint investigation transparent and making public the findings using appropriate media.





3.7 Standard for Unexpected Cultural Sites and Archaeological Finds Introduction This standard guides actions required when project work for or by ArcelorMittal Liberia encounters sites of cultural heritage value, archaeological remains, graves and human remains. The purpose of this chance finds Standard is to ensure that a protocol is in place for identification, data collection, reporting; and, if necessary, salvage of significant chance finds. The National Museum of Liberia, in consultation with the Company will determination the level of significance for purposes of salvage. In its ESIA studies, ArcelorMittal has taken care to encourage communities to identify and map sacred sites – forests, groves, bushes, stones and rocks, caves, sites of archaeological or ancestral history and graves, and areas for African Traditional Religions. It is possible that some sites have been forgotten, missed or are important to people still displaced. It is also possible that there may be the discovery of human remains left from the civil war or more recent incidents. Possible sites A site of importance is defined as any of the following.

Any physical place or geographical feature identified by local people as culturally important – usually these will be identified by local people working on the site as they are found.

Any archaeologically significant structure or artefact. These may be difficult to identify but may be, for example, stone circles or unusual mounds that only appear as brush is cut back.

Graves – these may be stone markers only revealed on cutting back brush.

Exposed human remains – these may be recent, related to civil war incidents or much older. Cultural sites may be difficult to identify without explanation by local people. Features to look out for include signs of human activity or artefacts around large or unusual trees, bushes and rocks, particularly in remote locations. Supervisors and Contractors must be sensitive to comments by Liberian staff regarding cultural sites. Sometimes these may sound derogatory because of differences between Liberia‟s ethic cultures; but all cultural sires are valuable to someone. An archaeological site is a place in which evidence of past human activities is preserved. Sites that are buried or not identified by prior surveys may be discovered during project land clearing and in the first few metres of excavation. They may exhibit features such as scatters of broken pottery, flakes of worked stone, bones, discarded shellfish, walls of former buildings, or iron smelting works. These artefacts usually have no commercial value but are of value in defining a history of human occupation. Action required The Community Liaison Unit will include physical cultural resource awareness training for all staff and contractors during site induction and follow-up with reminder information on responsibility and respect for such resources in the event of a chance find, and the appropriate procedure to follow. In order to prevent vandalism, the Contractor, the Contractor‟s staff and the Project staff must keep confidential the location of the suspected find The procedure below states the steps that must be undertaken to report, investigate and deal with chance finds in the concession area and associated works.




Procedure Step Responsibility Action

1. Realisation Worker Report find to Supervisor.

2. Halt action Supervisor/ Engineer 1. Assess find.

2. Report to Project Director or COO.

3. Stop any action by workers or machinery that may affect the integrity of the find within at least 10 metres of the find.

4. Post a guard.

5. Record his inspection in the responsible contractor‟s daybook.

3 Investigate nature of find

Project Director or COO

Require the designated Cultural Heritage Resource Assistant (CHRA) from the Community Liaison Unit or Environmental Team to visit the find, check and report back on the type of find.

4 Site Visit Cultural Heritage Resource Assistant

Visit, inspect, and locate the site by GPS, and report to the Project Director or COO.

Report the find in the cultural heritage database and Community Engagement Matrix.

5. Action Project Director or COO

Call in the Liberian National Police to investigate the cause of death and determine whether this is a crime scene. The LNP will then take charge and manage removal of the remains.

a) In the case of human remains

b) In the case of a clearly identifiable grave

CLU / CHRA and Heritage Resource Group

The CHRA must try to identify relatives through community leaders or the Heritage Resource Group and arrange for relocation of the body by the nearest relatives. Removal costs and rituals associated with grave relocation will be paid from the Company‟s resettlement compensation budget.

c) In the case of a feature that may be archaeologically significant

Corporate Responsibility Director

1. Contact the University of Liberia, Liberia College of Social Science and Humanities, Anthropology Department

2. Request rapid appraisal visit to site by a competent specialist.

3. Commission specialist investigation with a view to researching, preserving or relocating the find if it is of archaeological significance.

4. Liaise with the project design team to avoid the site either temporarily or permanently.

5. Costs of the specialist visit, appraisal and any conservation or relocation activities will be met from the Company‟s resettlement compensation budget.

d) In the case of a site of cultural value

Cultural Heritage Resource Assistant

1. Contact the Heritage Resource Group, local community, elders, Poro and Sande leaders, and the Leader of the Animals to investigate claims to cultural significance.

2. Liaise with the project design team to avoid the site either temporarily or permanently.

3. If not possible to avoid, agree a relocation package and timetable with costs met from the Company‟s resettlement compensation budget.

4. Oversee and monitor the relocation to the agreed timetable and cost.

6 Reporting

At each level of report, the responsible officers will report appropriate information on the site

Cultural Heritage Resource Assistant with all involved officers

Enter appropriate information into the cultural heritage database and Community Engagement Matrix: a) Location – GPS co-ordinates. b) Conditions in which the discovery occurred. c) Type – principle evidence for suspected archaeological

sites, or informant declaration in the case of cultural sites.

d) Area – horizontal and vertical. e) Work stopped – task and schedule.





3.8 Standard for Warning of Blasting at Mines and Quarries Blasting causes considerable concerns locally and can damage the structures of poorly-built houses nearby. The obligatory procedure given below is to be followed for this activity.

Obligatory Procedure for Blasting at Quarries

1. Never blast on Sundays, national public holidays, nor at night (6 pm to 7 am).

2. Blasting shall be announced at least 60 hours in advance and the timing agreed with the Company‟s Community Liaison Officer.

3. At mines, regular blasts may be conducted at the same times on a daily or weekly schedule.

4. The blasting warning news shall be broadcast on local radio for a minimum of two days in advance: this shall be done in all local languages as well as English and on at least two radio stations.

5. Communities shall be fully informed of the blast at least 48 hours in advance. To achieve this, workers shall be sent out to carry the blasting notices to all the villages and farms within 2 km from the mine or quarry, to inform the precise time of the blasting operation. The workers shall post the notices on specially appointed notice boards at prominent locations at the nearby villages, the mine or quarry access road and other approaches to the area. The notices shall explain the siren signals (1 hour, 15 minutes and 5 minutes before, and all-clear afterwards) and the grievance redress mechanism.

6. The workers shall also discuss the significance of the blast with the Village Chief or other community representative.

7. The day before any blasting, the Mine or Quarry Manager and the Community Liaison Officer shall visit all households judged to be close enough to the 500-metre fly rock exclusion zone as to require warning of evacuation.

8. On the day of any blasting, additional security shall be deployed around the mine or quarry, and patrols made to enforce the exclusion of people from the 500-metre safety zone.

9. The Blast Operator will sound a loud double siren (15 seconds each with a 15-second gap) 1 hour, 15 minutes and 5 minutes before the blasting shots are fired.

10. Workers equipped with radios for communication shall be sent in all directions from the

blasting area to enforce the clearance within the 500‐metre fly rock danger zone 1 hour in advance, and keep watching every path leading to the blasting area until the blasting has finished.

11. The Blast Operator shall separately ensure that all workers and security guards are removed to an approved safe location before the blast.

12. At the last minute, the Blast Operator shall confirm the safety one more time through the radios, and then does the blasting.

13. After the blast, the Blast Operator shall check that all shots have fired and that the site is now safe. The all-clear shall then be sounded (a single siren of 30 seconds).

14. After the all-clear has sounded, the Community Liaison Team is sent to the villages to do the investigation for any possible damage.

15. A grievance process including a guidance form for all complaints shall be established, and a reporting mechanism to reach resolution.

16. In the event of a postponement for any reason, the all-clear shall be sounded. The Mine or Quarry Manager shall arrange a new time of blasting, which shall be not less than 48 hours ahead. The affected communities shall be informed of the reasons for postponement and updates provided every 24 hours until the blast takes place.





4. AIR QUALITY STANDARDS

4.1 Standard for Air Pollution Prevention and Control at Mine and Quarry Sites The following prevention and control measures shall be adopted in order to reduce fugitive dust emissions in mine and quarry sites. To control fugitive dust emission from drilling, wet drilling shall be used. Where there is a scarcity of water, a suitably designed dust extractor may instead be provided for dry drilling along with a dust collection hood at the mouth of the drill hole collar. Where possible, blasting sites shall be pre-wetted before blasting during the dry season. The time of blasting shall be planned to suit local conditions, avoiding blasting during temperature inversions and strong winds blowing towards residential areas. Conditioning of ore with water (moisture content: 7.5 – 9.5%) shall be done as a primary method to minimise fugitive dust emissions as long as this does not affect the flow of ore into the processing and handling areas. Dust suppression and dust extraction systems shall be provided at crusher hoppers, crushing, screening, ore bunkers, transfer points, loading points and other handling areas where dust may be generated. Where appropriate, enclosures shall be provided to crushing and screening plants, conveyors, transfer points in order to reduce the fugitive dust emissions. At stockpile areas, water sprays shall be used wherever possible to prevent dust from getting air borne at times of dry weather and strong winds. Appropriate transfer chutes shall be provided at discharge and loading points to minimise the drop height and spread of air borne dust. All haul roads and other heavily used roads shall be either black-topped or, if gravel, shall be either treated with stabilisers or sprayed with water as necessary to suppress dust. During dry weather and strong winds, when dust generated from operations may spread beyond the site, mine and quarry benches and other working areas shall be sprayed with water from mobile water tankers as necessary according to conditions. Appropriate vegetation shall be established or maintained alongside roads to help trap fugitive dust caused by the movement of vehicles and plant. An appropriate vegetation green belt of a minimum width of two hundred metres shall be established or maintained around the perimeter of crushing and screening plants, stockpile and loading areas, quarry working areas, mine pits and so on. Green belts should be maintained particularly if these sites are located in close proximity to villages and residential areas. Operators‟ cabins in all mobile and fixed plant shall be provided with dust proof enclosures. Persons working in dust prone areas shall be provided with suitable dust masks.




Ambient air quality tolerance limits Operations involving any dust- or gaseous-generating activity must not exceed the standards given in the tables below. These limits apply to all machinery, vehicle, railway and power generation emissions, as well as to the generation of dust from earthworks, ore and rock crushing, and vehicle movements. The tables below present both international and national standards. The most stringent of the two should be achieved. Both are given in this standard because measurement techniques vary and the differences of averaging periods may mean that one table can be used for interpretation rather than the other. In practice, emission fluctuations, meteorological conditions and baseline concentrations mean that in many cases compliance with the standard for 90 percent of the time can be accepted except where sensitive receptors are within the influence zone. International standards

Pollutant Averaging

period Standard Standard derivation Sources

Dust deposition

30 days 600 mg/m2/day

(Not to be exceeded more than three times per year, no two sequential months)

South African action level for residential areas (SANS 1929, 2004)

Mining operations, roads, agriculture and various non-anthropogenic sources

PM10 24 hours 150 µg/m3

(99th

percentile) IFC (adopted from WHO Guidelines, Interim Target 1)

Mining operations, vehicle exhausts, railway locomotives, power generation

Annual mean 70 µg/m3

PM2.5 24 hours 75 µg/m3

(99th

percentile)


Nitrogen dioxide (NO2)

1 hour 200 µg/m3 IFC (adopted from

WHO Guidelines) Vehicle exhausts, railway locomotives, power generation


Sulphur dioxide

10 min mean 500 µg/m3 IFC (adopted from

WHO Guidelines) Railway locomotives, heavy fuel oil-fired power generation 24 hours 125 µg/m

3 IFC (adopted from

WHO Guidelines, Interim Target 1)

Carbon monoxide

8 hours 10 mg/m3 IFC (adopted from

WHO Guidelines) Vehicle exhausts, railway locomotives, power generation

PM10 and PM2.5 are fine particulate matter with an aerodynamic diameter of less than 10 and 2.5 micrometres respectively.




Liberian draft standards

No. Pollutant Time weighted average Industrial

areas

Residential, rural and other

areas

Controlled areas***

1. Sulphur oxides (SOX)

Annual Average* 80 g/m3 60 g/m

3 15 g/m

3

24 hours** 120 g/m3 80 g/m

3 30 g/m

3

Annual Average 0.019 ppm

50g/m3

24 Hours 0.048ppm

125g/m3

Instant Peak 500 g/m3

Instant Peak (10 min) 0.191 ppm

2. Oxides of Nitrogen (NOX)


3 15 g/m

3

24 hours** 120 g/m3 80 g/m

3 30 g/m

3

Annual Average 0.2 ppm

Month Average 0.3 ppm

24 Hours 0.4 ppm

One Hour 0.8 ppm

Instant Peak 1.4 ppm

3. Nitrogen Dioxide Annual Average 0.05 ppm

Month Average 0.08 ppm

24 hours 0.1 ppm

1 hour 0.2 ppm


4. Suspended particulate matter (SPM)


3 70 g/m

3

24 hours** 500 g/m3 200 g/m

3 100 g/m

3

Annual Average* 100 g/m3

24 hours*** 180 g/m3

5. Suspended particulate matter

(<10m) (RPM)


3 50 g/m

3

24 hours** 150 g/Nm3 100 g/Nm

3 75 g/Nm

3

6. Lead (Pb) Annual Average* 1.0 g/Nm3 0.75 g/Nm

3 0.50 g/m

3

24 hours** 1.5 g/m3 1.00 g/m

3 0.75 g/m

3

Month Average 2.5 g/m3

7. Carbon monoxide (CO)/carbon dioxide (CO2)

8 hours** 5.0 mg/m3 2.0 mg/m

3 1.0 mg/m

3

1 hour 10.0 mg/m3 4.0 mg/m

3 2.0 mg/m

3

8. Ozone 1 hour 0.12 ppm


* Annual Arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform interval. * 24-hour limit may not be exceeded more than three times in one year; ** 24 hourly/8 hourly values should be met 98% of the time in a year. However, 2% of the time, it may exceed but not on two consecutive days. ** 24-hour limit may not be exceeded more than three times in one year micrograms/m3 *** Not to be exceeded more than once per year average concentration

Source: adapted from Liberia Environmental Protection Agency Draft Regulations (September 2010).




4.2 Standard for Emissions Limits from Heavy Diesel Engines Introduction Limits are set on emissions from engines in order to limit pollution and improve air quality. This is necessary not just to avoid unhealthy levels of pollutants for humans, plants and animals, but also to help provide a cleaner and more pleasant environment. The reduction of carbon emissions is also a necessary part of controlling potential impacts on atmospheric conditions. This standard applies to all vehicles and machines with a mass greater than 2,610 kg (i.e. everything larger than a standard road passenger car, van, pick-up or four-wheel drive “jeep”). Large diesel engines The permitted emissions from large diesel engines shall comply with the Euro VI regulation, issued by the European Union in 2009. This gives limits for both gaseous and particulate emissions, as shown in the table below. Permitted emission limit values

CO (mg/kWh)

THC (mg/kWh)

NMHC (mg/kWh)

CH4 (mg/kWh)

NOx (mg/kWh)

NH3 (ppm)

PM mass (mg/kWh)

ESC (CI) 1,500 130 400 10 10

ETC (CI) 4,000 160 400 10 10

ETC (PI) 4,000 160 500 400 10 10

THC – total hydrocarbons; NMHC – non-methane hydrocarbons. ESC – European steady state cycle; ETC – European transient cycle. CI – compression ignition; PI – positive ignition.

The following points must be considered in the installation, operation and maintenance of company facilities and vehicles.

All new equipment must comply with the emissions limits set out in this standard.

Second-hand equipment procured by the company or provided by contractors must be modified to comply with the emissions limits set out in this standard.

Replacement parts for engines must be of a standard that will ensure adherence with the emissions limits.

Wherever possible, equipment should have an on-board diagnostic system, capable of detecting malfunctions and alerting the operator.

No equipment may be modified to improve performance at the expense of increasing emissions.

No equipment may be operated if emission control devices or recirculation systems are not functioning, or appropriate reagents are not present.

All equipment must have a certificate to show compliance at the time of installation or initiation of work for the company, and updated annually thereafter.

All equipment must have servicing and maintenance logbooks and records.

All servicing must be undertaken no later than the time appointed in the manufacturer‟s recommendations.

Engines should not be used beyond the manufacturer‟s guaranteed life span for any installed pollution control device, without a suitable replacement device being fitted.

Power plants The World Bank Group‟s 1998 document, Thermal Power: Guidelines for New Plants, defines procedures for establishing maximum emission levels for fossil-fuel based thermal power plants with a capacity of 50 or more megawatts of electricity (MWe) that use coal, fuel oil, or natural gas. The guidelines include emission limits for particulate matter, SO2 and NOx for various types of power plants, including engine-driven power plants. The World Bank Group‟s 2007 document, Environmental, Health, and Safety General Guidelines, gives guideline values for facilities in the 3 to 50 MWe range. These two documents are used as company standards.




The maximum emission levels are expressed as concentrations, to facilitate monitoring. The emission limits are to be achieved through a variety of control and fuel technologies, as well as through good maintenance practice. Dilution of air emissions to achieve the limits is not acceptable. The following are emission limits for engine driven power plants. Particulate matter. PM emissions (all sizes) should not exceed 50 mg/Nm

3.

Sulphur dioxide. The maximum sulphur output should be 1.5 percent. Total SO2 emissions should be less than 0.20 tonnes per day (tpd) per MWe of capacity for the first 500 MWe, plus 0.10 tpd for each additional MWe of capacity over 500 MWe. In addition, the SO2 concentration in flue gases should not exceed 2,000 mg/Nm

3, with a maximum emissions level of 500 tpd.

Nitrogen oxides. Provided that the resultant maximum ambient levels of nitrogen dioxide are less than 150 µg/m

3 (24-hour average), the NOx emissions levels should be less than 1,460 mg/Nm

3 for a bore

diameter less than 400 mm, and 1,850 mg/Nm3 for greater bore diameters. In all other cases, the

maximum NOx emission level is 400 mg/Nm3 (dry at 15% O2).

Source: European Union Regulation 595/2009 and World Bank Guidelines.

4.3 Standard Fuel Specifications for Project Phase 2 Much of Liberia is covered by rainforest of high biodiversity value. For this reason, chemical air pollution is to be minimised wherever possible. In particular, sulphur emissions must be limited to the greatest extent possible because of the acidifying effect of particulate residues and rainfall, which in turn can damage sensitive vegetation and small animal life. All diesel fuel oil used by Project Phase 2 from the commencement of operations shall have a total sulphur content that is less than 0.05 percent (500 ppm). Wherever possible, the sulphur content shall be less than 0.005 percent (50 ppm). This will apply to all machine and transport applications running on diesel engines, including generators, railway locomotives, mining machines, haul trucks and light vehicles. All heavy fuel oil (HFO) used by Project Phase 2 from the commissioning of its power plants onwards shall have a total sulphur content that is less than 2.0 percent (20,000 ppm). Wherever possible, the sulphur content shall be less than 1.0 percent (10,000 ppm). In addition to the above, all other standard environmental parameters of diesel and HFO shall be met as per ArcelorMittal‟s specifications as modified and strengthened from time to time. Source: IFC Environmental, Health, and Safety General Guidelines (2007) and ESIA.




5. WATER AND SOIL QUALITY STANDARDS

5.1 Standard for the Control of Water Pollution Introduction No person shall discharge or apply any poisonous, toxic, noxious or obstructing matter, radioactive waste or other pollutants unless the discharge of such material is treated to permissible standards as defined in the Company‟s environmental permits. No person shall:

Generate and discharge any form of effluent on to land or into any water resource without compliance with an approved Environmental Management Plan and a valid Environmental Certificate;

Discharge wastewater or effluent off an operational site, which does not meet the water quality requirements stipulated in the appropriate licence for effluent discharge or in ArcelorMittal Liberia standard for effluent (standard 5.3); or

Discharge into any water resource effluent from a sewage treatment plant, trade or industrial facility without both treatment and a valid effluent discharge license.

In rural Liberia, all surface water courses are used for drinking water supplies at some point during the agricultural year. Prevention of water pollution Surface run-off from mining areas, waste dumps and other areas shall be properly controlled, collected and treated before discharging into natural water courses. Silt traps and check dams of appropriate sizes shall be constructed at all strategic points to control surface run-off. All run-off water shall be diverted through a series of sedimentation basins to remove suspended particles and chemicals as necessary. Entrained sediment shall be collected as close to the source as possible. In particular, coarse sediment (sand- and coarse silt-sized particles) should be removed from water courses at the point where they leave the source of supply. Coarse sediment can destroy riverine biotic systems that can otherwise thrive close to mine and waste dump sites. Sedimentation ponds and check dams shall be de-silted at regular intervals, as required to maintain effectiveness. Re-vegetation of exposed surfaces shall be done as far as possible in the mine and dump sites, and around all infrastructure and roads. A separate series of standards covers these works. Pit water discharged from mines working below the water table shall be properly treated and used in ore beneficiation, dust suppression, etc. It shall be ensured that the level of the water table is not depleted by mining activities outside the immediate boundary of the pit. Pit water may contain high nutrient levels from explosives where ammonium nitrate is used, and has the potential to cause eutrophication of surface water bodies. Water with this characteristic can be hard to treat, though dilution may be feasible; but the quality will need to be confirmed by the Company‟s Environmental Department before use. If this is the case, a settlement pond will be required for this purpose, perhaps fed from a sump in the pit. All efforts shall be made to re-use and re-cycle treated effluents to the maximum possible extent in order to achieve zero effluent discharge. Domestic effluents shall be treated in properly designed oxidation ponds or by any other suitable sewage treatment method. Outfalls should be allowed to discharge into the environment only where the quality standards given in Standard 5.2 are met. The Company‟s Environmental Department shall be responsible for monitoring this, but may require a contractor to undertake monitoring on its behalf.




Where camps are operated by contractors or other agencies, then the operator is responsible for monitoring outfalls. Workshops, fuelling stations and other areas handling fuels, lubricants and other hazardous substances shall be subject to special provisions. These are covered in detail by separate standards. Protection and conservation of riparian areas Riparian land is the area along the banks of rivers and creeks, and edges of swamps, where there is a dynamic complex of plant, animal and micro-organism communities and their non-living environment adjacent to and associated with a watercourse. Although this zone varies, a practical guideline is to take it as occupying 50 metres on each side of a watercourse. In specific conditions, where there is a strong case for a narrower width, this may be reduced to a minimum of 15 metres. The following activities shall not be permitted on riparian land except as provided in the following two paragraphs:

Tillage or cultivation;

Clearing of trees or other vegetation;

Building of permanent or temporary structures;

Disposal of any form of waste;

Excavation of soil or development of borrow pits or quarries; or

Any other activity that may degrade the water resource. Where it is essential that tracks or roads must cross the riparian zone, they shall be aligned to cross at rightangles, thereby minimising disruption to this valuable habitat. The area cleared for them shall be kept as narrow as possible and special provision shall be made for soil erosion control measures. Culverts shall be installed so that vehicles do not drive through the water. If any of the above activities must take place within the 50-metre riparian zone, a full environmental management plan must be prepared that demonstrates how any impacts will be mitigated, with control measures put in place before any other site works start. Riparian zones should be considered as key areas in all work site environmental monitoring. Water quality assessment or the health and diversity of indicator insect species such as dragonflies shall be used to judge the effectiveness of mitigation measures. Spillage No person shall wilfully and deliberately allow any substance to spill out into any water resource or on to land where such spillage may contaminate either soil or a body of surface or groundwater. In the event of accidental spillage where such spillage may contaminate either soil or a body of surface or groundwater, the following actions shall be taken.

The person responsible for or causing or finding the spilt substance shall immediately inform the Company of the accident.

The Company shall take immediate and adequate measures to prevent spread of the spillage and its likely adverse effects to soil and water resources.

The Company shall take measures to notify the public of the spillage and also to cause action to be taken to deal with the spillage.

In this context the Company is represented by the Manager responsible for that overall site (e.g. the Mining Manager).




5.2 Standard for Water Quality The Company is to ensure that the standards in the table below are maintained as far as is possible in any water flows affected by its operations. Where the ambient water quality is lower than the standard, then the company shall restore the water to the ambient quality. Categories of water use Class I Drinking water; water supply for industry requiring drinking water. Class II Natural and cultivated fisheries, public bathing places, recreational water sports. Class III Industrial supplies (other than for drinking); irrigation of agricultural land. The Liberian water quality standard table also gives the World Health Organisation (WHO) guideline standard where it is available. The absence of a WHO guideline value usually suggests that there is not considered to be a health risk. Liberian water quality standards

Parameter Unit WHO Class I Class II Class III

pH -logH - 6.5-8.0 6.0-9.0 5.5-9.0

Chloride Cl mg/l 350 ≤ 250.0 ≤ 350.0 ≤ 450.0

Sulphate SO4 mg/l ≤ 150.0 ≤ 200.0 ≤ 250.0

Hardness CaCO3 mg/l 100-500 ≤ 190.0 ≤300.0 ≤ 600.0

Total iron Fe mg/l 0.1 ≤ 0.1 ≤ 1.5 ≤ 2.0

Manganese Mn mg/l 0.1 ≤ 0.1 ≤ 0.3 ≤ 0.8

Total zinc Zn mg/l 5 ≤ 1.0 ≤ 2.0 ≤ 5.0

Coliform bacteria n/ml 0 0 0 ≤ 5

Total bacteria n/ml 0 0 ≤ 10 ≤ 50

Dissolved substances mg/l 500 ≤ 500.0 ≤ 1000.0 ≤ 1200.0

Suspended solids mg/l - ≤ 10.0 ≤ 30.0 ≤ 50.0

Ammonia NH4 mg/l 0.5 ≤ 1.0 ≤ 3.0 ≤ 6.0

Nitrate NO3 mg/l 50 ≤ 40.0 ≤ 60.0 ≤ 80.0

Nitrite NO2 mg/l - ≤ 0.1 ≤ 0.5 ≤ 1.0

Phosphate PO4 mg/l - ≤ 0.01 ≤ 0.02 ≤ 0.05

Phenols mg/l 0.001 ≤ 0.001 ≤ 0.02 ≤ 0.05

Detergents mg/l - ≤ 1.0 ≤ 2.0 ≤ 3.0

Fluoride F mg/l 1.5 ≤ 1.5 ≤ 1.5 ≤ 2.0

Cyanide Cn mg/l 0.05 n.d. ≤ 0.02 ≤ 0.05

Lead Pb mg/l 0.1 ≤ 0.1 ≤ 0.1 ≤ 0.1

Mercury Hg mg/l 0.01 n.d. ≤ 0.005 ≤ 0.01

Copper Cu mg/l 0.05 ≤ 0.01 ≤ 0.01 ≤ 0.2

Cadmium Cd mg/l 0.01 n.d. ≤ 0.001 ≤ 0.01

Chromium trivalent Cr mg/l - ≤ 0.5 ≤ 0.5 ≤ 0.8

Chromium hexavalent Cr mg/l 0.05 ≤ 0.05 ≤ 0.1 ≤ 0.1

Nickel Ni mg/l - ≤ 1.0 ≤ 1.0 ≤ 1.0

Silver Ag mg/l 0.05 ≤ 0.01 ≤ 0.01 ≤ 0.01

Vanadium V mg/l - ≤ 1.0 ≤ 1.0 ≤ 1.0

Boron B mg/l - ≤ 1.0 ≤ 1.0 ≤ 1.0

Arsenic As mg/l 0.05 ≤ 0.05 ≤ 0.05 ≤ 0.2

Source: adapted from Liberia Ministry of Health and Social Welfare Water Quality Standard (1987) and Environmental Protection Agency Draft Regulations (September 2010).




5.3 Standard for Water Effluent Quality Setting and Rationale All creeks and rivers in rural Liberia are used as drinking water supplies by farming households. The upland creeks of the Western Range mine sites contain unique species and biodiversity. While some damage is inevitable, this can be minimised by limiting the movement of sediment within the creeks and swamps. In the complex terrain and hydrological landscape of the Liberian interior, the creeks and rivers around the Company‟s mine and infrastructure sites are minor in terms of discharge volumes compared with the increasing catchment area contributing to the major rivers downstream. Cutting off sediment output from these headwaters will have little effect on the overall river hydrology. On the other hand, if they are allowed to contribute significant volumes of sediment (particularly large particle sizes of inorganic mining waste), there is strong evidence that aquatic flora can be smothered. Once the plants in a river are dead, oxygen levels decrease markedly and so aquatic fauna also die. Large particles in a river therefore wipe out the aquatic life. The approach to be adopted is therefore to trap the larger particles as close to their source as possible, and to trap the remaining sediment before it leaves the site boundaries. Within an operational site where soil disturbance is underway, or where bare soils have not yet been revegetated, the guideline standard is to ensure the settlement of particles of coarse silt size (i.e. greater than 0.06 mm) and above as close as possible to the source location. Of the material potentially derived from the mine sites, coarse silt and fine sand are the particle sizes found to be most damaging through sedimentation in downstream river fringes. Particles of fine silt size (0.002 to 0.06 mm) and clay size (less than 0.002 mm) generally stay suspended in the Nimba rivers and therefore do not pose a significant sedimentation problem. Boundary Limits At the point where water flows out of any Company site, the guideline quality standards should be met. In many cases, where a site is not large or where terrain allows, there may be a single water treatment system. On larger sites, particularly mountain mine sites, it is impractical to achieve complete effluent cleansing close to the source due to terrain steepness and the need to avoid excessive construction. In these situations the intention is to trap the coarse sediment as high up a water course as possible, and then to settle out the finer suspended materials wherever the terrain and stream bed gradient allow. In any event, the guideline quality standards need to be met before the water leaves the overall site boundary. Guideline Quality Standards – Biological Following dilution in the receiving waters, the faecal coliform count shall not exceed 200 CFU (colony forming units) per 100 millilitres at 50 metres from the discharge point. Guideline Quality Standards – Chemistry The following guideline quality standards shall be used for effluents discharged from sedimentation basins and storm water drainage.

Biological oxygen demand (BOD): 50 mg/l.

Oil & grease: 20 mg/l. These levels are taken from the International Finance Corporation‟s Environmental, Health and Safety Guidelines for Mining (December 2007). For pH, the range of 6 to 9 is required. Ambient levels are very rarely outside this range. Where more acid conditions occur in wetlands, discharge tends to be limited and is quickly buffered by




dilution in downstream water courses. Hence pH levels outside the guideline range should be investigated promptly and thoroughly. Residual heavy metals (total concentrations):

Arsenic: 1.0 mg/l;

Cadmium: 0.1 mg/l;

Chromium+6

: 0.1 mg/l;

Chromium, total: 1.0 mg/l;

Copper: 0.3 mg/l;

Lead: 0.6 mg/l;

Mercury: 0.002 mg/l;

Nickel: 0.5 mg/l;

Zinc: 1.0 mg/l. These levels are taken from the International Finance Corporation‟s Environmental, Health and Safety Guidelines for Mining (December 2007). Iron levels are naturally high in the water courses of northern Nimba, and frequently exceed the World Bank guideline level of 2 mg/l total iron. This is not necessarily unhealthy, and the WHO does not set a guideline value for reasons of health. However, high concentrations of iron give rise to poor taste and discoloration of water. The guideline levels for iron are therefore as follows.

Mean concentration in the months of November to April is to be 2.0 mg/l or lower.

Tolerated range is up to 4.0 mg/l for 30% of the time and up to 10.0 mg/l for 5% of the time in the months of May to October.

Iron levels exceeding 10.0 mg/l levels should be investigated promptly and thoroughly. Guideline Quality Standards – Sediment As far as possible, all coarse silt and sand must be settled out of discharge water within the site boundaries.

Effluent may not contain particles of sediment that are larger than 0.06 mm in the months of November to April.

Effluent may contain particles of sediment that are larger than 0.06 mm for 5% of the time in the months of May to October.

Discharges of sediment finer than 0.06 mm (fine silt and clay) are permitted within the following guideline limits. November to April, all rivers.

Total suspended solids are to be at a maximum of 50 mg/l (50 ppm) for at least 95% of the time.

Turbidity is to be 40 NTU or less for 95% of the time.

During the less than 5 percent of the time when heavy rainfall events have just taken place, the total suspended solids should not exceed 1000 mg/l and turbidity should not exceed 1400 NTU at any time. This is calculated as a proportion of hours per year.

May to October, Dayea River. Effluent levels should generally meet the standards given below for “all other rivers”, but monitoring levels are permitted as follows.


Turbidity is to be 150 NTU or less for at least 70% of the time.

Total suspended solids are permitted to a maximum of 500 mg/l (500 ppm) for up to 25% of the time during or immediately after periods of prolonged rainfall.

Turbidity is permitted to a maximum of 800 NTU or less for up to 25% of the time during or immediately after periods of prolonged rainfall.

For up to 5 percent of the time when heavy rainfall events have just taken place, the total suspended solids should not exceed 1000 mg/l and turbidity should not exceed 1400 NTU at any time. This is calculated as a proportion of hours per year.




May to October, all other rivers. Both effluent and monitored river water should meet the following quality levels.


Turbidity is to be 100 NTU or less for at least 70% of the time.

Total suspended solids are permitted to a maximum of 250 mg/l (250 ppm) for up to 25% of the time during or immediately after periods of prolonged rainfall.

Turbidity is permitted to a maximum of 500 NTU or less for up to 25% of the time during or immediately after periods of prolonged rainfall.

For up to 5 percent of the time when heavy rainfall events have just taken place, the total suspended solids should not exceed 1000 mg/l and turbidity should not exceed 1400 NTU at any time. This is calculated as a proportion of hours per year.

Total Dissolved Solids Total dissolved solids (TDS) measurements are not generally considered as a parameter for assessment in relation to industrial discharges to the environment, but are used only as an indication of the presence of major chemical constituents, particularly Ca, Mg, Na and K as cations, and SO4=, Cl

- and HCO3- as anions during assaying. Where one of these major constituents is of relevance to

the local environment, it is this constituent which is adopted within standards or guidelines. The constituent most normally considered is sulphate, SO4=, where it may be relevant to local freshwater fish. Typical guidelines adopted internationally refer to 250 mg/l SO4= as a required standard, although local circumstances may indicate a higher value as appropriate. Water quality data obtained at ArcelorMittal‟s Tokadeh Mine, not only for local streams but also from water sampling locations at the mine site, have demonstrated sulphate levels to be far lower than this, and often below detection. Where TDS is more commonly used is for potable drinking water, where high TDS is an indicator of poor aesthetic characteristics, though only in respect of taste and not health considerations. In this case, TDS for potable drinking water can be set at 500 mg/l (to put this into perspective, spring water purchased in bottles can contain TDS in the order of 250 to 350 mg/l). In most countries, TDS limits are still under debate. For the reasons stated here, TDS is not therefore included in the guidelines as it is not considered relevant in the Liberian hydrological environment. Permitted Deviations As a general rule, discharges to surface water should not result in contaminant concentrations in excess of local ambient water quality criteria outside a scientifically established mixing zone. Receiving water-body use and assimilative capacity, including the impact of other sources of discharges to the receiving water, need to be considered with respect to acceptable contaminant loadings and effluent discharge quality. Except where otherwise stated, the guideline levels given above should be achieved, without dilution, at least 95 percent of the time that the site is operating. Deviation from these levels could not be justified in the environmental assessment and so are not permitted. Monitoring Effluent quality monitoring shall be undertaken by the Company to check the efficiency of the control measures adopted for protection of the aquatic environment. The effluent quality should be monitored at each watercourse outfall on a weekly basis and immediately after any accidental spillages or similar events. The monitoring programme shall have the following objectives: (a) to check the compliance status, for which it is essential to monitor the water quality parameters for the effluents arising out of the mining




and other operations for all the parameters; and (b) to identify sources of pollution and to plan proper management strategies to maintain the quality of receiving water bodies. Where possible, the Company‟s water discharge monitoring will include the following provisions for both site discharge points and nearby ambient water flows.

Continuous or regular monitoring of turbidity or suspended solids.

Periodic sampling for assessment of other potential contaminants.

Opportunistic sampling during high flows following heavy rainfall.

Field data verification and quality assurance. The determinands for pH, BOD, oil and grease and TSS (or turbidity) should be monitored at each outfall at intervals not greater than one month and usually every week. The residual heavy metals should be monitored monthly unless a non-compliance measurement occurs during a weekly monitoring, in which case additional observations for metals should be made appropriate to the non-compliance. Sources: (1) Adapted from World Bank guidelines, including the International Finance Corporation’s Environmental, Health and Safety Guidelines for Mining (December 2007); and (2) modified in line with ArcelorMittal Liberia’s Assessment of Water Quality Standards in Northern Nimba County, Liberia, dated 3 March 2014.

5.4 Standard for Soil Contamination Screening Heavy metals and acidity Soil is a highly complex medium with infinite variability in its biological, chemical and physical composition, and is dynamic over time. The setting of values for acceptable levels of contamination is therefore difficult. Also, the level of contamination that can be accepted depends on the use of the soil and the likelihood of contaminants entering food chains. Guideline soil screening values for individual elemental contaminants are shown in the table below.

Contaminant Contaminant soil screening value (mg/kg)

Land use Residential,

with plant uptake Commercial/industrial

Playing fields and recreational

Total Sulphate tbd tbd tbd

Arsenic 20 500 1,900

Cadmium1 1 1,400 545

Chromium2 130 5,000 2,800

Copper 653 760,000 330,000

Lead 450 750 -

Mercury 8 480 220

Nickel 50 5,000 930

Selenium 35 8,000 3,600

Zinc 139 >1,000,000 390,000

Acid Soluble Sulphide tbd tbd tbd

Total Organic Carbon tbd tbd tbd

pH Value tbd tbd tbd

Source: Contaminated Land Exposure Assessment (CLEA) from the UK Environment Agency (December, 2004), supplemented by Atkins Soil Screening Values. tbd Denotes values yet to be determined through research. 1

Depends on soil pH: value given is for pH6. Changes to SSV of 2 for pH7 and SSV of 8 for pH8. 2

Assumes that all chromium is chromium IV.

Hydrocarbons Interpretation of hydrocarbon contamination is difficult due to the complex chemistry of these compounds. In general, health concerns are related to the following:

The degree of contamination.




The volatility and rate of decomposition of the contaminants.

The different fractions within the particular hydrocarbon, and whether they are known to be carcinogenic.

The length of exposure to the contaminants. Ecological concerns are related to uptake pathways through the food chain and other vectors, and again this is a complex bio-chemical assessment. In the case of diesel, assessment is based on a wide range of different fractions. Screening of the C10 to C14 fractions are typically based on criteria for naphthalene (typically 3% of diesel). Screening of the C15 to C36 fractions are often based on pyrene (typically 0.4% of diesel). The relatively high acceptability criteria for the heavier C15 to C36 fractions are related to the low concentrations of the heavier, carcinogenic polycyclic aromatic hydrocarbon (PAH) compounds in diesel (generally the concentrations of benzo(a)pyrene and other carcinogenic PAHs are very low (below detection limits). However, an additional uncertainty lies in the differential degradation of the PAHs compared to other diesel components, and so it is necessary to introduce a safety factor to account for this. There are no international standards or Liberian standards for acceptable concentrations of petroleum hydrocarbon products in soils. Other national standards for some hydrocarbon groups are given in the two tables below, and these are adopted by the Company.

Contaminant Contaminant soil screening value (mg/kg)

Land use Residential,

with plant uptake Commercial/industrial

Playing fields and recreational

Poly-aromatic hydrocarbons (PAH) by GCMS

Naphthalene 4.4 98 620

Acenaphthylene tbd tbd tbd

Acenaphthene 536 88,000 14,000

Fluorene 454 57,700 8,820

Phenanthrene tbd tbd tbd

Anthracene 4,300 351,000 68,500

Fluoranthene 796 57,700 8,820

Pyrene 590 43,400 6,850

Benz(a)anthracene 4.79 290 45.6

Chrysene 479 29,000 4,560

Benzo(b)fluoranthene 5.54 290 45.6

Benzo(k)fluoranthene 55.4 2,900 456

Benzo(a)pyrene 0.54 29 4.56

Indeno(123cd)pyrene 6.04 290 45.6

Dibenzo(ah)anthracene 0.61 29 4.56

Benzo(ghi)perylene 62.6 2,900 456

Source: Contaminated Land Exposure Assessment (CLEA) from the UK Environment Agency (December, 2004), supplemented by Atkins Soil Screening Values. tbd Denotes values yet to be determined through research.

Soil screening (agricultural use) criteria for heavy fraction petroleum hydrocarbons associated with diesel (all values mg/kg)

Soil Type Contaminant Depth of contamination

Surface (<1m) 1m - 4m > 4m

Sand C10-C14 58 560 650

C15-C36 4,000 >20,000 > 20,000

Sandy silt C10-C14 58 670 5,400

C15-C36 4,000 > 20,000 > 20,000

Silty clay C10-C14 58 2,700 8,900

C15-C36 4,000 20,000 20,000

Clay C10-C14 58 2,900 9,700

C15-C36 4,000 > 20,000 > 20,000

Source: Guidelines for Assessing and Managing Petroleum Hydrocarbon Contaminated Sites in New Zealand: Ministry for the Environment, 1999.




The New Zealand approach makes it clear that a considerable amount of professional discretion is necessary due to a general lack of information on the subject. Their standards draw a distinction between the medium and heavy fractions, which are spanned by diesel. In most cases the Government of New Zealand is cautious on pollution issues. Another assessment comes from the United States of America (see table below). This gives the total petroleum hydrocarbon concentration in the soils that should not be exceeded by free-phase chemicals in the soil saturation solution. These allow somewhat higher concentrations than the New Zealand standards. Maximum saturation concentrations permitted in soils (all values mg/kg)

Fraction Residual saturation concentration

Sand and gravel Silty/clayey sand Silty clay

Light C6-C12 1,000 5,000 8,000

Middle C7-C16 2,000 10,000 20,000

Heavy C16-C35 5,000 20,000 40,000

Source: Guidance for Assessing Petroleum Hydrocarbons in Soil: Environmental Protection Agency of Ohio State, USA, 2004.

Sources: Government guidelines from UK, New Zealand and USA; W. S. Atkins International.




6. EROSION CONTROL AND REVEGETATION STANDARDS

6.1 Standard for Mine Drainage and Sediment Capture Overview Surface run off from mining areas, spoil tips, stock piles and loading areas, and other surfaces, shall be properly collected and treated in a series of attenuation and settlement ponds before discharging water into any watercourses. Check dams and similar measures shall be constructed at all strategic points to control the surface runoff and carry-over of suspended solids. Such structures shall be emptied of sediment at least annually each dry season, or more frequently if necessary. Collection of water Rainwater will find its way on to mine benches as a result of direct rainfall, direct runoff or sub-surface flow through the weathered zone. Benches shall be suitably graded and the water properly diverted to flow out by gravity (through proper gradient) to controlled outfall to attenuation and settlement ponds. Bench floors may be sloped towards the excavated bench face: a slope of not less than 2% should prove suitable. Longitudinally along the toe of the high wall, the bench should slope along the whole length to the nearest culvert outlet: a slope of not less than 1% should be adequate. On abandoned mine benches (but not narrow catch benches on high slope cuttings), a 2-metre high stable berm shall be built along the outer edge of the bench, to prevent water spilling over to the lower bench. All roads shall be cross-sloped at typically 2% to 3% towards the cut face and shall be sloped longitudinally towards the nearest controlled outfall. Outfalls shall be built in adequate number to receive the runoff water and directed to controlled outfalls via sedimentation basins. Sediment capture Sediment capture measures are designed to trap the diffuse sediment carried by surface water before flow enters attenuation and settlement ponds. These measures can remove a significant fraction of the sediment which otherwise would need to be removed by the ponds. This approach is similar in principal to accepted techniques of sustainable drainage systems. Specific measures to capture sediment must be designed on a site specific basis, and the standards for revegetation and erosion control should be used for guidance as appropriate. Methods for sediment capture commonly used at mines include the following.

Sediment control dams. These are rock-filled dams constructed across a valley to arrest mine washouts triggered by rainfall and prevent them from entering into a watercourse. Sediment is removed from upstream of the dam at least annually each dry season, or more frequently if the dam becomes full. Sediment can be used as fill material if suitable, or otherwise taken to a managed spoil tip.

Construction of a diversion channel. Where there is no choice but to construct stockpiles and spoil tips in areas of an existing watercourse or across ephemeral water paths which flow through the site, the flow must be diverted, channelled or directed through a culvert past the area without impediment, and discharged into a natural drainage course downstream.

Construction of check bunds. Temporary check bunds can be constructed across the areas which contribute mine washouts to watercourses during the wet season, to control water pollution. The accumulated material should be removed at least annually each dry season, or more frequently if necessary.

Construction of contour trenches. Water borne sediment in areas outside the catchment of a pollution control dam can be intercepted and channelled to the dam by the cutting of contour trenches.

Source: ESIA recommendations.




6.2 Standard for Settlement and Attenuation Ponds Design The most effective control measure for removal of sediments from surface run-off is a settlement pond. Such a pond must be adequately sized to allow sediment to settle under flows generated by all “normal” heavy rainfall events at the site. It also modulates the discharge hydrograph. The intention is to force the settlement of particles of coarse silt size (i.e. greater than 0.06 mm) and above from watercourses as close as possible to the source of supply. Of the material potentially derived from the mine sites, coarse silt and fine sand are the particle sizes found to be most damaging through sedimentation in downstream river fringes. Particles of fine silt size (0.004 to 0.06 mm) and clay size (less than 0.004 mm) generally stay suspended in fast-flowing rivers and therefore do not pose a significant sedimentation problem in the Company‟s upland mine sites. However, more stringent effluent guidelines must be reached, as described in standard 5.3, before water leaves the site boundary, to prevent damage downstream. The limit of 50 mg/l should be achieved as per that standard. In severe rainfall events, the runoff rate may greatly exceed the capacity of any practical size of settlement pond. Flood attenuation ponds may therefore be required upstream to control the flow rate and to prevent the settlement pond from being overwhelmed, and leading to uncontrolled discharges to surface water courses. Attenuation ponds provide additional modulation of the runoff hydrograph. Attenuation ponds should be designed with a capacity to accommodate a 1 in 100-year return period storm of any duration, with the discharge restricted to match the rate of runoff that existed prior to mining. In this respect it must be taken into account that storms of several days duration may give more runoff than storms of a few hours duration, even though the latter may be of much greater intensity. The design calculations should therefore ensure that the attenuation will work for low frequency return period storms of: high intensity but short duration; and low intensity but long duration; or any combination of these. The design should constrict the flow rate entering the settlement pond to the treatment capacity of the pond and retain larger flows in the attenuation pond or bypass excess flow. In hydraulic design the rationale is to design for the common flow occurrence but consider what will happen during an over-design flow. The treatment standard can be compromised by excessive capacity: if a modular approach is used some modules will be only rarely used. That is why settlement pond design should be for normal flows in combination with attenuation for the management of peak flows. “Normal” rainfall can be considered as rainfall that occurs at least on several occasions in a single wet season. This will ensure that the attenuation ponds also function at least several times each year and do not become neglected and overgrown. The predicted 1-year return period 24-hour rainfall at the mine sites is 92 mm. The probabilities of 2- and 10-year return period rainfalls occurring over a 5-year period are 97% and 41% respectively, and the corresponding 24-hour rainfalls have been estimated as 123 mm and 161 mm. In all cases there must be a bypass spillway which will accommodate flows greater than that which the combination of ponds are designed to accommodate (1 in 100 years if attenuation is provided). For the Nimba Western Area Iron Ore Project, the following rainfall duration intensities are to be used as the estimated “normal” heavy rainfall that may occur at least twice per year, and the maximum expected in 1 in 100 years events. The user should note that these figures are only approximations, and are subject to change as more data are collected year on year, and weather patterns are gradually understood better.




Duration

Northern Nimba Mountains Buchanan Coastal Belt

“Normal” rainfall (twice per year)

Maximum rainfall (1 in 100 years)

“Normal” rainfall (twice per year)

Maximum rainfall (1 in 100 years)

1 hour period 50 mm 100 mm 80 mm 120 mm




Settlement ponds accumulate mine waste, so must be routinely cleaned and the waste disposed at a suitable spoil tip. It is therefore necessary to design the ponds to allow for cleaning. This may be achieved by dividing the ponds into compartments so that while one compartment is being maintained the remaining compartments have the required capacity for the design flow. Alternatively, it may be a single large compartment that can be cleaned during the dry season. The high fraction of silt observed during the baseline sampling of watercourses that have suffered mining legacy impacts indicates that it may be necessary to use chemical additives as flocculants to promote settlement of the fine particles. The presence of these chemicals must be considered when disposing of the settled waste from the ponds. Siting Settlement ponds that can trap significant volumes of sediment need to fit the following criteria.

Adequate volume that coarse silt- and sand-sized sediment settle out of suspension.

The smallest amount of construction for the settlement volume required.

Ease of access for initial construction and for subsequent annual cleaning. The optimal location for settlement ponds is where the long profile of the streams emanating from the mountains start to flatten off. On steep sections of stream course, large construction volumes are required to achieve adequate settlement volumes, especially with the high turbidity caused by fast-flowing water entering the pond. However, attenuation ponds may be located on relatively steep sections of stream course. For these structures, larger volumes and slower currents are not as important as for settlement ponds, as long as they are adequate for the retarding of peak discharges. It may also be better to have a larger number of attenuation ponds in order to act additionally as check dams to reduce flow rates on erodible sections of stream course. Where water courses have already been damaged by former LAMCO mining at Mount Tokadeh, settlement ponds should be located in areas where there has been substantial accumulation of sediment in the past (i.e. where the environment has already been spoilt). Where possible, settlement ponds should not be in major areas of swamp land, which are important for biodiversity. To avoid this, they should not be located too far from the mine (i.e. not too far from where the stream long profile flattens out). Construction A settlement pond is a simple construction, expected to consist of a simple dam and spillway, giving adequate upstream capacity to contain the volume of water and sediment needed to ensure time for settling out of the suspended sediment. The volume behind each dam needs to be calculated separately for each watercourse, on the basis of the design criteria above. However, in most cases the dam need be only a simple wall built across the valley and keyed well into the sides. The spillway should be sited at the point where the dam crosses the natural channel. Because of the heavy weathering of the rocks and soils of the terrain surrounding the mine sites, hard rock foundations are hard to attain. For this reason, flexible structures are preferred that can tolerate weak or unconsolidated foundations. In practice this means the use of gabion dams for both




settlement and attenuation ponds. However, since gabions are highly porous, for settlement ponds especially it is necessary to construct them with a silt-proof membrane. Gabion dams are simple modular structures that should be built with the following main principles.

The dam must be founded to a minimum of 500 mm below ground level at both the base and sides.

There must be a central spillway adequate to take the maximum flow volume.

The spillway outfall must be fully protected against scour, for example by a gabion mattress. This is to stop erosion downstream of the dam.

The inside of the dam must be lined with a geotextile membrane to stop silt from being washed through the gabion voids.

Where there are high volumes of discharge, a concrete capping is advisable to protect the gabion wires. This would be particularly important for attenuation structures if the stream is expected to contain abrasive suspended material.

The main features in the construction of a gabion dam are shown in the sketch below. The construction of gabions is covered by standard 6.9, and check dams are covered by standard 6.10.

Elevation

In cross-section, the normal width to height ratio is: width = ½ height + 0.5. Management Settlement ponds are to be cleaned out during each dry season and the accumulated waste taken to an approved spoil tip. The management regime is to ensure that the settlement pond has been cleaned to give the maximum storage capacity by the end of March in every year. Intense early storms can carry large volumes of sediment as they transport an accumulation of loose material from fresh workings. If flocculants are used, their residual effects are to be checked and the implications for the spoil tips assessed and managed accordingly. Source: ESIA recommendations and ArcelorMittal Liberia.

6.3 Standard for Mine Spoil Tips Spoil tips are required for the safe disposal of overburden from the mine. They shall be used only for inert rock. Material that contains living biota and qualifies as a soil resource shall be stockpiled according to the relevant standard. The design of spoil tips should accommodate progressive rehabilitation to ensure a minimum area of disturbance at any one time and to establish final rehabilitation at the earliest opportunity. Alternative uses for part of the material, such as in landfill or road construction, may also be possible. The standards for revegetation and erosion control should be referred to in this instance. The following basic objectives for spoil tips need be considered.




The height, footprint and shape of the spoil tip to be designed, having regard to the area of land available, the general topography of the area and the vegetation.

Spoil tips shall be properly formed, benched, and sloped at low angle. Retaining walls shall be constructed as necessary at the toe of the dumps. Check dams and other erosion control measures shall be installed to prevent soil erosion during heavy rain.

All completed surfaces of a spoil tip should be stable and able to resist long term erosion.

Wherever it is possible to use waste material for construction of facilities associated with the mine or to the benefit of the community, such as for road material or construction fill, the suitable material should be stockpiled separately so that it is not buried under or mixed with unusable material, and can be accessed and used whenever necessary.

Where top soil is present, it shall be removed and stockpiled for later use in low height dumps, duly covered with grass and vegetal cover to preserve its fertility and biomass.

Stockpiled topsoil shall be spread on completed surfaces of spoil tips and re-vegetated.

Drainage shall be constructed to accommodate heavy rainfall events of not less than a 1 in 10-year return period. Appropriate garland (annular) drains and drains at individual terraces shall be provided to guide the rainwater to drainage channels without washing material off the dumps.

Source: ESIA recommendations.

6.4 Standard for Topsoil Stripping, Stockpiling and Restoration Overview This standard provides guidance on the management of topsoil and subsoil in engineering operations. Topsoil is an important resource, both ecologically and economically, since it is the source of all terrestrial life. Topsoil is therefore classed as an asset and must be treated as a living entity. Under no circumstances is topsoil a waste material. Subsoil is an essential foundation to topsoil and where possible should also be saved to aid later rehabilitation. The recommended sequence for stripping, stockpiling and restoring of topsoil from a borrow area or other site, is as follows. The paragraphs below give details on how each step should be undertaken.

1. Delineate borrow (or other) area. 2. Delineate topsoil storage area. 3. Complete land access procedure. 4. Construct access tracks. 5. Clear vegetation and dispose. 6. Install drainage and silt traps. 7. Grub roots and stumps. 8. Strip topsoil from borrow area. 9. Place topsoil on designated storage. 10. Stockpile unusable subsoil if present. 11. Remove approved earthfill to construction site. 12. Replace subsoil if available. 13. Replace topsoil and rehabilitate. 14. Undertake revegetation works to restore habitat.

Field Identification of Topsoil Topsoil is the darker coloured surface layer that varies in depth depending on location, but in general is 100 to 150 mm in depth. It is the soil layer with the greatest proportion of organic matter (in the form of fine roots, decomposing plant material and microbial animals). In the Nimba forests, the organic carbon component in the surface horizon ranges from 4 to 10 percent, usually with higher levels under better-developed forest. Where there is any leaf litter on the soil surface, this should be considered part of the topsoil. Topsoil depth and quality generally increases from a hilltop to the toe of a slope. Swamps may contain considerable thicknesses of topsoil that are highly fertile if managed correctly.




With depth in the soil profile, the material becomes increasingly less weathered and thus of decreasing value as plant-growing material. This is the subsoil. The downward change is often gradual and thus it is a matter of judgement as to where to make the cut-off. However, the subsoil horizon from 150 to 500 or 600 mm contains soil that is of value in restoration, as it contains some organic material and raised nutrient levels, and is weathered to a consistency that will help facilitate later regrowth when it is re-laid as a foundation below the topsoil. Note, however, that lack of cleared land for storage space means that ArcelorMittal will not normally take subsoil for storage unless it is found between the topsoil and the approved borrow material.

Identification of topsoil and subsoil

Topsoil is the darker surface layer of soil. It is usually from the surface to a depth of 150 mm (6 in) or slightly more. It may include decaying plant material on the surface (dead leaves and sticks).

Subsoil is the weathered layer below the topsoil. This almost always extends to 500 mm (20 in) below the surface and sometimes much more. In most of the borrow areas, subsoil will be classed as approved engineering earthfill material and removed to the construction sites.

The illustrations below show typical soil profiles in the Nimba Mountains. In all of them, the topsoil layer is visible.

Distinct topsoil 200 mm thick

Subsoil to 600 mm depth Seasonally waterlogged swamp soil

Distinct topsoil 230 mm thick Subsoil to 800 mm depth Well-developed forest soil

Indistinct topsoil about 120 mm deep Subsoil to 1000 mm depth

Iron-rich steep mountain soil

Storage of Topsoil Topsoil storage areas are chosen to comply with ArcelorMittal‟s standards for soil management. The location for a soil stockpile shall be in a place where it will not erode, block drainage, or interfere with work on the site. The stockpile location must be selected to avoid steep slopes (gentler than 1:4 to avoid slippage), flood plains and natural channels. It shall be at least 30 metres from a water course, pond or swamp to prevent sedimentation and damage to riparian habitat. Topsoil should not be stored on another topsoil or subsoil of highly contrasting texture. Sandy topsoil over clay subsoil is a particularly poor combination, especially on slopes: water may creep along the junction between the soil layers and cause the topsoil layer to slip or slough. Subsoil should not be stored on top of topsoil. If necessary, the topsoil at a stockpile location must be stripped off and the subsoil laid down, before the topsoil is replaced on top of it. On large sites, re-spreading may be easier and more economical when soil is stockpiled in small piles located near the areas where it will be re-used. One process approved by ArcelorMittal for some borrow areas, is for removal and replacement of topsoil in successive strips as the borrowing moves across the area.




Before any topsoil is stored in a designated area, vegetation must be cut and a full drainage and sediment control system installed. The grubbing of stumps and roots may also be necessary to aid the processes of topsoil placement, management and later recovery for use in rehabilitation works. As far as the terrain allows, storage areas should be gently convex in design so that run-off is managed and does not lead to erosion and instability. The slopes used should be at a maximum angle of 18 to 20º to enable working, and subject to final assessment and sign-off by the authorised engineer to ensure that the slopes are stable in the short and long term. Where stockpiles are on slopes, the downward slope shall be adapted to retard run-off water and prevent erosion. Erosion control berms and appropriate drainage channels may be used to achieve this. An alternative is to create “moonscape” indentations to retard run-off, placed in a staggered manner to ensure they do not form continuous lines Management of Topsoil (and Subsoil) Stores The management of topsoil storage areas shall be determined on an area-by-area basis and an appropriate plan agreed. All storage areas will be in approved locations, with sites prepared as described above. The main management options are as follows.

Temporary storage of topsoil, with it replaced to site within the same dry season.

Longer term storage requiring management interventions, including revegetation, periodic aeration, erosion controls and other work.

Initial stabilisation followed by handover for approved use by the landowner under an agreement with ArcelorMittal‟s Resettlement Plan.

Topsoil stockpile height shall not exceed 1 metre. If space permits, where topsoil is being stockpiled on areas where agriculture will remain active as part of the management plan, then it should be limited in height to 0.5 m to retain topsoil characteristics (significant biological activity really continues only to a depth of 300 mm). Gentle compaction is necessary, but should be as light as possible, such as one pass by a tracked excavator or small bulldozer; but never by a roller or vibrating compactor. Soil stockpiles shall be protected against erosion and soil loss by temporarily planting or seeding with a locally collected species of grass. This must be done as soon as possible, but only when there is enough moisture in the soil for germination and growth. In the wet season, no stockpile shall be unprotected for more than 30 days after its formation. While vegetation is becoming established, the stockpile may need additional protection by a silt fence or other sediment barrier on the down-gradient sides. If stockpiles will not be removed within the same dry season as they were created, they should be stabilised with permanent vegetation to control erosion and weed growth. This will involve the planting of fast-growing pioneer shrubs or trees. No seeds or plants from sources outside Nimba County may be used on any revegetation sites under ArcelorMittal. Invasive plants also must not be used. This is on account of the need to protect the local biodiversity to the greatest extent possible. Staff of the ArcelorMittal Environmental Department will advise on which species and sources are acceptable. Fine-textured topsoil may need aeration periodically if there is a risk of waterlogging and the generation of anaerobic conditions. This can be achieved by turning down the stockpiles once a year, or using a chisel plough or tines on a small bulldozer, but the most suitable method will be dependent on the height of the stockpile. Revegetation may be required after the aeration operations. The depth of a subsoil stockpile is limited by stability concerns. As it is laid, the soil should be compacted in layers of 1 metre thickness. Usually a height of 3 metres is the maximum that should be permitted without stabilisation measures being required. Compaction is to ensure integrity, not to create a full engineering fill specification, and should be achieved using a few passes by a tracked machine.




Replacement of Topsoil (and Subsoil) on Borrow Areas Before spreading soil back on to a site, erosion and sedimentation control practices such as run-off water diversions, berms, and sediment basins shall be put in place. The slopes and elevations should be graded smooth for the receipt of soil. Slopes steeper than 1v:3h should not normally be considered for re-soiling, but instead should be protected by direct planting with suitable pioneer species. Topsoil shall be spread evenly over freshly laid subsoil in a layer of 150 to 200 mm depth (or as otherwise approved by the appropriate ArcelorMittal representative). When the soil is dry, light compaction shall be provided, such as by one pass by a tracked excavator or small bulldozer. When the soil is moist or wet, then it should be harrowed using standard agricultural implements, or raked by hand, to form a fine tilth. No topsoil operations shall be undertaken while it is muddy or when the subgrade is saturated. The running of vehicles over newly spread topsoil shall be minimised to avoid excessive compaction. Where embankments are being constructed (such as part of a permanent drainage system), the slope, ground and climatic conditions may reduce the ability of the topsoil layer to bind well with the subsoil layer. In these situations, offsetting lifts of material to create an uneven surface prior to topsoil placement should be considered. Where subsoil is available, its use should be considered as part of the rehabilitation process. Where the substrate has the characteristics of subsoil, particularly in terms of allowing root penetration and plant growth (i.e. similar physical and chemical properties to natural subsoil in a similar site), then it may be appropriate only to add topsoil and not to expend energy and resources in re-laying subsoil unnecessarily. A decision to take this approach must be approved by ArcelorMittal‟s Environmental Department staff based on soil characteristics and the particular site rehabilitation plan. Available subsoil may be better retained for the rehabilitation of sites with very poor substrate. Immediately prior to spreading any available subsoil, the subgrade should be loosened by disking or scarifying to a depth of at least 150 mm to ensure bonding between the layers. Subsoil shall be distributed uniformly to a minimum compact depth of 500 mm and compaction achieved using a few passes by a tracked machine. No soil shall be spread while it is muddy or when the subgrade is saturated. Any irregularities in the surface shall be corrected that result from stockpiling or other operations, to prevent the formation of depressions or water pockets. Placement of Topsoil on Engineered Structures The placement of topsoil on engineered structures shall be at the discretion of the appropriate ArcelorMittal representative. In some cases, especially on embankment slopes, it is better to plant vegetation straight on to the earthfill structure rather than to attempt to stabilise a veneer of topsoil. This is because unconsolidated topsoil can become saturated in heavy rain due to the discontinuity below it to a compacted and impermeable substrate; in extreme conditions this can lead to a small mud flow of the topsoil. In some cases topsoil may be specified in porous bags, especially at the toe of a slope, to allow vegetation to grow, while the bags provide temporary stability and protection from scour erosion. Rehabilitation of Topsoil Simply replacing topsoil back on top of an altered surface does not constitute rehabilitation. In the best cases, following topsoil placement, the only rehabilitation required is revegetation using planted grasses, as described in the next sub-section, and tending for a period of a few years to allow the processes of nature to aid the rehabilitation process. But in certain cases other work may be needed to ensure that the topsoil returns to a good condition. After stockpiling for periods of more than about six months, the topsoil characteristics will have altered so that only the surface 300 mm or so retains real topsoil characteristics, and the lower 700 mm or so starts to have characteristics more like subsoil.




In many site rehabilitation cases it is difficult to establish the right drainage regime for the soil. Sometimes it may be necessary to alter the compaction or the drainage system to achieve this. Compaction can be reduced by ripping or ploughing the soil, or increased by running machines over it. Frequently the problem lies in the discontinuity between a relatively loose replaced topsoil and the hard substrate below, which does not have the same physical characteristics of naturally occurring subsoil, or the same physical continuity with the topsoil. Therefore the surface conditions and drainage network in a re-engineered site may need to be quite different from what was there before disturbance. Compost or manufactured organic soil amendments can be added to topsoil to increase its organic content and assist in rebuilding soil micro-organism populations. Undecomposed organic materials such as wood bark or fibre, grass hay or grain straw should not be mixed into topsoil unless nitrogen fertiliser is included (organic material uses nitrogen to break down and decompose the fibres). Compost derived from livestock or green urban waste (cut brush) is far superior to non-composted manure or wood fibre. Some borrow areas may be utilised to introduce improved agricultural methods with members of the local communities. If this is done, an agreement may be made to take the area under the control of the livelihoods restoration component of the ArcelorMittal Resettlement Plan before rehabilitation is complete. Revegetation of Topsoil All topsoil surfaces must be revegetated as soon as there is enough moisture at the start of the rainy season to allow plant growth. In many cases, the seeds and residual plant parts in the topsoil will grow, giving the initiation of natural revegetation. However, some areas of topsoil require special treatment. These include, but may not be limited to, the following.

Alongside drains.

Alongside roads.

On slopes above water courses.

On steep slopes.

Around the crest of cut slopes. In these locations, intensive revegetation measures are essential. The appropriate ArcelorMittal representative will make a specific instruction as to the extent of revegetation on site, but as a general rule, at least four lines of planted grasses are required on all peripheries of topsoil stockpiles and rehabilitated borrow areas. ArcelorMittal Liberia does not permit the use of hydro-seeding or other mechanical applications of seeds or plants. This is because abundant native species of grass are available locally, and their planting by hand is an excellent way to increase local employment opportunities. The main revegetation technique is therefore the use of planted grass slips. Standard 6.12 gives the full details of the methods to be used. Part of the Nimba WRIOP Phase 2 Environmental and Social impact Assessment gives full details of appropriate grass species: Volume 4 Part 1.2, Grassland Botanical Impact Assessment. Other revegetation techniques that may be required are as follows.

Brush layers, made of hardwood cuttings of certain shrubs or small trees. These can be used to create stronger, more substantial barriers to erosion where run-off tends to be concentrated. This technique is described in Standard 6.13.

Tree or shrub seedling planting. Plants raised from seed in a nursery are planted on to a site to start the process of restoration of the forest vegetation community. ArcelorMittal operates a tree nursery in Yekepa, and other community and commercial nurseries also exist in the area (although plants may not meet specification). This technique is described in Standard 6.14.

Source: ArcelorMittal Liberia, based on recommendations from the US Department of Agriculture and UK government institutions




6.5 Standard for Constructing and Maintaining Earth Tracks Earth tracks shall be aligned to follow the best possible route. Wherever feasible, they shall avoid steep slopes and swamps. The amount of cut and fill shall be minimised. The adequate provision of culverts shall be ensured, both for capacity and frequency, and scour protection shall be provided as necessary. Catch pits shall be used to capture sediment at pipe culvert inlets and turnouts. The routine emptying of the catch pit sumps shall be included in the maintenance schedule. Soil conservation measures shall be provided as appropriate, including grassed and vegetated cut and fill slopes, grassed longitudinal road drains, check dams in drains for shallow gradients, and concrete or masonry lined drains for steep gradients. The creation of flattening gradients along roadside drains shall be avoided. A reduction in gradient causes sediment to settle and block the drain: this particularly applies in dips approaching an outfall to a watercourse because the gradient of the vertical alignment of the road flattens here. As far as it is possible ditches shall be formed with a constant or increasing gradient moving downstream. Silt traps shall be used where required on drainage outfalls. When carrying out machine maintenance, particularly when a grader is used, it must be ensured that vegetated drains are left intact, and silt is removed from the drains using an appropriate ditching machine or by hand. Graders and dozers must not be used to push waste material on to surrounding land (windrow). This material shall be recycled on to the track or disposed of at a suitable waste dump. Routine environmental monitoring shall be undertaken of the water quality downstream of all earth tracks.

6.6 Standard for Simple Drainage Systems Design Surface drains are installed in the surface of a slope to remove runoff water quickly and efficiently. Sub-surface drains are installed in the slope to remove ground water quickly and efficiently. In practice they can be installed to a maximum of 1.0 to 1.5 metres (although the design depends on site conditions). Siting Any slope less than 35º. Construction Always design drainage systems to run along natural drainage lines. Choose locations for the drains so that the maximum effect can be achieved using the minimum possible volume of construction. Always ensure that drain outfalls are protected against erosion. Only use a rigid geometrical pattern of drains on newly formed fill slopes where there are no clear natural drainage lines. Excavate a foundation until a sound layer to build on is located. Drains must be well founded like all other civil structures.




Run main drains straight down the slope. Feed side drains in on a herringbone or branch pattern. Never use contour drains: these block very easily and are also highly susceptible to subsidence. A blocked or cracked drain can create terrible damage as a result of concentrated water flow. Design and construct the drains in such a way that water can enter them easily on the higher side but not seep out on the lower side. Use weep holes and thick, black polythene membranes carefully to achieve this. A flexible design is usually an advantage. Concrete masonry can be easily cracked by the slightest movement in the slope, and then leakage problems result. If there is a risk of people or animals damaging the drain, make sure that the construction is strong enough (e.g. use gabion rather than dry stone construction). Once the drain is completed, backfill around it and compact the fill thoroughly. Apply appropriate bio-engineering measures (i.e. planting of vegetation) to enhance the effectiveness of the drain. Where the site requires deeper drainage and the machinery is available, drains can be drilled into the slope. Source: ArcelorMittal Liberia.

6.7 Standard for Slope Protection by Stone Pitching Design A slope or water spillway is armoured or protected with an unmortared stone covering. This gives a strong protection against running water. It is freely drained and will withstand considerable water velocities. Siting Any slope up to 35º. This technique is particularly useful on gully floors between check dams, and for scour protection by heavy runoff discharge or stream flow. It is also useful on slopes with a heavy seepage problem, in flood-prone areas or where vegetation is difficult to establish, such as on very hot, dry soils. Construction Prepare a sound foundation surface before constructing the stone pitching. It must be free of loose debris and topsoil, and trimmed to an even surface. Bed the stones down well into the slope surface. Excavate as necessary to ensure an even upper surface to the stone pitching. Build the stone pitching carefully, starting from the bottom and working up the slope. The stones must be fitted together firmly, as if it is a dry masonry wall. Stones should be perpendicular to the slope, with the main point or narrow side down. In drains and gullies, a rough surface can be left to retard water flow. For further strengthening it is best to plant grasses or hardwood cuttings of shrubs through the stone pitching.




Other options for strengthening are either to use a gabion mattress (of 0.3 to 0.5 metre thickness) instead of stone pitching; or to use cement mortar pointing. Main advantages. Stone pitching forms a strong and long-lasting method of reinforcing a slope surface and stopping gully development. Main limitations. Stone pitching is relatively weak when heavy water flow scours the floor and dislodges boulders (but it can be strengthened by planting grasses between the stones).


6.8 Standard for Spillways and Check Dams Lined with Soil-filled Bags Design A water course is armoured or protected with a covering that consists of bags filled with soil. This gives a protection against running water that can be made where stones are not available. Siting Any slope up to 35º. This technique is particularly useful on drain and gully floors for scour protection by heavy runoff discharge or stream flow. It is also useful on slopes with a heavy seepage problem, in flood-prone areas or where vegetation is difficult to establish, such as on very hot, dry soils. Construction Collect soil that is free of organic matter and has as low a clay content as possible, such as locally available nodular laterite or gravel. If sand or gravel are available, a mixture of 1:10 cement:fill can be used to strengthen the structure considerably. Fill empty bags with the soil, such as old cement or rice bags. Fill them only to about two-thirds capacity, so that they are not too tight when closed. Sew up the mouths of the bags with a needle and string. The individual bags are then ready to place in position. The base or foundation should be made ready for placing the filled bags by removing any loose soil. The spillway should be extended sideways to cover an extra 500 mm either side of the expected water channel width. The sides of the spillway should be keyed right into the surrounding ground at the sides, and should be raised at least 100 mm to form a channel: this ensures that water coming over the bags will then run down the middle and not scour the ends.

Invert level 500 to 1000 mm above floor of ditch

Soil bags keyed well into the sides of the excavation

Deep central channel for water to flow through without eroding the sides of the ditch

Old rice or cement bags filled with unsuitable subsoil or sand




A single or overlapping double thickness of filled bags should be laid on the prepared surface, starting from the bottom and working up the slope. The bags should be well keyed into each other so that gaps are minimised. Once the construction of the check dam or spillway is completed, backfill along the sides, and compact the fill thoroughly. Main advantages. If scoured at the foundation, soil bags are flexible and settle down, so that the check dam or spillway does not collapse. This structure can be used when no stones are available. Main limitations. Soil-filled bags are weak and cannot withstand much vehicle traffic. The bags may degrade in the sun and split open after a few years. They are essentially a temporary or emergency structure. Source: ArcelorMittal Liberia.

6.9 Standard for Stone-filled Gabions Design Gabion construction involves the use of mechanically prefabricated gabion baskets. These comprise:

mild steel wire galvanised with a heavy coating of zinc;

3.0 mm diameter hexagonal mesh with a normal mesh size of 80 mm x 120 mm, although this can be adjusted to suit the size of stone being used;

triple-twisted connections (i.e. twisted together in three half-turns) to reduce slippage and increase strength;

panel frames (selvedge) made up from 3.9 mm diameter wire;

wire for binding and connecting one basket to another, which is to be 2.2 mm diameter. In good practice, gabion wall construction is usually made up of 1 metre x 1 metre baskets with a maximum length of about 2 metres (see drawings below), although more often the end panels are prefabricated separately. The baskets are then staggered, as in brickwork, and with some gabions placed front to back. In this manner, the overall flexibility of the wall and the propensity for bulging or tearing apart is significantly reduced. Foundations The foundation excavation for a wall can initiate instability, creating a hazard for those carrying out the excavation and causing further clearance problems. In order to minimise such problems, it is always recommended that, whenever possible, wall construction is carried out in the dry season. Retaining walls should preferably be constructed in alternate bays, so that at least some support is maintained to the area of instability throughout the wall construction activity. The depth to a suitable founding level can often only be decided during construction, particularly for road-supporting retaining walls and small dams. The most important factors to take into account are as follows.

The origin of the material in the base of the excavation. Is it fill from earlier excavations (an indication is often to look at the ends of the excavation for any signs of the original ground) or is it more obviously original ground?

The type of material in the base of the excavation. Is it soil or weathered rock, or a mixture of soil and boulders?

The consistency of the material in the base of the excavation. Is it hard or soft, loose or intact, wet or dry?

The probability of a better foundation at a greater depth. Is it likely that there is harder or less variable material at a short depth below the surface of the excavation?

If the intention is to build a strong retaining structure, it is better to found a wall in material that is in-situ rock or residual soil, and not too variable in strength, so that a masonry wall can be constructed. If this is not possible, a gabion wall should be used. Probing the base of the excavation using a




Dynamic Cone Penetrometer (DCP) may help in the decision-making process and the following simplified table may be used as guidance. Gabion basket details

Standard gabion box of 1 x 1 x 2 metres. Further details on right

Gabion mattress, used for erosion prevention below dams or along river edges. Dimensions vary, with thicknesses of 300 to 500 mm.

Allowable bearing pressures

No of blows for 300mm

penetration

Equivalent mm per

blow

Allowable bearing pressure (kN/m2)

2m width foundation

4m width foundation

5 60 90 70

10 30 140 100

20 15 200 160

30 10 270 220

40 7.5 340 290

50 6 400 350

The table should be used with caution; in gravelly soils a single large stone could significantly distort the blow count. For most moderate size walls, a consistent DCP blow count of at least 20 blows per 300mm should indicate a satisfactory founding stratum. Construction Walls founded on smooth bedrock should either be keyed or dowelled into the bedrock. Compaction of backfill is also important for road-supporting retaining walls to reduce the possibility of long-term settlement of the road pavement. Care needs to be taken not to cause overloading of the




wall during the compaction process, and ideally small pedestrian rollers or plate compactors should be used to compact the fill immediately adjacent to the wall. The stone used to fill the gabions should be carefully packed by hand, of even tabular size, of a size double the mesh, and of good quality. Rounded river stone should be limited to a third of the total stone in any one basket, the remainder preferably dressed; long flat stones should be oriented from front to back. It is important to ensure that:

the end panels are properly wired in;

bracing wires are fixed to hold the sides of the basket when it is one third and two thirds full, to prevent the basket from bulging;

in long baskets, properly wired-in vertical cross panels are introduced within the basket at 1.0 metre intervals to reduce distortion and stone migration;

all baskets are wired together;

all basket lids are properly wired down. The ends of walls should be keyed into intact material by gradually reducing the height of the wall or by constructing an angled return into the hillside. This will also help to reduce ravelling and scour. In some circumstances where additional corrosion resistance is required, the use of PVC coated mesh and binding wire may be appropriate. Source: adapted from the Slope Maintenance Manual of the Lao PDR Ministry of Public Works and Transport.

6.10 Standard for Check Dams Design Check dams are simple physical constructions to prevent the downcutting of runoff water in gullies or at the outfalls of drains. They ease the gradient of the gully or drain bed by providing periodic steps of fully strengthened material. Check dams are designed to accept an active pressure of an unstable mass if it is applied in the future, while permitting a safe discharge of water (and perhaps debris) via a spillway. Check dams can be constructed with dry stone masonry, concrete-bound masonry or gabion. Gabion check dams have the advantage of flexibility and tolerance of poor foundations, but tend to be rather larger than masonry alternatives. For very small gullies, living plant materials or soil-filled bags may be used. Construct check dams using the best available materials. If possible, use dry stone masonry or gabions to improve drainage. If this will not work, use concrete-bound mortar. Siting Check dams may be constructed in any loose or active gully or drainage discharge point. Small check dams may be placed in any rill (small gully) that threatens to enlarge. In general, they may be used anywhere on a slope or drainage line where there is a danger of scour from running water. Choose locations for the check dams so that the maximum effect can be achieved using the minimum possible volume of construction.




Gabion check dam design features

Construction Excavate a foundation in the gully or drain bed until a sound layer is obtained to build on. For masonry, the base of the dam should be at least 660 mm thick if it is one metre high; for every additional metre of height, add a further 330 mm to the width. For gabion the usual ratio is width = ½ height + 0.5. If using concrete-bound masonry, include weep holes to drain water from behind the check dam and reduce hydrostatic pressure. The ends of the dam should be keyed right into the gully sides and should be raised at least 250 mm to form a central spillway or notch: this ensures that water coming over the dam will then run down the middle and not scour the ends. An apron must be provided below the dam to ensure that energy is dissipated and that flow continues in the centre of the gully below the check dam. This may use a gabion mattress or stone pitching. If the check dam is in a gully likely to take a large flow of water, cast concrete over the top layer. This should form a slab of 300 mm thickness and will prevent abrasion damage to the wire. Once the construction of the check dam is completed, backfill behind the wings and sides, and compact the fill thoroughly.




Design of gabion check dams for settlement ponds Wall width at base = 0.5 h + 0.5. Gabions are normally in square units of 1 metre, formed into boxes of 1 x 1.5, 1 x 2, 1 x 3 or even 2 x 3 metres. It is recommended that a check dam should be 4 metres high, including the wing walls. The bottom layer should be the foundation level, set into the ground. This gives a settlement pond depth of 2 metres at the lowest point. The length of the check dam depends on the ground conditions. They may be any length from 3 metres upwards. The width of the spillway also depends on ground conditions. It should be as wide as possible to minimise flow velocity. It must be narrow enough that all water coming over the spillway flows into the stream channel below. Where a high discharge is expected, the spillway surfaces of the gabion may be rendered with concrete.

Elevation

Cross-section

Source: ArcelorMittal Liberia; and adapted from the Slope Maintenance Manual of the Lao PDR Ministry of Public Works and Transport.

Spillway Ground surface

Gabions keyed into ground

Wing wall

Ground surface

Wing wall

Water / sediment at spillway level

Geotextile membrane

2 x 1 gabion box running sideways




6.11 Standard for Selection of Revegetation Techniques for Erosion Prevention Revegetation techniques should normally be used to cover bare soil slopes, to begin the process of restoring the natural habitat, to control soil erosion or to stabilise or prevent shallow landslips (i.e. where the depth to the sliding surface is shallow, up to 0.5 m). The table below summarises the best available techniques for different situations. Location Technique Advantages Disadvantages

Road cut slope in soil Grass planting in lines, using rooted slips.

Rapid and complete surface cover.

Requires a soil slope without too many stones. Slow to establish on hard cut slopes. Road edge or shoulder in soil

Fill slopes and backfill above walls Brush layers using hardwood

cuttings from trees or shrubs.

Instant physical barrier that interrupts runoff. Stronger than grass. Often successful on stony debris.

Can only be installed on slopes of 1V:1.25H or less, on unconsolidated materials. Small erosion gullies or small

seasonal stream channels

Other bare areas Tree planting using potted seedlings from a nursery.

Allows a long term forest mix of trees to be restored.

Takes a long time to establish a complete cover. Seedlings are vulnerable to grazing for a few years.

Materials for revegetation Grass slips are small sections of a grass plant, made by splitting up a large clump. The stems are cut down to a height of 100 to 200 mm and the roots cut back to 40 to 80 mm. There should be 2 or 3 stems per slip. Hardwood cuttings are taken from the branches of certain types of small trees. They are cut to be between 450 and 600 mm long, and the diameter should be between 20 and 40 mm in diameter. Shoots and leaves are trimmed off. It is very important that plant materials for revegetation works are kept cool and damp when they are being moved and prepared. Source: ArcelorMittal Liberia, adapted from Nepal Department of Roads Bio-engineering Manual.




6.12 Standard for Revegetation using Planted Grasses Function Grass slips (rooted cuttings), rooted stem cuttings or clumps grown from seed are planted in lines on the slope. This form of revegetation uses large clump grasses. Grasses planted in contour or horizontal lines protect the slope with their roots and, by providing a surface cover, reduce the speed of runoff and catch debris, thereby armouring it. Grasses planted in diagonal lines protect the slope with their roots and by providing a surface cover, while at the same time helping to drain surface water. They have limited functions of catching debris and draining surface water. The main engineering functions are to armour and reinforce the soil surface, with secondary functions to catch debris and drain moisture. This technique offers the best compromise of the grass line planting systems in many situations. Sites Almost any slope less than 50º. Contour or horizontal lines are used on all slopes less than 35º. Also on steep (35º to 50º) dry sites, where moisture needs to be conserved. They are most widely used on well-drained materials where increased infiltration is unlikely to cause problems. On cultivated slopes, horizontal lines of grass planted at intervals across a field can be used to avoid loss of soil and to help conserve moisture, as a standard soil conservation measure. Diagonal lines are used on poorly drained materials on steep slopes (35º to 50º) where an increase in infiltration can lead to liquefaction of the soil. It is also useful on damp sites, where moisture needs to be shed. Timing Planting work should only be done in the wet season. The slope should be moist when the planting is done. If it does not rain within 24 hours of the work being done, water the plants every day until it does rain. On small sites this may be done by hand but on large sites it will require a water truck and spray cannon. Spacing of plants Line spacing depends largely on the steepness of the slope. Within rows: plants at 100-mm centres. Row spacings: rows at 500-mm centres for diagonal lines; for contour lines: slope < 30º: 1000 mm; slope 30-45º: 500 mm; slope > 45º: 300 mm. Materials Grass slips are small sections of a grass plant, made by splitting up a large clump. The stems are cut down to a height of 100 to 200 mm and the roots cut back to 40 to 80 mm. There should be 2 or 3 stems per slip. The clumps must be obtained locally (i.e. from similar terrain within 15 km of the planting site) where their loss will not cause soil erosion to start. The source location should have similar environmental characteristics (altitude and soil particularly) to the destination site. The material must be between 6 and 18 months old. Grass clumps must be dug up and brought to site on the same day that the slips are made and planted, and kept cool and moist.




Construction Prepare the site well in advance of planting. Slopes should be trimmed to an even grade that meets Standard 6.16. Trimming should achieve a slope that meets the appropriate design for the material. If there is no design, it should be cut or finished with a straight profile, without undulations that give over-steep portions that are steeper than the grade appropriate for the material. After slope trimming, remove all debris and either remove or fill in surface irregularities so that there is nowhere for erosion to start. If the site is on backfill material, it should be thoroughly compacted, preferably when moist. Always start grass planting at the top of the slope and work downwards. Mark out the lines with string, using a tape measure and spirit level. Make sure the lines run exactly as required by the specification. Split the grass plants out to give the maximum planting material. Trim off long roots and cut the shoots off at about 100-mm above ground level. Wrap the plants in damp hessian to keep them moist until they are planted. With a planting bar (typically a 500-mm section of re-bar with a flattened end), make a hole just big enough for the roots. Place the grass into the hole, taking care not to tangle the roots or have them curved back to the surface. Fill the soil in around them, firming it gently with your fingers. Take care to avoid leaving an air pocket by the roots. If it looks dry and there is no prospect of rain for a day or two, consider watering the plants by hand. Example illustration Grass slips are planted in lines across the slope. The best results usually come from lines that are at 45

o to the maximum

slope. Start from the top and work downwards. Mark out the lines on the slope and then plant the grass slips to the original depth and gently firm the soil back around them. Source: ArcelorMittal Liberia, adapted from Nepal Department of Roads Bio-engineering Manual.

6.13 Standard for Revegetation using Hardwood Cuttings (Brush Layers) Function Woody (or hardwood) cuttings are laid in lines across the slope, usually following the contour. Brush layers protect and reinforce a slope in weak soil. They catch debris and provide a strong and low-cost barrier to erosion, especially on debris slopes, however loose. Sites This technique can be used on a wide range of sites up to about 45º. It is particularly effective on debris sites, fill slopes and high embankments.




Timing Planting work should only be done in the wet season. The slope should be moist when the planting is done. If it does not rain within 24 hours of the work being done, water the plants by hand every day until it does rain. Spacing Spacing between brush layers depends on the steepness of the slope. The following spaces should be used. Slope less than 30º 2-m interval; Slope 30 to 45º 1-m interval. Within the brush layers, cuttings should be at 50 mm centres, in the double layer described below. Materials Cuttings made from woody material of shrubs or trees that coppice well. They must be obtained locally (i.e. within 3 km of the planting site). The material must be between 6 and 18 months old. Cuttings shall be 20 to 40 mm in diameter and 450 to 600 mm long. When taking the cuttings, cut the top at right angles to the stem and the bottom at 45º to make it clear as to which way they should be inserted. Cuttings must be taken the same day that they are to be planted, and kept cool and moist. Construction Prepare the site well in advance of planting. Slopes should be trimmed to an even grade that meets Standard 6.16. Trimming should achieve a slope that meets the appropriate design for the material. If there is no design, it should be cut or finished with a straight profile, without undulations that give over-steep portions that are steeper than the grade appropriate for the material. After slope trimming, remove all debris and either remove or fill in surface irregularities so that there is nowhere for erosion to start. If the site is on backfill material, it should be thoroughly compacted, preferably when moist. Using string, mark the lines to be planted, starting 500 mm from the base of the slope. Always install brush layers from the bottom of the slope, and work upwards. Form a small terrace, with a 20% fall back into the slope. The terrace should be 400 mm wide. If you are brush layering a gravel-filled road embankment you should lay a 50-mm thick layer of soil along this terrace to improve rooting conditions. Lay the first layer of cuttings along the terrace, with a 50-mm interval between the cuttings. Leave at least one bud and up to 1/3 of the cuttings sticking beyond the terrace edge and the rest inside. The branch growing tips should point towards the outside of the terrace. Lay a 20 mm-thick layer of soil in between the cuttings to provide a loose cushion. Lay a second layer of cuttings on top of this, staggered with the first layer. On a gravel-filled embankment slope lay an 80-mm layer of soil over the cuttings before you do any backfilling. Partly backfill the terrace with the excavated materials. This should not be more than 50 mm thick. Mark a line 1 metre above the first brush layer and set the string for the next layer. Repeat the process. As the next terrace is cut, always fill the lower bench with the material excavated from above and compact it reasonably well by gentle foot pressure.




Good site supervision is essential to ensure that lines run along the contours and do not concentrate runoff; also to make sure that cuttings are not allowed to dry in the sun. Well-buried cuttings have a higher survival rate. Example illustration Mark out horizontal lines every 2 metres down the slope. Start from the bottom and work upwards. Dig shallow trenches along the lines, 350 to 450 mm wide. Lay the cuttings across the trenches with the bottom inwards and 80 to 100 mm of the top protruding from the slope. The cuttings should be 50 mm apart. Place a small amount of soil over the cuttings and then lay another line of cuttings. Replace all the soil and firm it down gently. Source: ArcelorMittal Liberia, adapted from Nepal Department of Roads Bio-engineering Manual.

6.14 Standard for Revegetation using Shrub and Tree Seedlings Function Shrubs or trees are planted at regular intervals on a bare area of soil. As they grow, they create a dense network of roots in the soil, helping to reinforce it against erosion or mass failure. It helps to re-establish a vegetation cover on disturbed areas. Sites This method can be used without adverse effects on almost any slope up to 30º. With care, it can be used on slopes between 30º and 45º. It can be used on any material and site other than bare rock. Timing Planting work should only be done in the wet season. The slope should be moist when the planting is done. If it does not rain within 24 hours of the work being done, water the plants by hand every day until it does rain. Spacing The spacing of plants is important. The main considerations are cost and the speed with which a full cover is required. In typical forestry sites, a spacing of 2 × 1 metres is normal, requiring 2,500 plants per hectare. However, in revegetation sites a spacing of 1 × 1 metre is usually necessary, requiring 10,000 plants per hectare. Plants should be planted in off-set rows unless a different pattern is needed for specific erosion control or landscaping effects. Construction Prepare the site well in advance of planting. Remove all debris and remove or fill surface irregularities. If the site is on backfill material, thoroughly compact it, preferably when it is moist. Cut all weeds. If possible, dig pits for the shrubs or trees in advance of the planting programme, but refill them the same day. Pits should be 300-mm deep and 300-mm in diameter if this is possible without causing excessive damage to the slope.




When the ground is wet enough to support reasonable growth, plant out good quality seedlings from a nursery. The bigger the hole made, the better it is for the plant; but there must be a compromise between helping the plant and avoiding excessive disturbance to the slope. Carefully remove the pot. If it is a polythene bag, do this by slicing it down the side with a razor blade. Take care not to cut the roots. Plant the seedling in the pit, filling the soil carefully around the cylinder of roots and soil from the pot. Ensure there are no cavities. Firm the soil all around the seedling with gentle foot pressure. If available, mix a few handfuls of well-rotted compost with the soil around the roots when you are backfilling the hole. Remove any weeds around the plant. Add mulch around the seedling, but with a slight gap so that it does not touch the stem. Main advantages. Planting shrubs and trees reinforces and restores a slope by establishing a community of larger plants. Main limitations. Seedlings take about 5 years (or more) to provide a canopy, produce useful materials or contribute significantly to slope strengthening. Care and protection are required in the first three years. Source: ArcelorMittal Liberia, adapted from Nepal Department of Roads Bio-engineering Manual.

6.15 Standard for Drainage Systems on Major Roads Major roads are significant features in the landscape. In particular, they interfere with the flow of surface water and shallow groundwater in the slopes that they cross. The surface of the road can also produce large volumes of water during heavy rain, and special provisions need to be made to dispose of this safely. Natural drainage systems are unlikely to be able to accommodate major additional flows of this nature without an adverse effect such as erosion. Water can cause widespread damage to surrounding land through erosion, which, once started, can be difficult and expensive to rectify. Water can also cause extensive damage to the road itself by weakening the pavement or foundations, and eroding the side slopes. This is a world-wide feature of highway engineering, but is of particular importance in wetter climates such as that of Liberia.

This illustration shows the main drainage features of a major gravel road. It is important to use side drains both to catch water running off the road and to prevent water from the surrounding slopes from getting on to the road. On sloping road sections, if side drains are not lined with masonry, scour checks are needed to prevent them from eroding the sides of the road. Side drains must be discharged as often as possible to avoid the build-up of large water flows. On the lower side of a road this is easily achieved through a mitre or turnout into the bush. On the higher side it requires the installation of a culvert to take the flow across the road. Culverts must also be able to accommodate natural water courses. Cut off or catch water drains can be used to reduce natural water entering cut slopes.




The drainage system of a road is therefore its most important feature to ensure that the investment and is safeguarded and reliability of service assured. The purpose of the drainage system is to collect and conduct water away from the road, and to ensure that no area of the road remains waterlogged. Major roads are to be cambered to shed water on either side, except on sharp bends where the road surface may be super-elevated to shed water only on one side. The angle of camber or super-elevation should be a minimum of 2 degrees but 4 to 5 degrees is an optimum. Side drains are to be provided all along both sides of every major road except where the filled embankment slope exceeds 1 metre in height. They should normally be between 0.5 and 1.0 metre deep and 1.0 to 1.5 metre wide. The cross section can be curved, triangular or trapezoidal. If they are unlined, a trapezoidal section with a base width of 0.3 to 0.5 metre is usually easiest to maintain. Examples of three different types of drain protection are shown in the illustrations below. The two on the left hand side are made with stone, concrete blocks or bricks. That on the right uses concrete slabs.

Scour checks are to be provided in earth side drains wherever the longitudinal gradient of the road is steep enough that the water running along the drain may erode the base or sides. This can be anywhere that the road or drain gradient exceeds 5 degrees (1:12), depending on the strength and cohesiveness of the soil. Scour checks should be placed no more than 10 metres apart. They are most easily made of stone (below left) but can also be made using wooden stakes (below right). The centre of the scour check must be lower than the sides, to keep water flow in the middle of the drain. It is also important to provide erosion protection for the turbulent water immediately downstream of the scour check, such as a bed of rocks.

Mitre or turn out drains are to be provided as frequently as possible on the lower side of the road, and should never be more than 50 metres apart unless a cutting makes this impossible. The turn outs should terminate in a densely vegetated area of bush, where the vegetation is adequate to prevent erosion even by a prolonged maximum flow from the side drain. If there is any doubt of this, then additional vegetation planting will be necessary, or the installation of a water dissipation structure such as a gabion or concrete cascade or stilling basin. Culverts are to be provided at all natural drainage lines, and must have a capacity at least double that of the maximum flow of water in the combined natural water course and roadside drain. Where there are few natural water courses, culverts must be provided as frequently as possible to transfer drain water from the higher to the lower side of the road. This may be possible in depressions in the topography. If these are not natural water courses, then they must be fully protected against erosion by the water from the road.




Culvert outfalls are to be fully protected against scour. For smaller culverts with limited flow this can be achieved simply and cheaply as shown below (left): a raft of rock fill is provided where the water discharges from the culvert into the lower side channel. For locations where flows are likely to be substantial, a properly constructed stilling basin may be necessary (below right): the concentrated water flow is stilled before being discharged into the channel below at a low velocity.

Natural water courses are to be protected against erosion at all times. The presence of the road may alter water flow to the extent that much greater volumes are channelled into it than it is able to bear without the bed or sides starting to erode. This is particularly the case where runoff from the road and its side drains is discharged into the water course. Check dams should be installed as necessary in natural water courses to prevent the destabilisation of the channel and the initiation of erosion. Cut off or catch water drains should only be installed above roadside cut slopes where there is seepage or a regular flow of water on the surface. This will help to dry out the slope and reduce the likelihood of mass failure or erosion. In most places, however, cut off drains above the road are rarely kept properly clean because they are out of sight in the bush and so are not maintained. For this reason they can pose a hazard and should be avoided unless there is a particular reason for them to be installed. Embankment slopes must be fully protected against erosion, whether there is a side drain installed or not. However well the road surface is graded, runoff is never uniform over the edge of the road. Instead, it tends to accumulate in small rivulets which run along certain courses each time it rains. These have the potential to cause erosion unless the side slopes are well vegetated. In exceptional cases, physical erosion protection is also required, such as stone pitching. Source: ArcelorMittal Liberia; illustrations from PIARC International Road Maintenance Handbook 1994.

6.16 Standard for Slope Cutting Grades Some tropical residual soils (e.g. laterite gravels) will remain stable for many years at slope angles of 63 to 70 degrees, and rainfall infiltration and gullying may increase at lower angles unless the slope is vegetated. Nevertheless, field observations suggest that the following slope angles are appropriate for new cut slopes in infrastructure development.

Soft material: 45 degrees (1V:1H);

Transition material: 63 degrees (1V:0.5H), where discontinuities are favourable;

Hard (strong) rock: 76 degrees (1V:0.25H), where discontinuities are favourable. Where discontinuities are unfavourable, cut slope angles need to be designed according to the orientation and frictional strength along joint surfaces. Slope stabilisation measures in cuttings where significant recent failures have occurred therefore consist of cutting back affected sections to 1V:1H and carrying out appropriate revegetation and drainage work, including strengthening at the toe to ensure that the toes of slopes are not undercut. Locations where minor failures have occurred need to be monitored and stabilised if the problem worsens. Source: Phase 2 Environmental and Social Impact Assessment.




7. NOISE, VIBRATION AND RADIATION STANDARDS

7.1 Standard for the Limitation of Noise Emissions Introduction and Measurement Between the quietest audible sound and the loudest tolerable sound there is a million-to-one ratio in sound pressure (measured in Pascals or Pa). Because of this wide range, a noise level scale based on logarithms is used in noise measurement, called the decibel (dB) scale. Audibility of sound covers a range of approximately 0 to 140 dB. The human ear system does not respond uniformly to sound across the detectable frequency range and consequently instrumentation used to measure noise is weighted to represent the performance of the ear. This is known as the 'A weighting' and annotated as dB (A). The table below lists the sound pressure level in dB (A) for common situations. Sound pressure levels for a range of situations

Typical noise levels dB(A)

Example

0 Threshold of hearing

30 Rural area at night, still air

40 Public library; refrigerator humming at 2 metres

50 Quiet office, no machinery; boiling kettle at 0.5 metre

60 Normal conversation

70 Telephone ringing at 2 metres; vacuum cleaner at 3 metres

80 General factory noise level

100 Pneumatic drill at 5 metres

120 Discotheque – 1 metre in front of loudspeaker

140 Threshold of pain

The noise level at a measurement point is rarely steady, even in rural areas, and varies over a range dependent upon the effects of local noise sources. C lose to a busy road, the noise level may vary over a range of 5 dB(A), whereas in a suburban area this may increase up to 40 dB(A) and more due to the multitude of noise sources in such areas (cars, dogs, aircraft etc.) and their variable operation. Furthermore, the range of night time noise levels will often be smaller and the levels significantly reduced compared to daytime levels. The equivalent continuous A-weighted sound pressure level, LAeq, is the single number that represents the average sound energy measured over that period. The LAeq is the sound level of a notionally steady sound having the same energy as a fluctuating sound over a specified measurement period. Human subjects are generally only capable of noticing changes in noise levels of no less than 3 dB(A). It is generally accepted that a change of 10 dB(A) in an overall, steady noise level is perceived to the human ear as a doubling (or halving) of the noise level. A parameter that is widely accepted as reflecting human perception of the ambient noise is the background noise level, LA90. This is the noise level exceeded for 90% of the measurement period and generally reflects the noise level in the lulls between individual noise events. Over a one hour period the LA90 will be the noise level exceeded for 54 minutes. The parameter LA10 is used to describe road traffic noise. This is the noise level exceeded for 10% of the measurement period. Over a one hour period, the LA10 will be the noise level exceeded for 6 minutes.




Acceptable Noise Levels No operations of the Company or its Contractors should exceed the levels of, or exposures to, noise as given in the tables below. Where it is not feasible to reduce noise levels to those given below, suitable earth bunds or other barriers to the lateral spreading of noise shall be designed and installed to ensure compliance. Noise impacts should not exceed the levels given in the tables below. These are given as façade levels at the wall of a property (e.g. just outside a window). Façade level is 3 dB(A) higher than the free-field level due to reflection from the façade. Maximum permissible noise levels for the general environment

Facility Noise Limits B (A) (Leq)

Day Night

A. Any building used as hospital, convalescence home, home for the aged, sanatorium and institutes of higher learning, conference rooms, public library, environmental or recreational sites

45 35

B. Residential buildings 50 35

C. Mixed residential (with some commercial and entertainment) 55 45

D. Residential + industry or small-scale production + commerce 60 50

E. Industrial 70 70

Note: Day: 6 am to 10 pm. Night 10 pm to 6 am.

Maximum permissible noise levels for construction sites

Zone Sound Level dB (A) (Leq)

Day Night

Residential 55 45

Commercial 75 50

Industrial 85 85

Note: Day: 6 am to 10 pm. Night 10 pm to 6 am.

Maximum permissible noise levels from a factory or workshop

Leq dB (A) Duration (Daily) Duration (Weekly)

85 8 hours 40 hours

88 4 hours 20 hours

91 2 hours 10 hours

94 1 hour 5 hours

97 30 minutes 2.5 hours

100 15 minutes 1.25 hours

103 7.5 minutes 37.5 minutes



Note: Continuous or intermittent noise

Noise Levels shall not exceed a Leq of: (i) Factory/Workshops 85 dB (A) (ii) Offices 50 dB (A) (iii) Factory/Workshop Compound 75 dB (A).




Maximum permissible noise levels for impact or impulsive noise

Sound Level dB (A) (Lmax) Permitted number of impulses or impacts per day

140 100

130 1,000

120 10,000

Noise Standards for Automobiles (a) Noise limits for automobiles at a distance of 7.5 metres at the time of manufacture

No. Vehicle dB(A)

1 Motorcycle, scooters and three wheelers 80

2 Passenger cars 82

3 Passenger or commercial vehicles up to 4 tonnes 85

4 Passenger or commercial vehicles between 4 and 12 tonnes 89

5 Passenger or commercial vehicles exceeding 12 tonnes 91

(b) Maximum permissible noise levels for accelerating vehicles

No. Vehicle dB(A)

1 Vehicles intended for carriage of passengers and equipped with not more than nine seats, including the driver‟s seat

78

2 Vehicles intended for carriage of passengers, and equipped with not more than nine seats, including the driver‟s seat and having maximum permissible mass of more than 3.5 tonnes

a) - with an engine power of more than 150 KW 80

b) - with an engine power of less than 150 KW 83

3 Vehicles intended for carriage of passengers and equipped with more than nine seats including the driver‟s seat: vehicles intended for carriage of goods

a) - with a maximum permissible mass not exceeding 2 tonnes 79

b) - with a maximum permissible mass exceeding 2 tonnes but not exceeding 3.5 tonnes

80

4 Vehicles intended for the carriage of goods and having a maximum permissible mass exceeding 3,5 tonnes

a) -with an engine power of less than 75 KW 81

b) -with an engine power of not less than 75 KW but less than 150KW 83

c) -with an engine power of not less than 150 KW 84

Source: ESIA and adapted from Liberia Environmental Protection Agency Draft Regulations (September 2010).

7.2 Standard for Radio and Microwave Emissions Electromagnetic radiation from radio and microwave transmitters is limited to two sets of exposure levels. The first is for the general public and the second for trained workers in controlled conditions. Uncontrolled exposure limits for the general population apply in all situations in which the general public may be exposed. They also apply in situations in which persons that are exposed as a consequence of their employment may not be fully aware of the potential for exposure, or cannot exercise control over their exposure.




Limits for uncontrolled exposure by the general population

Frequency Range (MHz)

Electric Field Strength (E)

(V/m)

Magnetic Field Strength (H)

(A/m)

Power Density (S)

(mW/cm2)

Averaging Time |E|

2, |H|

2 or S

(minutes)

0.3-1.34 614 1.63 (100)* 30

1.34-30 824/f 2.19/f (180/f2)* 30

30-300 27.5 0.073 0.2 30

300-1500 -- -- f/1500 30

1500-100,000 -- -- 1.0 30

f = frequency in MHz *Plane-wave equivalent power density

Controlled occupational limits apply in situations where persons are exposed as a consequence of their employment, provided those persons are fully aware of the potential for exposure and can exercise control over that exposure. Limits for controlled occupational exposure also apply in situations when an individual is transient through a location where controlled occupational limits apply, provided that the person is made aware of the potential for exposure. Limits for controlled occupational exposure

Frequency Range (MHz)

Electric Field Strength (E)

(V/m)

Magnetic Field Strength (H)

(A/m)

Power Density (S)

(mW/cm2)

Averaging Time |E|

2, |H|

2 or S

(minutes)

0.3-3.0 614 1.63 (100)* 6

3.0-30 1842/f 4.89/f (900/f2)* 6

30-300 61.4 0.163 1.0 6

300-1500 -- -- f/300 6

1500-100,000 -- -- 5 6

f = frequency in MHz *Plane-wave equivalent power density

Source: adapted from Federal Communications Commission, Office of Engineering and Technology, Bulletin 65 (August 1997).

7.3 Standard for the Limitation of Vibrations and Air Overpressure Ground vibrations: introduction and measurement When an object is in contact with a vibrating surface it is displaced about its reference (stationary) position. Displacement (in mm) is therefore one parameter that can be used to describe the magnitude of a vibration. For sinusoidal signals, displacement, velocity (mms

-1) and acceleration

(mms-2

) amplitudes are related mathematically by a function of frequency and time. If phase is neglected (as is always the case when making time-average measurements), then the velocity can be obtained by dividing the acceleration signal by a factor proportional to frequency (measured in Hertz, Hz) and the displacement can be obtained by dividing the acceleration signal by a factor proportional to the square of frequency. Modern electronic integrating meters are capable of providing a wide range of measurement parameters during any single vibration measurement. For a complex acceleration signal giving rise to a complicated time history, there are several additional quantities which can be used to describe the vibration:

The root mean square value (rms) is obtained by taking the square root of the means of the sum of the squares of the instantaneous acceleration measured during the total measurement time (T);

The peak value is the maximum instantaneous acceleration measured during the measurement time, T. It is a useful indicator of the magnitude of short duration shocks; and

The peak particle velocity (ppv) is the maximum instantaneous velocity of a particle at a point during a given time interval.




Context In general, buildings are reasonably resilient to ground-borne vibration and vibration-induced damage is rare. Vibration-induced damage can arise in different ways, making it difficult to arrive at universal criteria that will adequately and simply indicate damage risk. Damage can occur directly due to high dynamic stresses, due to accelerated ageing or indirectly, when high quasi-static stresses are induced by, for example, soil compaction. Given the construction of many of the residential properties in rural Liberia (sun-dried clay blocks, with a very thin concrete skim direct on to the clay) and the likely levels of ground borne vibration, it is considered that these types of properties will not suffer from cosmetic damage due to vibration. Measurements are therefore recommended only for short duration vibrations (such as from blasting) or for particular, very sensitive receptors. The British Standard BS 7385-2:1993 (Evaluation and measurement for vibration in buildings – Part 2: Guide to damage levels from ground borne vibration) provides guidance on vibration levels likely to result in cosmetic damage (e.g. plaster cracks). Limits for transient vibration, above which cosmetic damage could occur, are given in the table below, taken directly from that standard. Transient vibration levels for cosmetic damage The vibration velocities given in the table below must be adhered to in relation to company activities.

Type of Building

Peak component particle velocity in frequency range of predominant pulse

4 Hz to 15 Hz 15 Hz and above

Reinforced or framed structures Industrial and heavy commercial buildings

50 mms-1

at 4 Hz and above

Un-reinforced or light framed structure Residential or light commercial buildings

15 mms-1

at 4 Hz increasing to 20 mms

-1 at 15 Hz

20 mms-1

at 15 Hz increasing to 50 mms

-1 at 40 Hz and above

Notes. 1. Values referred to are at the base of the building. 2. For un-reinforced or light framed structures and residential or light commercial buildings, a maximum displacement of 0.6 mm (zero to peak) is not to be exceeded.

The guide values relate predominantly to transient vibration which does not give rise to resonant responses in structures. Where the dynamic loading caused by continuous vibration is such as to give rise to dynamic magnification due to resonance, especially at the lower frequencies where lower guide values apply, then the guide values in the table may need to be reduced by up to 50%. Air overpressure limits Air overpressure (or blast overpressure) is the pressure or high energy impulse noise caused by a shock wave over and above normal atmospheric pressure. Based on a review of international standards, the figure of 133 dB (L) is adopted at 500 metres from the blast site (the standard evacuation zone) or at the nearest non-quarry-related structure if closer. Standard measures to reduce ground vibrations and air overpressure in blasting The following standard measures shall be used in all blasting operations by or on behalf of company, to reduce ground vibrations and air overpressure. It is recognised that these are difficult to predict owing to the many factors involved in ground conditions, distance to receptor, atmospheric conditions and the intention of individual blasting operations.

Explosive quantities shall be minimised to the least amount required to accomplish the required task.

The spacing of blast holes shall be optimised so as to accomplish the required task with the least amount of explosive possible.

http://en.wikipedia.org/wiki/Shock_wave

http://en.wikipedia.org/wiki/Atmospheric_pressure




Detonator timings shall be optimised to minimise ground vibrations. Normally the standard 8 millisecond rule between blast holes shall apply, unless the use of electronic timers allows for better patterns.

Burden depth and blast hole diameter shall be optimised to obtain the best balance between reduced ground vibrations and reduced air overpressure.

It is expected that the quarry operator will undertake a series of trials to reach the optimal reduced ground vibration and air overpressure impacts over the first five blasts at a particular site. Source: ESIA, British Standards and ArcelorMittal.

7.4 Standard for Use of Instruments with Sources of Ionising Radiation All instruments that contain sources of ionising radiation (i.e. radioactive isotopes) imported and used in Liberia must be covered by a specific permit issued by the Environmental Protection Agency. From the point of import, throughout transport, handling, installation, use and disposal, the radiation source must be under the direct control and responsibility of a trained and competent company employee who shall be no lower than manager level. All permit and manufacturer‟s conditions for transport, handling, use and disposal shall be followed at all times. Once the radioactive source is received on site, it shall be stored in a locked room with controlled access. Its movements and use from this point onwards shall be monitored by a designated radiation safety officer. When the radioactive source is installed in its operating position, appropriate warning signage shall be installed and the potentially exposed workforce educated in the meaning of the signs. The source container will have a plate giving the local dose rate within a specified distance. This will be verified by measurement immediately after installation. An exclusion zone will be clearly marked out with physical barriers and appropriate warning signage to ensure that there can be no accidental straying of personnel into the zone of potential danger. The activation of radiation beams must be undertaken only by specially trained personnel, who must follow the manufacturer‟s instructions completely. The responsible manager and the radiation safety officer shall jointly determine a standard operating procedure for all instruments that incorporate ionising radiation sources. This shall incorporate a radiation safety plan that uses the standard radiological working procedures of minimising personnel exposure by a judicious consideration of time, distance and shielding factors. The responsible manager and the radiation safety officer shall also prepare an emergency response plan to be activated in the event of any accident or other emergency event. Once the use of the radioactive source has been completed, it shall be returned to the manufacturer or other certified receiving agent for disposal. There are no such receiving agents in Liberia. Before transport out of the plant, the source shall be sealed into a suitable robust shipping package. This shall be inspected for radioactive leaks and shall have a valid international test certificate showing it to be safe. [Source: ArcelorMittal Liberia]




8. VISUAL APPEARANCE STANDARDS

8.1 Standard for the Colours of Structures Where safety is of concern, then colours shall be or an appropriate eye-catching colour. This shall apply to mobile machinery, safety guards, steps, handrails etc. These should typically be painted a bright yellow, such as RAL 1021 (“safety yellow”). Otherwise paint colours are intended to provide the right balance between safety and blending into the landscape. It is generally recognised that it is safer for the workers in an environment with the framings painted in a visible colour, especially at night. Buildings, fixed plant, roofs, chimneys and other structures should blend into the landscape as far as possible.

At the mine and concentrator sites, and for industrial facilities around the town of Yekepa, the colour to be used on the cladding and roofs of these fixtures is RAL 6005 (“moss green”) or equivalent. This is because they will mainly be viewed against the backdrop of the forested mountains.

At the port sites, and for industrial facilities around the town of Buchanan, the colour to be used on the cladding and roofs of these fixtures is RAL 1015 (“light ivory”) or RAL 9001 (“cream”) or similar. This is because they will mainly be viewed against the backdrop of the sky in the flat coastal landscape.

Structural steel framing (columns and beams) of roofed buildings (with or without walls) should be light ivory or cream (RAL 1015 or 9001). This is mainly for safety reasons, to make them more visible.

Structural steel framing (columns and beams) of open structures (e.g. conveyor belts) should also be light ivory or cream (RAL 1015 or 9001). Again, this is mainly for safety visibility.


8.2 Standard for Night-time Lighting of Work Sites Introduction Excessive night-time lighting is wasteful of energy and can cause serious disturbance to neighbouring communities as well as to nocturnal animals. Liberia has low levels of night-time light, and so light pollution is easily caused. All of the work sites are in or close to areas of high biodiversity value. Of particular concern are the effects of excessive light on moths, birds and primates at the mine sites, and marine turtles close to the port. The attraction of insects to lights sets off an ecological chain reaction: abundant insects attract geckos and toads, and after those come snakes. Notwithstanding the above, lighting shall be provided by the Company that is adequate to ensure safe working practices during the hours of darkness. General security lighting shall be minimised and should be reviewed periodically. Effects on biology and health Colour sensitivity in the UV spectrum plays an important role in foraging, navigation, and mate selection in both flying and terrestrial invertebrate animals. The human visual system is activated by radiant energy in the colour range from deep blue to dark red, which we call light. The vision of flying insects is shifted away from long wavelength red towards the shorter blue and near ultraviolet (black light) wavelengths of the electromagnetic spectrum. Sources which radiate ultraviolet energy and blue light are most attractive to flying insects, while those with a deficiency of ultraviolet and blue are less attractive. Insects see black light fluorescent, mercury, and metal halide best. Lamps which




insects have more difficulty seeing include incandescent, high-pressure sodium, and “bug light incandescent” (yellow). It was previously claimed that light-emitting diodes (LED) emit little or no power in the ultraviolet spectrum, but research published in 2014 shows that “white” LED do in fact have a sharp peak near the ultra-violet end of the spectrum, although most of their light is in the green-yellow-red part of the spectrum. Incandescent, fluorescent, metal halide and mercury vapour sources emit a substantial amount of ultraviolet radiation. Low pressure sodium emits moderate ultraviolet light. There are reportedly health issues with metal halide lights. Ultraviolet can apparently contribute to retinal damage and contribute to macular degeneration. Both of these types should be avoided. Approved site lighting types External site lighting shall be by high pressure sodium or xenon sodium lights. Lighting shall be to the minimum level of brightness required at the site according to the relevant safe working standard. Lights shall be shielded to direct light only where it is needed, and so that they are not visible from long distances. Appropriate shielding shall be added to the required specifications. Lights shall be installed so that they are easily turned off when not needed, as even high pressure sodium lights will attract some insects. Motion sensors or a timer may be appropriate, and the higher capital cost offset by savings in running costs. There is a high capital cost in LED lighting fixtures, and in general it is much more economical to use high pressure sodium lighting. However, LED may have advantages for internal locations where energy saving is important (such as in remote locations supplied by photovoltaic panels of batteries). Mines In general, lighting shall be provided only by operating machines. Area lighting shall be restricted to key operational areas, such as around workshops, crushing and screening sites, loading points, and dumping points such as stockpiles and waste dumps. In these areas, lights shall be fitted with shades or deflectors to minimise the light shed over surrounding areas and to ensure that no direct light shines over neighbouring areas of forest or bush. Mobile lighting stands shall be located such that the illumination provided is only in the area of working, and there is no spillage into neighbouring land. Where large numbers of moths are found to congregate around lights, the siting and requirement for lighting shall be reviewed. There shall be no outward-facing security lights around mine or other infrastructure sites. Access roads and haul roads shall not be lighted. Railway yards Reliance shall be placed where possible on the lights of operating locomotives. Area lighting shall be restricted to key operational areas, such as switches, fuelling points and wagon marshalling yards. In these areas, lights shall be fitted with shades or deflectors to minimise the light shed over surrounding areas and to ensure that no direct light shines towards nearby settlements or over neighbouring areas of forest or bush.




Unless required for security, lights shall be switched off when no operations are taking place. Port of Buchanan Lighting at the Fuel Quay shall be fitted with shades or deflectors to minimise the light shed over the breakwater and on to the beach towards the south-east. It is highly likely that light pollution in this area would disturb nesting turtles on the beach. All marine turtles visiting the Liberian coast are globally endangered and protected by international conventions. Lighting at the Iron Ore Quay should be no more than necessary for safe night-time working, and should be kept as low as possible to do the job. Shades or deflectors shall be fitted to avoid direct light shining towards either Buchanan City or the beach towards the south-east of the port. Ships shall always carry the lights required by the maritime code for navigation or anchorage. Deck lights shall only be used when loading or unloading operations are underway. Security lighting in compliance with the International Ship and Port Security (ISPS) Code shall be permitted at the minimum levels required. Airstrips Lighting should be no more than the minimum required for safe night time operating under Liberian Civil Aviation Authority (LCAA) and International Civil Aviation Organisation (ICAO) regulations for the standard of airstrip and flight operations that are being undertaken. Where white or other light colours are not specifically required in regulations, External site lighting shall be by high pressure sodium or xenon sodium lights. Perimeter security lighting shall be fitted with shades or deflectors to minimise the light shed over the surrounding areas. Except in limited locations (e.g. aircraft parking aprons and fuel stores) where required for security, lights shall be switched off when no operations are taking place. Obstructions to aviation Possible aviation obstacles shall be identified and lighted according to LCAA and ICAO regulations on the control of obstacles. Source: ArcelorMittal Liberia.




9. POLLUTION PREVENTION STANDARDS

9.1 Standard for the General Prevention of Pollution at Work Sites Introduction All industrial and commercial sites have the potential to damage our natural environment. This standard is produced to help you reduce the risk of causing environmental pollution. Pollution incidents occur every day as a result of spillages, accidents, negligence or vandalism – sometimes the pollutants put human health at risk and often they devastate wildlife habitats, including rivers in which they kill fish and destroy the invertebrate life on which fish and other animals feed. To cause or allow pollution is against the law. Society is no longer prepared to accept businesses that do not take their environmental responsibilities seriously. The Environmental Protection Agency can impose fines of up to US $ 50,000 for pollution offences, and if a case goes to court you could go to prison. The polluter will also have to pay clean-up and court costs. Even if a case is not taken to court, the cost of repairing the damage to the environment has to be met – these costs can be very large. For example, fish restocking can cost thousands of dollars and cleaning up serious groundwater pollution can cost over a million dollars. Following the guidance in this standard not only reduces the chance of causing pollution, but also makes good business sense. Minimising waste and pollution risk saves money by reducing operating costs. Businesses that have a „green‟ image are at a competitive advantage, which is important in today‟s economic climate. Drainage A good knowledge of all the drainage systems on your site is fundamental to prevent pollution. There are two types of system – Separate and Combined. The Separate Drainage System, in most of the Company‟s industrial sites, has two different drains – foul water and surface water. Drains are also known as sewers. The foul water drain carries contaminated water (sewage and/or industrial effluent) safely to a sewage treatment works. The surface or clean water drains should only carry uncontaminated rainwater because they lead directly to ditches, streams, rivers or soakaways. It is usual for roadside drains to be connected to the surface water system. The Combined Drainage System, mostly found in the housing areas, has one drain, which carries both foul and surface water to a sewage treatment works. It is important that every manhole, drainage grill or gully on industrial sites is identified as being connected to foul, surface or combined drains. Without this knowledge it is impossible to be sure that all drainage is connected to the right system. Wrongly connected effluents can cause severe pollution. They can prove expensive and time consuming to trace, so it is essential to make sure that everything is connected correctly. Produce a comprehensive and up-to-date drainage plan of the site, which accurately identifies all drains. If there is no in-house expertise to do this a reputable service company should be used. Key staff need to be familiar with the plan, which should be readily available. Check drainage plans before any new construction work is carried out to ensure connections are made to the right drainage system. Update the drainage plan to make sure that any alterations, additions or amendments to the drainage system are shown. Drains should be identified clearly by colour coding all manhole covers, drainage grills and gullies. Foul water drains should be painted red and surface water drains blue. Combined drainage systems could be colour coded with a red letter C. Everyone (including Contractors) should be made aware of




the significance of the colour coding system. It is important that there are no wrongly connected effluents, especially in process areas in which industrial effluent is generated – see section below on liquid effluents. The following facilities are often overlooked and must be connected to the foul or combined drainage system:

Mess rooms;

Laboratories;

Toilets;

Showers ;

Sinks, dishwashers;

Canteens and washing machines. Seal all ducted cable ways so that they do not create uncontrolled drainage routes. Remember that only clean uncontaminated water (e.g. roof water) can be discharged to the surface water system. If site foul drains are connected to a sewage treatment system, such as a septic tank or package plant, make someone responsible for its upkeep. Make sure it is maintained and emptied regularly (you may need a Discharge Permit, so check with your local Environmental Officer). It may be necessary to provide permanent drainage isolation facilities, such as penstocks, valves or emergency containment systems, on high-risk areas or as part of your site‟s emergency procedures to prevent spillage or run-off polluting the environment. To prevent oil pollution, oil separators (or interceptors) should be provided on any surface water drain at risk – particularly fuelling and vehicle parking areas – a separate standard covers these. Separators:

Must be sized according to the area being drained;

Will not retain soluble oils;

Must be maintained and regularly emptied (oil and silt); and

Will not work if detergents are present. Deliveries and material handling Delivery and handling of material, such as oils, chemicals and food stuffs, around your site is always a high-risk activity. Good working practices are essential. Special care should be taken during delivery, loading, unloading and transfer of all materials, particularly hazardous substances, as there is a risk of spillage and accidents. It is important to identify these risks so they can be minimised wherever possible. Making someone responsible for supervising deliveries can help avoid spillages – and so prevent damage to the environment, save valuable raw materials and avoid potential legal action. Ensure all loading and unloading areas are designated, clearly marked and isolated from the surface water drainage system, for example by using separators or sumps with isolating valves. Develop and implement procedures for supervising all deliveries. Minimise the quantity of material stored on site. Storage containers and pipework must be well designed, “fit for purpose” and comply with any relevant regulations. Their condition and storage levels must be checked before receiving each delivery to prevent loss of product, for example, by overfilling or tank failure. Fit appropriately sized drip trays to all delivery pipe inlets and remove any spilt material immediately.




Fit an automatic cut-off valve or alarm to prevent spillages through overfilling. This is essential for oil tanks for which the vent pipe cannot be seen from the delivery point. Pumped dispensing is preferable to gravity draw-off. Reducing the need for materials to be moved around the site lowers the risk of accidents or spillage. Transfer routes should be identified and kept clear at all times, the potential for environmental damage assessed and risk reduction measures carried out. Avoid manual handling wherever possible to reduce the risk of human error and accidents. Have a contingency plan and make sure everyone is aware of what to do in the event of a spillage or other accident. Have a stock of emergency equipment, for example drain covers, absorbent materials and protective clothing, available to mop up small spillages. Ensure that all residues and contaminated materials are disposed of correctly. Storage Poor storage of oils, chemicals and other materials represents a major risk to the environment. The potential for accidental spillage is at its greatest during deliveries and dispensing, but storage containers (tanks, drums, bowsers, etc.) are also a risk. It is essential that they are sited appropriately, designed and maintained to take environmental protection into account. The use of secondary containment systems prevents materials escaping to the environment. Use an appropriate container for the material stored. Make sure it is fit for purpose and clearly labelled with product type, maximum capacity and both health and safety and environment protection information. Locate storage facilities away from watercourses, open drains, gullies, unsurfaced areas or porous surfaces. Protect containers from impact damage where necessary. Roof storage is high-risk and should be avoided because any loss of the contents may drain to the surface water system via guttering and cause pollution. Storage tanks, bowsers for chemicals, oils and raw materials must have either a complete double-wall system with full impact or puncture protection separation between the walls, or a secondary containment system able to hold at least 150% of the tank‟s maximum capacity (if fully roofed, then the containment system must be able to hold at least 110% of the tank‟s maximum capacity). It must be impermeable to the material stored, enclose the ancillary equipment (e.g. local fill and draw-off facilities, vent pipes, sight gauges, taps, valves, etc.) and have no open drain-down outlets or connection to the environment. Secondary containment for drum storage should be provided by using a proprietary container store, bunded pallet, drip tray or kerb-bunded area – preferably roofed. The capacity should be at least 25% of the total volume of the drums being stored. Where access for vehicles is necessary provide a properly designed ramp, but make sure use of the ramp does not cause spillages. All liquid containment systems must have a means of monitoring to allow regular checking that the primary containment is intact. Loss from the container beyond the secondary containment system (known as jetting) can be minimised by keeping the container as low as possible, providing deflection screens and directing any potential discharges into the containment system.




Maintenance schedules must be produced for regular inspections of storage facilities and any necessary remedial work must be carried out promptly. Rainwater which may have collected within open containment systems must be removed regularly. This wastewater may be contaminated and must be disposed of appropriately through a filtration system. In the long term it may be more cost effective to roof the facility or even replace the tank with a proprietary enclosed bunded tank system. All pipework must be protected against corrosion and physical damage (e.g. collision, vibration, ground disturbance, etc.). Above ground pipes should be properly supported and their condition checked frequently. Avoid underground pipework, as faults are very difficult to detect and can lead to groundwater contamination. If they have to be used underground, pipes should preferably be laid in an impermeable duct, must have inspection chambers at all mechanical joints and be tested regularly to ensure they are not leaking. Their route should be marked clearly on the ground and on all site plans. Security measures must be provided for storage areas to prevent vandalism and theft. Storage system valves, taps, hatches or lids and delivery hoses should be fitted with locks and locked shut when not in use. Where possible materials should be stored in secure buildings. Underground storage of oils and chemicals is a significant pollution risk to groundwater. Avoid underground storage of oils and chemicals unless absolutely necessary. Where unavoidable, it is essential that the risk to groundwater is reduced by good leak-detection facilities and management procedures. Waste management The guidelines below summarise the principles of waste minimisation and its minimisation. Standard 1.6 provides guidance on its disposal. Everyone should minimise waste production to save money and resources. Waste management and disposal are subject to strict legal controls, since these represent essential pollution prevention measures. A waste minimisation review will help you save money on raw materials and waste disposal costs. For example, work with your suppliers and distributors to find ways to eliminate or reduce the amount of packaging. Carry out a waste minimisation review and consider methods to reduce the volume of waste you produce. Reuse waste or buy in products that can be reused many times – it will save money in the long term. Recycle as much waste as possible. Try to substitute materials for less hazardous ones, for example biodegradable lubricants and solvent-free paints. Have waste taken off site frequently; do not allow large quantities to accumulate. You have a legal duty to ensure that any waste you produce does not escape from control, is transferred only to an authorised person (e.g. registered or exempt waste carrier or authorised waste manager), and is disposed lawfully. Waste must always be stored in appropriately designed containers that are fit for purpose and of sufficient capacity to avoid loss, overflow or spillage. All waste and waste containers must be stored in designated areas, which are isolated completely from surface water drains or direct discharge to the environment. The area should be able to contain spillages.




Segregate and label both wastes for recycling and hazardous waste from general waste. Do not mix or dilute hazardous wastes. Where appropriate, skips should be covered or enclosed unless stored undercover or within a building. Waste compactors can produce highly polluting run-off and must be isolated from surface drainage systems. It is best to drain the area to the foul sewer, with prior planning to ensure the treatment works can accommodate it, and to provide a roof to minimise the discharge. The disposal of certain hazardous wastes (e.g. oily wastes, acids, solvents and solvent-based products) have particular legal requirements and must be dealt with under special arrangements. Burning material in the open air is an undesirable method of waste disposal and may be unlawful. Always try to find another way to dispose of waste that is less harmful to the environment. Liquid effluents Liquid effluents that are produced by an industrial process are known as “industrial effluents” and require special consideration for their disposal. Industrial effluents are polluting and must not be discharged to the surface water system. Generally the least bad option is to discharge industrial effluent to the foul sewerage system, as long as prior arrangements are made for the reception of the effluents: there may be conditions set on the quality and quantity of a discharge and pretreatment may be necessary, depending on the nature of the effluent. If discharge to the sewerage system is not possible, a separate treatment system must be considered, designed specifically to treat all effluents connected to it. You will need a Discharge Permit from the Environmental Protection Agency for any treated industrial effluent discharge to the environment. It is unlikely that consent would be given to discharge industrial effluent to the ground. Connecting industrial effluent to small sewage treatment facilities is also likely to cause pollution. If treatment or sewerage disposal options are not possible then, because industrial effluent is regarded as a liquid waste, storage and off-site disposal will be necessary and waste management legislation will apply. Industrial effluent drainage systems should be checked regularly for leaks. All treatment plants, including storage vessels and chemical storage areas, must be isolated from surface water drains. Discharge points for all industrial effluent gullies and drains must be checked and included on your site drainage plan. Some effluents may be a small volume or considered “clean”, but the disposal route of ALL industrial effluents must be considered. Vehicles, components, plant and equipment, floors, surfaces and containers are cleaned on site every day. All these activities generate dirty water and the disposal of this effluent, as with all industrial effluents, must be considered carefully. All cleaning agents are potential pollutants, as are the materials they are intended to remove. These include detergents (even the biodegradable ones), disinfectants, degreasers, dirt and oil. Carry out all washing and/or cleaning operations in a clearly marked, designated area. This includes cleaning vehicles or plant. Isolate all cleaning or wash-down areas from the surface water system and unmade ground or porous surfaces by using drainage grids, gullies or kerbs. Wash water should drain or be disposed of to the foul sewer; but first check the specifications of the sewerage system to ensure it is appropriate. Ensure all employees and Contractors know where they can dispose of waste waters properly.




Cleaning agents including detergents are not suitable for discharge to surface water drains, even those described as biodegradable. Do not allow detergents to enter oil separators as the oil will be washed through. If yard areas are cleaned, do not allow the run-off to enter surface water drains. Think carefully about your site drainage before using a mobile steam or pressure cleaner, especially if detergents or degreasers are used. Ensure they are operated only in an area isolated from the surface water system. Take care when removing excess water from a site, or dewatering generally, especially in areas that may be or are known to be contaminated. It is often necessary to dewater underground ducts or chambers for inspection and maintenance purposes. This results in a relatively small volume of liquid to dispose of. Larger volumes may be produced as a result of groundworks or construction projects in which excavations extend into groundwater sources or collect rainwater and other run-off. Silt causes lasting damage to river life because it:

Blocks fish gills so they suffocate and die;

Destroys spawning sites of fish;

Destroys insect habitats

Stunts aquatic plant growth; and

Can build up and lead to flooding. Before any dewatering takes place, the collected water should be tested to determine its quality and the most appropriate disposal option. The disposal of polluted water requires careful consideration and must be discussed with the local office of the Environmental Protection Agency before any discharge is made. Silty water should never be pumped directly to a river, stream, road or yard gullies or surface water drains. Silt is generally a non-toxic pollutant and, in the absence of any other contaminants, can be disposed of by pumping to a settlement tank or over a large grassed area. If there is any risk that the silty water is contaminated with any other pollutant, you should consult with the Environmental Officer before its disposal. Groundwater protection Groundwater is out of sight, but must not be out of mind. As a valuable resource it must be protected from pollution. Spillage and unsuitable disposal of oils, solvents, chemicals or waste materials causes serious damage to groundwater. Pollution can occur from discharges onto open ground and other porous surfaces or from drainage systems that soak into the ground (soakaways). Chlorinated solvents are among the most serious causes of groundwater pollution. It is vital that groundwater pollution is avoided, as once it has become contaminated, groundwater is very difficult and expensive to clean up. All Company work sites are in sensitive groundwater areas, since they are all within the catchments of drinking water supply boreholes. Only allow clean uncontaminated rainwater to discharge to soakaways. Never allow wastes or chemicals to be disposed of onto the ground. Spillage of oils, chemicals or wastes must be dealt with promptly. Any contaminated soil should be removed and disposed of according to your emergency plans and waste management procedures. Specialist advice may need to be sought on remedial action for spillages of certain substances.




Training Training plays a crucial role in protecting the environment. Trained and knowledgeable staff can help prevent or lessen the effects of a pollution incident – saving both money and time. Training should cover environmental awareness, correct procedures and pollution-incident response. Make sure everyone is aware of how important it is to protect the environment and what the Company does to prevent pollution. Include environmental training for new starters. Display pollution prevention posters in positions where everyone can see them. Reinforce training with a regular refresher programme. People (and their deputies) who have specific responsibilities for procedures or plant with a potential environmental impact should receive regular and adequate training in their role. They must have an awareness of the potential for harm to personnel and the environment from materials and equipment they are responsible for. Contractors should be trained in relevant environmental management and emergency procedures before starting work. Emergencies Occasional accidents are inevitable so it is important to have plans in place to deal with pollution emergencies and make sure everyone knows what to do in the event of an incident. Develop a pollution incident response plan to prevent harm to human health and minimise damage to the environment caused by accidents, fires or spillages. Test your incident response plan by carrying out simulations and exercises for all those involved. Amend the plan to account for any deficiencies. Never leave anything to chance! Always have adequate emergency pollution-control equipment available to deal with spillages, accidents or firewater, such as absorbent materials, drain blockers or incident “grab packs”. Do not forget to provide personal protective clothing. Make someone personally responsible to and maintain regularly all routine and emergency pollution control and prevention equipment, devices and procedures. Make sure any remedial work is carried out as soon as possible. Devise procedures for the recovery, handling and disposal of all waste material that arises from incidents or emergencies. If you have an incident that has or is likely to damage the environment you must inform the Environmental Protection Agency. This is normally done through the Company‟s local Environmental Officer. Source: Adapted from UK Environment Agency guidelines.

9.2 Standard for Avoiding and Treating Spills Purpose The company and its contractors are using a number of hazardous substances that can cause significant damage to the environment if they are spilt. It is everyone‟s responsibility to do everything possible to avoid a spill. In an accident, immediate action is necessary to contain the spill.




What materials are hazardous? The most hazardous substances we are dealing with are:

Diesel fuel, which is highly poisonous.

Lubricants (engine oil, hydraulic fluid, brake and clutch fluids, etc).

Herbicide.

Timber preservative. But there are many others as well. What pollution may occur There are many ways in which pollution occurs. In most cases it is much more extensive than appears to be the case on the ground, especially with liquid spills.

Water supplies can be contaminated by liquid spills, leading to poisoning of the local population. If a liquid gets into the groundwater, it can persist there for many years.

Soil can be contaminated, leading to the loss of crops.

Rain can wash hazardous substances long distances and cause the effects of the spill to be extended over hundreds of metres.

Preventative arrangements All site managers and supervisors are responsible for ensuring the following.

Careful use of all hazardous substances at all times.

All staff follow the proper procedures for the use, transport and transfer of all hazardous substances, under properly controlled conditions.

No contractor is to handle hazardous substances unless they are properly prepared, have competent staff and are ready to respond to any accidents.

All sites using hazardous substances must have spill kits ready for use. Spill kits are available in company stores.

All vehicles carrying hazardous substances must have spill kits on board.

All personnel handling hazardous substances must be trained in how to avoid a spill, and what to do in the event of an accidental spill. Pay particular attention to contractors‟ workers.

Emergency response in an accidental spill See standard 9.3. Legal position Causing pollution is a crime under environmental law. You risk severe penalties for failing to stop pollution from occurring. Source: ArcelorMittal Liberia.

9.3 Standard for Action to Clean Up Spills Any spill of a hazardous or polluting substance constitutes an emergency. Rapid action is usually essential to contain and control the spill. Any person who discovers a spill of any substance must do the following. 1. Notify fellow workers and inform the Supervisor that a spill has occurred. 2. If anyone is injured or in danger, rescue them if it is safe to do so. Then call appropriate rescue

and medical assistance if required.




3. Notify all fellow workers or bystanders if there is a risk of fire or explosion, or of a collapse of infrastructure.

4. Evacuate all unnecessary personnel to a safe location. 5. Find the nearest spill kit and use it to contain the spill. Use all the protective clothing in the kit to

protect yourself. Place absorbent pads around the spill, to ensure that the spilt substance is contained and does not spread.

6. Use soil or sand to absorb large quantities of spilt liquids. If the pads in the spill kit are not

enough, make soil bunds around the spill. 7. If you do not have a spill kit or it would take too long to get one, soil and sand are what you must

use. Dig the soil to make a bund around the spill to stop it spreading. Keep digging and bringing more soil until it absorbs all of the spill.

8. If there is any danger of the spill getting into a water course or well, do your utmost to stop it. If

necessary, divert it into any other area than into water (it is usually easier to clean soil than to clean water courses).

9. Inform the nearest Safety, Health and Environment personnel. These are as follows. Yekepa Washingtone Onyango 0777 247737 K. Venkatesan 076 465535 Alvin Poure 077 926989 / 0886 669722 Wing-Yunn Crawley 0776 862114 Buchanan Willem Hammann 076 371947 Forkpayea Gbelee 077 827308 / 0886 512596 10. Provide the Environmental representative with this information.

The location of the incident.

The substance involved.

The approximate quantity of substance spilt.

The details of the area around the spill (e.g. on a road, on a farm, into a stream etc).

How far it has been possible to contain the spill. 11. Inform your sector Manager. 12. Continue to do what you can to contain the spill until further help arrives. 13. Do not leave the scene of the spill until it has been contained, cleaned or other appropriate action

has been taken. Do not allow any equipment to leave the scene until it has been checked by a police officer or a government official (you may be accused of removing evidence if an investigation is launched).

14. When absorbent mats are totally soaked and no longer needed to contain the spill, put them in

the polythene bags provided with the spill kits. 15. For fuel and oil spills, do not try to dilute the spill with water because this will just spread the

pollution further. 16. For herbicide spills, do not add water until all liquid has been absorbed by mats or soil. 17. If the spill is in a public area, warn people in the vicinity of the dangers posed by the spill. Try to

make contact with the Chief or District Commissioner and ask them to assist in safeguarding people‟s health. Enlist the aid of the LNP if they are nearby.





9.4 Standard for Pollution Prevention from Ships Introduction Applicability. This standard shall apply to all ships operating on behalf of the company through any charter or contract arrangement, either while in Liberian territorial waters (i.e. within 12 nautical miles of the shore of Liberia) or at any other time while engaged on a voyage in connection with company business. It shall be applied irrespective of the port of registration of the vessel concerned, and irrespective of whether the Authority of the ship‟s flag is a signatory to MARPOL or the London Dumping Convention. Framework. At all times, ships operating on behalf of the company through any charter or contract arrangement shall abide by the provisions of the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (“MARPOL” or “MARPOL 73/78”) and its Annexes. In all cases the latest modification of an Annex by the International Maritime Organization (IMO) or the Maritime Environment Protection Committee (MEPC) shall apply unless otherwise stated. The dumping of materials at sea shall be as stipulated in the 1996 Protocol to the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972, as amended in 2006 (the “London Dumping Convention”). Only the inert materials listed in Annex I of this Protocol may be dumped at sea, and only in places where the ship has the appropriate authorisation to do so. In addition, while in Liberian territorial waters, some further obligations are required as listed in this standard, to comply with the Liberian Maritime Regulations (2002). These obligations shall also apply to all ships operating on behalf of the company through any charter or contract arrangement, irrespective of the port of registration of the vessel concerned. Reporting of incidents. The master of a ship shall report any of the following incidents to the company within 24 hours while in Liberian territorial waters or within 50 nautical miles of the Liberian coast, in line with Protocol I of MARPOL 73/78.

Any discharge or probable discharge of oil or any other noxious liquid.

Any discharge or probable discharge of harmful substances in packaged form.

Damage, failure or breakdown of the ship, including grounding, collision, fire, explosion, structural failure, mechanical, hydraulic or electrical failure of any sort, flooding and cargo shifting.

Non-compliance. Failure to comply with the provisions of this standard will be dealt with by the company on a case-by-case basis. Infringements of Liberian or international law will be reported to the appropriate authorities. Prevention of pollution by iron ore – ship loading Ore is to be stockpiled on a concrete platform with drainage away from the sea, leading rainwater into sediment ponds which settle out any mobilised fines to prevent them from being washed into the sea during the wet season, to the levels set in Standard 5.3. From the stockpiles, ore is reclaimed and sent via pay-loader or conveyor to a ship loader. Ships shall enter the port from the west-north-west along the approved in-bound channel. They will turn in the port basin before berthing at the Iron Ore Quay, using tug assistance as necessary. It must be ensured that the vessel being loaded is low enough in the water for the correct operation of the ship loader (i.e. so that the ship loader is not operating at too steep an angle). If grab cranes are used for loading, ensure that ore is brought within reach of the grab only on an as-needed basis. Ensure that there is a clean band at least two metres wide between these temporary ore piles for the grabs and the edge of the quay. Clean the working area between the stockpile and




the edge of the quay thoroughly immediately after each ship loading operation. Temporary ore piles placed on the quay shall also be removed back to the stockpile whenever loading is stopped for a period of four hours or more, to prevent ore from being blown or washed by heavy rain into the waters of the port. Ship loaders shall not be moved while the belt is running except to trim the holds. The ship loaders‟ belts shall be stopped whenever any problems occur and during strong wind squalls. Any cargo spillage on deck shall be cleaned up by the ship‟s crew or by a special gang brought on board for the purpose before the ship shall be allowed to sail. This spilt ore shall either be placed in the holds with the cargo or, if wet or contaminated, shall be returned to the shore for appropriate processing. Prevention of pollution by iron ore – transhipment at sea Where iron ore is to be transhipped at sea into Capesize or ocean going vessels, the ship will enter Liberian territorial waters from the deep ocean and will anchor in the approved transhipment area, which is located at 5º 50.5‟ North, 010º 05.0‟ West. This is beyond the 20-metre depth line, which lies about 2 nautical miles off this part of the coast, and outside the navigation lanes for vessels entering and leaving the Port of Buchanan. The area chosen is the location of the former LAMCO silt dumping site after maintenance dredging operations. This is suitable for anchoring because of the mud bottom and the previous disturbance to the sea bed, meaning that environmental damage will be minimised. Operations at the transhipment anchorage will only occur during “weather working days”, which are defined as satisfying all of the following conditions.

Wind speed is less than or is reasonably forecast to be less than 25 knots.

Wave conditions are less than 2.0 metres in height.

Visibility is at least 0.5 nautical miles.

Swell is less than 3 metres. The transhipping vessel (TV) bringing ore from the port, will moor alongside the ocean-going vessel (OGV) at anchor. The TV will then unload its cargo into the OGV‟s holds. In order that this operation happens safely, a number of steps must be covered with rigorous care. These are ensured through the use of checklists, which must cover at least the following stages of the operation.

Pre-fixture exchange of information.

Before operations commence.

Before run-in and mooring.

Before cargo transfer.

Dry bulk cargo transfer.

Before unmooring. These checklists are to be based on the checklists provided in the International Maritime Organisation‟s Manual on Oil Pollution (Section I – Prevention). Once the OGV has anchored and is ready for transhipment, her Master will begin detailed communications with the Master of the TV. On site control of the transhipment will be in the hands of the Master of the TV who will advise the master of the OGV. However, the Master of each vessel shall still be responsible for his own vessel, crew and cargo. Before and after transfer operation, communications will be done by VHF channel 13 and an agreed working channel using portable UHF/VHF sets or walkie-talkies. In the event of radio communication breakdown between the vessels, one prolonged blast on either ship‟s whistle will mean „emergency stop‟ and cargo operations are to be suspended immediately. Once the pre-operation communications and checks are complete, the TV will berth and be secured alongside the OGV. This operation will be assisted by tugs. It must be ensured that the OGV is low enough in the water for the correct operation of the TV‟s ship loader, so that it is operating at the correct angle.




Each Master shall ensure that during all stages of the transhipment there will be sufficient manning for a safe and efficient operation. On each ship they shall ensure that the navigating bridge is continuously manned by a qualified officer throughout the operation and that the main engines are at all times available for manoeuvring. The OGV must ensure that an adequate number of crew is available at all times to ensure that the mooring lines from the TV can be handled safely. The TV will commence operating by transferring the DSO by a belt conveyor and ship loader system into the OGV. The entire discharge system will be controlled by the TV operator from the cargo control room of the TV. The cargo operations will also be monitored by a deck watchman on the TV. As loading progresses, the TV will be ranged alongside the OGV by using its mooring system to facilitate the loading of individual holds. The TV is required to load the OGV in such a way that each hold is trimmed as far as possible. Bulldozers will not be used for trimming. The ship loader may only be moved while the belt is running to allow trimming of the holds. Under certain sea or wind conditions, the OGV will be positioned across the wind by using a tug to push the stern around to reduce the rolling of the OGV. If the wind exceeds 25 knots or wave height exceeds 2 metres, the Masters of the two ships will evaluate and discuss transhipment conditions immediately and at two-hour intervals thereafter. If one Master considers that conditions exceed what is safe for working, operations will be stopped until the situation improves. Any cargo spillage on the OGV‟s deck shall be cleaned up by the ship‟s crew before the ship shall be allowed to sail. This spilt ore shall be placed in the holds with the cargo. Grab cranes may not be used for transhipment at sea. No cargo other than iron ore may be transhipped. Prevention of pollution by oil – general Definition of oil. In this standard, the word “oil” means petroleum in any form, including crude oil, fuel oil, lubricating oil, sludge, oil refuse, refined products and petrochemicals. IOPP Certificate. All ships shall be in possession of a valid International Oil Pollution Prevention (IOPP) Certificate issued in accordance with MARPOL 73/78 Annex I. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s IOPP Certificate. Discharges. Except in cases of emergency, and then only under the circumstances and conditions set forth in Regulation 11 of MARPOL 73/78 Annex I, no ship shall discharge into the sea any oil or oily mixture. Oil record book. All ships shall have a full and up to date Oil Record Book. This shall comply with the stipulations of Regulation 11 of MARPOL 73/78 Annex I. It must contain as a minimum, full records of the following: the ship‟s oil tanks and their capacities; the taking on board of oil, including source, volume and timing; ballasting or cleaning of oil tanks; discharge of dirty ballast or cleaning water from oil fuel tanks; collection and disposal of sludge and other oil residues; discharge overboard or other disposal of bilge water which has accumulated in machinery spaces, including location, volume and timing; bunkering of fuel or bulk lubricating oil; condition of oil filtering equipment; and any accidental or exceptional incidents involving oil. Ship-board oil pollution emergency plan. All ships shall have a ship-board oil pollution emergency plan in compliance with Regulation 37 of MARPOL 73/78 Annex I. This shall contain as a minimum: a procedure to be followed by the master, officers and crew in the event of an oil pollution incident such as will satisfy all of the requirements of MARPOL then in place; a detailed description of the actions to be taken by persons on board the ship to reduce or control the discharge of oil following the incident; the procedure and actions to be taken to clean up the pollution or as much of the pollution as can be safely cleaned up in the prevailing sea and weather conditions. All oil pollution incidents occurring within 50 nautical miles of the coast of Liberia shall be reported to the company within 24 hours.




When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the plan. Ship-board oil spill clean-up equipment. All ships shall carry on board the necessary equipment to clean up an oil spill of 1,900 litres. A designated officer and crew members shall be trained in its use. Reception facilities. The company will not provide onshore reception facilities for oil or oily waste of any kind at the Port of Buchanan. Should a ship need to discharge such waste, then the ship‟s agent shall provide the company with proof that both the handling mechanism and the disposal facility used are authorised by the Liberian Environmental Protection Agency for reception of such materials. This proof is to be provided before any such waste is off-loaded from the ship. Prevention of pollution by oil – refuelling in port Refuelling in port is only permitted for resident ships, such as transhipment vessels and tugs. Ore carriers and cargo importing ships must arrive with adequate fuel to carry them on to the next destination. Refuelling of diesel, marine gas oil (MGO) or a similar grade of fuel, and of lubricants, may be undertaken for resident ships in port. This will occur at the fuel quay in the Port of Buchanan unless the ship is too big to berth there, in which case it will be done at the iron ore quay. MGO is not an oil grade stored by ArcelorMittal, and so if required it will be purchased on an as-needed basis, and brought by road tanker from the main oil depot in Monrovia. When refuelling is required, an appropriate number of road tankers will be called to bring the fuel from Monrovia or another depot. The receiving ship will be made ready for the refuelling operation. The Master shall ensure that the crew is fully trained in the procedures. The crew shall check and test all necessary equipment. Any damaged, faulty or suspect equipment shall be replaced. Once this has been done, the ship‟s Master shall ensure that all appropriate checks are completed and signed off before the operation is started. These should be in compliance with MARPOL 73/78 Annex I and following the guidelines given in the IMO‟s Manual on Oil Pollution (Section I – Prevention). The appropriate bunkering checklist will be completed. Good communications will be established between the crew of the ship and the refuelling team on the quay. An emergency shutdown procedure and signals to trigger this will be in place and agreed between the ship‟s Master and the refuelling officer on the quay before starting the operation. Any spillage must trigger a shutdown of the operation until the problem has been rectified and the spill fully cleaned up. A ship must be present and on standby that has an activated foam fire fighting capacity and oil dispersant capability. The shore-based fire-fighting team will be mobilised to the quay and will remain on standby throughout the operation. The full shore-based spill clean-up team will be mobilised and kept ready for action in case of an accident. Hoses will be passed between the shore and the ship and, once all the safety checks are complete, refuelling will begin. The tanker‟s nozzles will have automatic shut-offs in case of disconnection or loss of pressure. During refuelling, a number of vigilance activities are to happen continuously: (a) a lookout watches for signs of spills or slicks of oil around the ship; (b) the pumps, hoses, other pipework and nozzles are monitored by appropriate crew members; (c) the levels of the tanks are monitored to ensure that refuelling is stopped on schedule and there is no overflow. As the tanks become filled, the topping off will be done by notifying the supplying road tanker, reducing flow and finally closing the valves of the tanker before the valves on the ships. Hoses and nozzles will be returned, and checks made to ensure that all valves are secured and no spillages made. Lubricants shall be transported in sealed units in shipping containers and stored in the Company‟s existing secure facilities for lubricants at Buchanan. When required by a ship, they will be brought




from the stores on trucks and transferred to the ship by means of the ship‟s own cranes. During this operation, a full shore-based spill clean-up team shall be mobilised and in attendance ready for action in case of an accident. A tug or other vessel with spill clean-up resources shall also be on standby close to the ship. Prevention of pollution by oil – refuelling at sea Resident transhipment vessels that require to be refuelled periodically with intermediate fuel oil (IFO), heavy fuel oil (HFO) or a similar grade of fuel, will be supplied using a chartered bunkering tanker. Bunkering will take place in international waters (i.e. at least 12 nautical miles off the Liberian coast) and will follow the rules set out in MARPOL 73/78, Annex I. It should be noted that refuelling at sea in international waters is covered by international maritime law and not by Liberian legislation. When refuelling is required, a bunkering tanker will be ordered from an approved agent operating on the West African coast. A suitable sea area will be agreed for the rendezvous. This will be in international waters and will be far enough from any shipping lanes to ensure full sea room for manoeuvres, including emergencies. A ship based in Buchanan that has an activated foam fire fighting capacity and oil dispersant capability will be put on short notice standby with sufficient amounts of fire-fighting foam and oil dispersant in its tanks. The crew of the receiving ship will be made ready for the refuelling operation. They will be fully trained in the procedures and required to check and test all necessary equipment. Any equipment that fails to meet the IMO standards will be replaced. As the ships approach the rendezvous, communications will be established and tested. The Masters of the two ships will confer regarding weather and sea conditions. If one of them is unsure that conditions are suitable, then the operation will be postponed until he is satisfied. The Master of the receiving ship will ensure that the checklists provided in the International Maritime Organisation‟s Manual on Oil Pollution (Section I – Prevention) are completed and signed off by each ship before the mooring operation is started. The Master of the bunkering tanker will sign off his own complete checklist, not simply countersign the hard copy that the Master of the receiving ship has signed. Yokohama fenders will be deployed by the refuelling tanker to ensure that there is no chance of any metal-to-metal contact. An emergency shutdown procedure and signals to trigger this will be in place and agreed between the two Masters before starting the operation. The ships will come alongside and moor together as per the agreement reached through the pre-operation communications and the completed checklists. Hoses will be passed between the ships and, once all the safety checks are complete, refuelling will begin. The nozzles used will have automatic shut-offs in case of disconnection or loss of pressure. During refuelling, a number of vigilance activities are to happen continuously: (a) the Masters continue to monitor weather and sea conditions; (b) a lookout watches for signs of spills or slicks of oil in the wake of the ships; (c) the pumps, hoses, other pipework and nozzles will be monitored by appropriate crew members; (d) the levels of the tanks will be monitored to ensure that refuelling is stopped on schedule and there is no overflow. Any spillage must trigger a shutdown of the operation until the problem has been rectified and the spill fully cleaned up. As the tanks become filled, the topping off will be done by notifying the bunkering tanker, reducing flow and finally closing the valves of the bunkering ship before the valves on the receiving ship. Hoses and nozzles will be returned to the appropriate ship, and checks made to ensure that all valves are secured and no spillages made. The ships will then cast off their moorings according to the pre-agreed sequence, and part company.




Prevention of Pollution by Noxious and Harmful Substances Discharge. No ship may discharge into the sea any quantities of noxious liquid substances as defined in MARPOL 73/78 Annex II or harmful substances as defined in MARPOL 73/78 Annex III other than in emergencies as permitted by MARPOL. In the event of such as discharge being made, whether deliberate or accidental, within 50 nautical miles of the shore of Liberia, the ship‟s master shall report the incident in full to the company. Oily water. In general, ships should process oily water through a separator before discharge in international waters in accordance with MARPOL 73/78. The Company can arrange disposal of oily water in suitable shore reception facilities if the ship is not sailing into international waters (where the oil-water separator can be used). Recording. All ships shall maintain an up to date Cargo Record Book at all times, in which any loading or discharges of noxious liquid substances and harmful substances are recorded. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the book. Prevention of Pollution by Sewage ISPP Certificate. All ships shall be in possession of a valid International Sewage Pollution Prevention (ISPP) Certificate issued in accordance with MARPOL 73/78 Annex IV. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s ISPP Certificate. Shore reception facilities. There is no direct piped sewage reception facility at the Port of Buchanan. Ships and ships‟ agents may transfer sewage to the company‟s sewage treatment facility at Buchanan provided that the sewage is transferred via a suitably designed truck operated under a valid Environmental Permit issued by the Liberian Environmental Protection Agency. The pipes used for discharge from the ship to the truck, and the receiving flange on the truck, shall comply with the specifications given in MARPOL 73/78 Annex IV. The ship‟s agent is to provide proof of both the certificate and the compliance of the equipment before any sewage is discharged from the ship. Discharge of sewage into the sea. No ship shall discharge sewage into the sea while it is in Liberian territorial waters. Onboard sewage treatment systems. Ships may treat sewage with a sewage treatment plant which also has a steriliser unit to discharge effluent into the sea. This must be certified by a recognised and competent national or international authority and the effluent must comply with the quality given in standard 5.3. Prevention of Pollution by Garbage Discharge of garbage at sea. No ship shall discharge garbage other than food waste into the sea. Discharge of food waste at sea. No ship shall discharge food waste into the sea within Liberian territorial waters. Outside territorial waters, ships shall follow the provisions of MARPOL 73/78 Annex V. Placards. All ships shall display placards which notify the crew and passengers that they may not discharge garbage and waste as stated above. Ship-board waste management plan. All ships shall carry a Waste Management Plan and the equipment required to implement it. The plan shall contain as a minimum: procedures for collecting, storing, processing, sorting and disposing of garbage; a list of the onboard equipment for these operations; the identity of the individual responsible for carrying out the plan; the actions required by the officers and crew to implement the plan. The plan shall be in compliance with the requirements of




such plans in MARPOL 73/78 Annex V. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s Waste Management Plan. Garbage record book. All ships shall have a full and up to date Garbage Record Book. This shall comply with the stipulations of Regulation 9 of MARPOL 73/78 Annex V. It must contain as a minimum, full records of the following: each discharge or incineration of garbage; the date, time and location of each operation; the nature of the garbage involved; any accident or loss involving garbage. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s Garbage Record Book. Shore reception facilities. The company shall provide reception facilities for garbage at the Port of Buchanan for resident ships. For visiting ships, a maximum of one average month‟s garbage (as per the ship‟s garbage record books) may be accepted by the company. Garbage shall be separated by the ship‟s crew or the ship‟s agent, and shall be agreed with the company‟s Environmental Officer before it is discharged from the ship. Garbage shall be transported to the reception facilities by the ship‟s agent and disposed of according to the directions of the company‟s Environmental Officer. The company may refuse to accept excessive quantities or particular types of garbage if they cannot be disposed of safely in its reception facilities. The ship or the ship‟s agent may dispose of garbage elsewhere in Liberia only if the operator of such a facility has a valid Environmental Certificate issued by the Liberian Environmental Protection Agency for reception of that material, and proof of this is provided to the company before the garbage is discharged from the ship. Hazardous garbage. The company reserves the right to refuse the landing of any garbage that cannot be disposed of safely at the facilities available to it in Liberia. This will include all garbage containing radioactive isotopes. Prevention of Pollution by Polyisobutylene Disposal Polyisobutylenes (PIB) are chemicals mainly used for thickening lubricants such as gear oils, engine oils, transmission oils, hydraulic fluids and metal working fluids. In the past it has been legal to dump PIBs in the sea outside coastal waters. No ship chartered by or under any contractual obligation to ArcelorMittal Liberia Limited may dispose of PIBs at sea, whether within territorial waters of Liberia or any other country, or in international waters. PIB residues may only be landed onshore when a ship is berthed in port, and sent for appropriate disposal at facilities certified to handle it. If in Liberia, the handling facility must have a current certificate issued by the Environmental Protection Agency. Prevention of Air Pollution IAPP Certificate. All ships shall be in possession of a valid International Air Pollution Prevention (IAPP) Certificate issued in accordance with MARPOL 73/78 Revised Annex VI as amended by resolution MEPC 176(58) in 2008. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s IAPP Certificate. Use of engines. The use of engines shall be minimised while ships are in port to that required for manoeuvring the ship, and for maintaining power for loading or discharging cargoes and for other ship-running purposes. Engines shall not be run on greater than half power while within the port basin or within two kilometres of the outer breakwaters, except where it is essential for manoeuvring the ship and avoiding collisions. Engines that have been serviced while berthed at Buchanan may be subjected to short test runs. Ship-board incinerators. Ship-board incinerators shall not be operated on any ship while berthed at the Port of Buchanan because of the downwind proximity of the city. Resident ships may use approved high temperature incinerators (i.e. those with a combustion temperature greater than 900 degrees centigrade) outside the breakwater. Visiting ships must not use incinerators while they are within 5 nautical miles of the shore of Liberia unless they are lying at anchor outside the breakwater




for more than ten days. Under these geographical restrictions, incineration may be undertaken in accordance with the provisions of MARPOL 73/78. Ozone-depleting substances. No ship shall discharge ozone-depleting substances into the atmosphere when it is berthed at the Port of Buchanan, anywhere within Liberian territorial waters or while it is operating on behalf of the company through any charter or contract arrangement. The company will not provide reception facilities for ozone-depleting substances. The ship or the ship‟s agent may dispose of ozone-depleting substances elsewhere in Liberia only if the operator of such a facility has a valid Environmental Certificate issued by the Liberian Environmental Protection Agency for reception of those substances, and proof of this is provided to the company before the substances are discharged from the ship. Emission of nitrogen oxides. All ships shall adhere to the provisions of the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines of the MARPOL 73/78 Revised Annex VI as amended by resolution MEPC 176(58) in 2008 (the NOx Technical Code 2008). All diesel engines shall comply with the emissions limits specified in the NOx Technical Code 2008 and for each engine the ship shall carry a valid Engine International Air Pollution Prevention (EIAPP) Certificate issued in accordance with Chapter 2 of the NOx Technical Code 2008. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s EIAPP Certificate. Emissions of sulphur oxides and particulate matter. All ships shall use fuel that complies with the limits set for sulphur content in Regulation 14 of MARPOL 73/78 Revised Annex VI. Source: MARPOL 2006 Consolidated Edition (i.e. MARPOL 73/78 and all Annexes and Amendments up to and including 2006); Revised MARPOL Annex VI and NOx Technical Code 2008 (2009 Edition); 1996 Protocol to the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972, as amended in 2006 (the London Dumping Convention); and the Liberian Maritime Regulations (2002).

9.5 Standard for Ships’ Ballast Water Management Introduction While ballast water is essential for safe and efficient shipping operations, it may pose serious ecological, economic and health problems due to the multitude of marine species carried in ships‟ ballast water. These include bacteria, microbes, small invertebrates, eggs, cysts and larvae of various species. The transferred species may survive to establish a reproductive population in the host environment, becoming invasive, out-competing native species and multiplying into pest proportions. To safeguard the marine environment, all ships entering the Port of Buchanan for loading iron ore shall be required to manage ballast water in a responsible and planned manner. This shall be in accordance with the International Convention for the Control and Management of Ships‟ Ballast Water and Sediment, 2004 (“BWM Convention”). All shipping contractors and agents shall follow the regulations, guidelines and other provisions of the International Maritime Organization (IMO) or the Maritime Environment Protection Committee (MEPC) in connection with this Convention, irrespective of whether their flag of registry is or is not a signatory to the BWM Convention. The Port of Buchanan does not have an onshore reception and treatment facility for ballast water. Therefore all ore carriers and other ships will be required to discharge their ballast water into the sea. The Port of Buchanan is a largely enclosed area with limited currents and tidal flow. It is rich in marine life in the midst of a relatively pristine coastal environment. For these reasons, the company is obliged to make every effort to ensure that its shipping operators abide by the highest environmental standards.




Systems and safeguards Shipboard ballast water management system. All ships shall have a ballast water management system of a type approved by the International Maritime Organization and in good working order. This shall comply with Guidelines for Approval of Ballast Water Management Systems (G8) of Resolution MEPC.174(58), 10 October 2008. Certificate of ballast water management. All ships shall have a valid International Ballast Water Management Certificate, issued under the provisions of the BWM Convention. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s certificate. Ballast water record book. All ships shall have a full and up to date Ballast Water Record Book. This shall comply with the stipulations of Appendix II to the BWM Convention. It must contain as a minimum, full records of the following: the ship and its ballast water capacity; the taking on board of ballast water, including source, volume and timing; circulation or treatment of ballast water; the discharge of ballast water, including location, volume and timing; any accidental or exceptional ballast water incidents. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s Ballast Water Record Book. Ballast water management plan. All ships shall have a full and up to date Ballast Water Management Plan. This shall comply with Guidelines for Ballast Water Management and Development of Ballast Water Management Plans (G4) of Resolution MEPC.127(53), 22 July 2005. It must contain as a minimum, full details of the following: the ship and its ballast water capacity; the name of the officer responsible for administration of the plan; details of the arrangements of ballast water tanks, pumps, treatment systems and other facilities, and their layout on the ship; a description of the ballast system; the locations of sampling points; ship and crew safety procedures; operational or safety restrictions; a description of the methods used for onboard water management and sediment control; procedures for the disposal of sediment; duties of the officers and crew; recording requirements; training provisions; and exemptions. If the plan is in another language, a full English translation will be provided. When berthed at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect the ship‟s Ballast Water Management Plan. Over-riding safety provisions. The exchange or discharge of ballast water when a ship is at sea may be avoided when the weather or sea conditions are such that the safety of the ship and its crew will be prejudiced. Such conditions will be recorded and the lack of action will be reported to the company‟s environmental staff on arrival at the Port of Buchanan, and before any water is discharged. Procedures Minimisation. Ships shall minimise the use, uptake and discharge of ballast water to the greatest extent possible within the requirement for safe operation of the ship and handling of cargo. Taking on ballast water. When taking on ballast water, every effort shall be made to avoid the uptake of potentially harmful organisms, pathogens and sediments. The uptake of ballast water shall be avoided in the following situations:

areas identified by a port authority as being potentially polluted;

in estuarine or turbid coastal waters;

within 5 nautical miles of large coastal or riverine cities;

in darkness (when organisms may rise up the water column);

in very shallow water;

where propellers may stir up sediments; or

where dredging is active or has recently been carried out. Exchange of ballast water. Since ships entering the Port of Buchanan for the purpose of loading iron ore will have travelled from a completely different environment, they are required to exchange ballast water on the voyage. The voyage from the port of origin to Buchanan will therefore be planned in such a way as to ensure suitable ballast water exchange. The exchange of ballast water must comply




with Guidelines for Ballast Water Exchange (G6) of Resolution MEPC.124(53), 22 July 2005. The exchange of ballast water should follow these guidelines:

there shall be at least 95 percent volumetric exchange of ballast water;

where the pumping-through method of exchange is used, the water pumped through will be at least three times the volume of each ballast tank.

Locations for the exchange of ballast water. All exchange of water should be undertaken at least 200 nautical miles from the nearest land. If the voyage does not take the ship so far from land at a suitable latitude (see below) then the exchange of water must be undertaken in depths exceeding 200 metres and at least 50 nautical miles from the nearest land where that land is part of the African continent. In any event, all exchanges of water are to be undertaken between the Equator and the latitude of 15 degrees north. The locations for the exchange of ballast water shall otherwise comply with Guidelines on Designation of Areas for Ballast Water Exchange (G14) of Resolution MEPC.151(55), 13 October 2006. Discharging of ballast water. Every ship will discharge the maximum amount of ballast water that it is safe to offload before entering the Port of Buchanan. Wherever possible, this should be before entering water with a depth of less than 200 metres. Sediment management. Ships will not undertake any sediment management operations within 200 nautical miles of the coast of Liberia. Monitoring and assessment by the company Failure to follow procedures. In the event of a ship failing to follow any of the procedures given above, for example through reasons of safety or equipment failure, the fact and circumstances shall be reported to the company‟s environmental staff before any water is discharged. The company will then agree suitable mitigation actions with the ship‟s master. Monitoring by the company. On berthing at the Port of Buchanan, the company‟s environmental staff may board the ship to inspect any of the ship‟s ballast water management documents. The ship‟s master or designated officer may be required to provide a list of the potentially harmful organisms found at the port of origin (“target species” under the BWM Convention, G7, which are those species of concern that may impair or damage the environment, human health or resources). The company shall also be permitted to sample the ship‟s ballast water tanks and to undertake analyses of the water and sediment found there. This will be done in accordance with Guidelines for Ballast Water Sampling (G2) of Resolution MEPC.173(58), 10 October 2008. Risk assessment. The company is to undertake a risk assessment of the threats posed by potentially harmful organisms from areas that are the points of origin in the event that a significant number of vessels enter the Port of Buchanan from the same origin. This shall follow the Guidelines for Risk Assessment under Regulation A-4 of the BWM Convention (G7) of Resolution MEPC.162(56), 13 July 2007. Source: Ballast Water Management Convention and the Guidelines for its Implementation, 2009, published by the International Maritime Organization.




9.6 Standard for Ship to Ship Transfers This standard covers the approved procedure for the transhipment at sea of iron ore. With suitable adaptations, it can also be used for fuel bunkering in international waters. The ocean-going vessel (OGV) must be lying at anchor. It is treated as static and the transhipment vessel (TV) carries out the manoeuvres necessary to moor alongside her. To bring two large ships together is a major operation requiring rigorous teamwork between both crews, and with the crews of the supporting tugs. To ensure that this operation happens safely, three formal checklists are followed:

Checklist 1: Pre-fixture exchange of information;

Checklist 2: Before operations commence; and

Checklist 3: Before run-in and mooring. These checklists are given on the following pages. The first two shall be completed before the TV leaves port. The third checklist, “Before run-in and mooring”, shall be completed as the TV clears the port breakwaters and the Master takes over from the Pilot. As the TV leaves port, her Master shall begin detailed communications with the Master of the OGV. On site control of the transhipment is in the hands of the Master of the TV, who shall advise the master of the OGV on the actions required. However, the Master of each vessel is still responsible for his own vessel, crew and cargo. Each Master shall ensure that during all stages of the operation there is sufficient manning for a safe and efficient operation. The Masters of both the TV and the OGV shall ensure that the navigating bridge is continuously manned by a qualified officer throughout the operation and that the main engines are at all times available for manoeuvring. In particular, the OGV‟s Master shall ensure that an adequate number of crew is available at all times to handle the mooring lines from the TV safely. Communications shall be by VHF channel 13 and an agreed working channel using portable UHF/VHF sets or walkie-talkies. In the event of radio communication breakdown between the vessels, one prolonged blast on either ship‟s whistle shall mean „emergency stop‟; and approach, mooring or cargo operations are to be suspended immediately. Once the pre-operation communications and checks are complete, the TV may start its final approach towards the OGV. This operation shall be assisted by the tugs that are kept on charter at Buchanan. As the TV approaches the OGV, cables shall be passed from the bow of the TV to one tug, and from the stern of the TV to the second tug: these are to allow either end of the ship to be pulled as necessary, and the tugs can also push the ship if required. The approach shall be undertaken very slowly, with the TV gradually losing way forwards and then being pushed sideways by the tugs, into position against the OGV. The Master of the TV shall conduct this part of the operation from the port wing of the bridge, which provides a clear view of both ships. As the gap narrows between the ships, ropes shall be passed across and the TV‟s mooring cables pulled over to be secured to the OGV. These shall then be used to fine tune the positioning of the two ships, and to ensure that the ships are longitudinally aligned for the loading sequence that is about to be started. To help make the operation as efficient as possible, the intention is that the TV makes only one approach, and positions herself longitudinally so that only one ranging movement (i.e. fore or aft shifting against the OGV) is required in each loading cycle. Once the TV is fully moored against the OGV, with approximately 16 cables deployed between the ships, the tugs shall be used to push the combined pair around so that they lie across the swell with the smaller TV in the lee of the larger OGV. The bows shall be held by the OGV‟s anchor, and the sterns held in place against the wind by the tugs. This gives the greatest stability and minimises the movement of the TV. To maintain this position, the tugs shall remain in place throughout the transhipping operation and must follow the instructions given by the Master of the TV.




If the wind exceeds 25 knots or the swell height exceeds about 3 metres, the masters of the two ships must evaluate the conditions and discuss them immediately and at two-hour intervals thereafter. If one Master considers that conditions exceed what is safe for working, operations must be stopped until the situation improves. Wind-driven waves tend not to be much of a problem for such large ships, but the long, deep sea swell can be. The actual transhipment operation is driven by a loading plan for the OGV. It is important that, as the cargo is transferred, it is distributed in such a way as to keep the ship stable. As the weight of iron ore in the OGV increases, water must be pumped out of the ballast tanks to compensate. The loading plan will therefore have been transmitted to the TV, and must be closely followed between the responsible cargo transfer officers on both the TV and the OGV. Three checklists are required to be followed during the actual transhipment operation, as shown on the following pages.

Checklist 4a: Before cargo transfer.

Checklist 4b: Dry bulk cargo transfer.

Checklist 5: Before unmooring. In summary, the TV shall transfer the DSO to the OGV by means of a belt conveyor and ship loader system into the OGV. The entire discharge system shall be controlled by the TV operator from the cargo control room of the TV. The cargo operations shall also be monitored by a deck watchman on the TV. Once the two ships are in position across the swell, the appropriate cargo hatches are to be opened on the OGV. The shiploader of the TV shall then be manoeuvred across the gap and positioned with the feed chute over the middle of the hold. The operator of the shiploader shall be positioned at the outer end of the secondary boom, and he shall remain in contact with the Master of the TV and the TV‟s cargo control room by two-way radio. From the holds of the TV, iron ore is then to be brought through the ship by a series of conveyors and lifts, to the shipboard end of the primary derrick of the shiploader. It then passes along conveyor belts that run along the derrick and the secondary boom, and is discharged into the OGV‟s hold from a chute at the extreme end of the boom. The transfer shall continue, apart from the movement of the boom to ensure that the holds are filled in the correct order and are properly trimmed (i.e. evenly loaded). As ore is transferred, the shall TV take on ballast water to compensate, and at the same time, the OGV shall discharge its ballast water. Usually once per discharge of a full TV load, the TV has to be ranged (moved) alongside the OGV to allow the shiploader boom to reach other holds. This is done principally by altering the tensions on the mooring ropes, but tug assistance may also be required. Interruptions may also occur if rain forces the necessity of closing the OGV‟s cargo hatches. On completion of unloading of the TV, the shiploader shall first be docked back in its central fore-and-aft position. The unmooring procedure shall then be activated, following a system in reverse of the mooring pattern described above. Source: ArcelorMittal Liberia; checklists supplied by CSL Limited, adapted from the International Maritime Organization’s Manual on Oil Pollution (2011).




SHIP TO SHIP TRANSFER

CHECKLIST 1 – PRE-FIXTURE EXCHANGE OF INFORMATION

Name of OGV:

Name of TV: MV CSL ATLAS

Expected Date of Operation: OGV Operator’s

Confirmation Remarks

1. What is the LOA? What is the parallel body length at loaded and ballast draft?

2. Can the ship maintain less than 5 knots for a minimum of two hours? (in case of double-banking while underway)

3. What is the height from top of hatch cover from water line at loaded, light ballast and heavy ballast conditions? What is the maximum/minimum height expected during the operation?

Insert figure:

4. Are both sides of the ship clear of any overhanging projections?

5. Is the transfer area agreed?

6. Is the ship fitted with sufficient enclosed fairleads to receive the other ships mooring lines?

7. Has the shipper provided the cargo specifications? (Moisture content, Safety Guidelines, MSDS, others)

8. Are the atmosphere measuring instruments calibrated and a service/calibration log available?

9. What is the nationality of the OGV Master, Officers and crew on board? Are there any other persons on board besides the crew? (provide designation and nationality)

10. Have the vessels (OGV and TV) been advised that checklist 1 is satisfactorily completed?

For OGV Operator: Name: Rank: Signature:





CHECKLIST 2 – BEFORE OPERATIONS COMMENCE

Name of OGV:


Date of Operation: OGV

checked TV

checked Remarks

1. Has checklist no 1 “Pre-fixture Exchange of Information” been completed and received from operators of vessels?

2. Are radio communications well established?

3. Is language of operation agreed to be English?

4. Is the rendezvous position agreed?

5. Has the mooring plan been prepared and agreed?

6. Are berthing and mooring procedures agreed and is it decided how many, and which moorings ropes will be provided by each ship?

7. Is the ship upright and at a suitable trim?

8. Are engines, steering gear and navigational equipment tested and found in good order?

9. Are the engineers briefed on engine speed (and speed adjustment) requirements?

10. Has a weather forecast been obtained for the transfer area?

11. Are fenders and fender pennants rigged and in good condition?

12. Are the crew briefed on mooring procedures?

13. Are the contingency plans agreed?

14. Have the local authorities been advised about the operation and necessary clearances obtained?

15. Has a navigational warning been broadcast?

16. Has the other vessel been advised that checklist 2 is satisfactorily completed?

Master: Date:





CHECKLIST 3 – BEFORE RUN-IN AND MOORING

Name of OGV:



checked TV

checked Remarks

1. Has check list no 2 “Before Operations Commence” been completed?

2. Are primary fenders floating in their proper place? Are fender pennants in order?

3. Are secondary fenders in place, if required?

4. Have over side protrusions on side of berthing been retracted?

5. Is a proficient helmsman at the wheel?

6. Has course and speed information been exchanged and understood?

7. Is engine speed adjustment controlled only by changes to revolutions or pitch?

8. Are navigational signals displayed?

9. Is adequate lighting available?

10. Is power available on winches and windlass and are they in good order?

11. Are rope messengers, rope stoppers and heaving lines ready for use?

12. Are all mooring lines ready as per the agreed mooring plan?

13. Are mooring gangs in position?

14. Are communications established with mooring gangs?

15. Is the anchor on opposite side to transfer made ready for dropping?


Master: Date:





CHECKLIST 4a – BEFORE CARGO TRANSFER

Name of OGV:



checked TV

checked Remarks

1. Are all requirements from the International Ship/Shore Safety Checklist complied with?

2. Is the gangway stowed and well secured?

3. Is an inter-ship communication system established and understood?

4. Is the main engine on standby notice for manoeuvring as appropriate to weather conditions and an engine room watch maintained throughout the transfer?

5. Are fire axes or suitable cutting equipment in position at fore and aft mooring stations?

6. Are a bridge watch and anchor watch established?

7. Is a deck watch established to pay particular attention to moorings, fenders and security?

8. Is the cargo transfer plan, ballasting requirements and transfer rate agreed with the other vessel?

9. Is the availability of personnel for support operations such as signalling, trimming agreed with the other vessel?

10. Is a security plan in place for each vessel?

11. Has procedures for contingencies, operation shut down and rapid cast off agreed?

12. Are smoking areas designated on board vessel and strict no smoking rules for other areas enforced?

13. Are procedures for hot work/repair work agreed upon?

14. Are procedures for monitoring of cargo hold atmosphere, deployment of pollution prevention containment system agreed upon?

15. Are the notification procedures as per SOPEP plan understood by all?


17. For dry bulk cargo transfers checklist 4b to be completed

Master: Date:





CHECKLIST 4b – DRY BULK CARGO TRANSFER

Name of OGV:



checked TV

checked Person

responsible

1. Person Responsible to Load the OGV:

__________________________________

Chief officer

2. Is it understood that the loading and trimming of the OGV is the sole responsibility of the Master of the OGV or supercargo representing the OGV?

OGV

3. Number of mooring lines required to shift alongside the OGV has been agreed? Indicate #

___________________

Chief officers,

both ships

4. Total quantity of cargo to be loaded onto the OGV?

Indicate ordered quantity ___________________ M/T

OGV

5. Rate of unloading (loading onto OGV) requested?

M/T per Hour _______________________________

OGV

6. Trimming unloading rate requested?

M/T per Hour _______________________________

Chief officer, OGV

7. Is it understood that the Vessel is to notify the OGV when the operation is complete?

Chief officer

8. Emergency stops of unloading equipment been demonstrated to the OGV representative?

Chief officer

9. Is the OGV representative aware that from the time a stop order is given until the time the last cargo comes from the boom can be as long as one minute and thirty seconds; unless an emergency stop is ordered?

Chief officer

10. Is it known that unloading vessel personnel will not involve or advise the amount of cargo that should be loaded onto the OGV?

Chief officer

11. Have all other pertinent transfer operations been agreed to with the OGV representative?

Chief officer

12. Has the cargo declaration been received? Chief officers,

both ships

13. Is the OGV representative aware that the following standard vocabulary will be used for this operation:

Chief officer

Continued on next page…




Checklist 4b continued OGV

checked TV

checked Person

responsible

STOP CARGO - For normal stops, allow 1 min 30 sec to run off belts

Chief officer

EMERGENCY STOP – To shut down systems in an emergency

Chief officer

COMPLETED LOADING – On completion of loading OGV Chief officer

BOOM TO PORT - To slew the ships boom to the port side Chief officer

BOOM TO STARBOARD – To slew the ships boom to the starboard side

Chief officer

LOWER BOOM - To lower the boom Chief officer

HOIST BOOM - To raise the boom Chief officer

Remarks:

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

OGV Representative Transhipment Vessel Representative ____________________________ ____________________________ ____________________________ ____________________________ Signature Signature

When the actions detailed in this checklist are complete, a responsible person shall make the required entries in the Deck or Engine Log as applicable, and Official Log Book/Crew Articles of Agreement if applicable; if use of the checklist is mentioned, then include the reference number of the checklist in the Log and/or Articles.





CHECKLIST 5 – BEFORE UNMOORING

Name of OGV:



checked TV

checked Remarks

1. Is the transfer side of the ship clear of obstructions?

2. Are the local authorities informed and necessary clearances obtained?

3. Have engines, steering gear and other navigational equipment been tested and found in good order?

4. Is a proficient helmsman at the wheel?

5. Has area traffic (shipping) been checked and a navigational warning broadcast?

6. Has the method of unberthing and of letting moorings been agreed with the other vessel?

7. Are navigational signals displayed?

8. Is adequate lighting available?

9. Is power available on winches and windlass and are they in good order?

10. Are rope messengers, rope stoppers ready for use?

11. Are mooring gangs in position?

12. Are communications established with mooring gangs?

13. Are mooring gangs instructed to let go only as requested by the manoeuvring vessel?


15. Has the navigational warning been cancelled (when clear of the ship)

Master: Date:




10. HAZARDOUS MATERIALS STANDARDS

10.1 Standard for the Storage, Dispensing and Disposal of Hazardous Materials The Contractor shall take full responsibility for the use and effects of any hazardous materials that are required for operations that are part of the Project. The Contractor is further responsible for complying with the Company‟s policies and procedures as may from time to time be communicated, and will ensure that all aspects of the spill clean-up plan are followed in the event of a spill (see appropriate standard). All materials that are potentially hazardous to the environment must be stored or disposed of in accordance with this standard. Hazardous materials include, but are not limited to, substances such as fuels, lubricants, preservatives, herbicides, pesticides, explosives, cement, lime, slurry clays, bentonite, catalysts or other chemicals, in solid or liquid form, or sewage and foul waste water. Approval by the Company for the use, storage and disposal of hazardous materials shall not reduce the Contractor‟s responsibility to prevent all leaks and spillages, nor his liability to remedy the damages which may be caused should such incidents occur. Prevention: Every effort will be made to prevent spills and leaks of any kind. All hazardous materials will be stored in appropriate ways, in line with international safety practices. All operators and supervisors will be trained in appropriate inspection procedures and checks. All problems detected during inspection must be passed on to the relevant superior officer. Appropriate repairs will be made immediately. Storage: Hazardous materials shall be stored at least 400 metres from the sea, a water course, spring, swamp, drain or well, and at least 400 metres from a dwelling. Storage areas shall have barriers and impervious surfaces preventing leakages of spilt material outside the storage area or into the underlying soils. They shall be protected from rainfall and secure against intrusion by people other than the Contractor‟s personnel. Fuelling operations: Fuel tanks will be bunded: i.e. there must be secondary containment for the full capacity of the tank in the event of a leak from the tank (see appropriate standard). A trained attendant will always be in control of fuelling nozzles during refuelling operations. Designated fuelling areas will be bunded (diked) and lined to capture any unexpected releases of fuel. Oil and lubricant dispensing drums will have spill containment trays and liners, or both, to catch and contain material. Refer also to the specific standards for the bunding of tanks and dispensing of fuel. Disposal: All used oils, lubricants, solvents, and filters will be recycled whenever possible. Where excess quantities of a hazardous material need to be disposed of, then the Contractor shall prepare a disposal plan and seek the approval of the Company before implementing it. In general, hazardous solids that need to be disposed shall be buried in a location proposed by the Contractor and approved by the Company. Disposal sites must be situated at least 400 metres from any dwelling and at least 400 metres from a water body or water course. They should not be on cultivated land. Wherever possible, they should be on a permeable but not sandy soil. Holes shall be a minimum of 2 metres deep when first excavated and all materials must be buried under at least 1 metre of soil. Sewage disposal: Sewage and foul waste water shall be disposed into a covered underground septic tank. If this is a permanent feature, then it shall have an underground soakaway so that water does not seep on to the surface. All parts of the system shall be at least 100 metres from a water body or water course. The Contractor shall present his plans for such facilities to the Company for approval prior to their implementation. Fuel contamination of water: Where there is a significant risk of water becoming contaminated with any form of fuel, such as in port areas, then appropriate containment equipment (e.g. floating bunds or barriers, absorbent pads etc) will be kept in readiness at fuel dispensing areas to assist in cleaning up any spills that may occur.




Cleaning up spills: In the event of a spill or release of any material, the spill will be stopped and the incident reported to the nearest representative of the Company. The substance will then be cleaned up immediately, disposed of in an approved manner and the contaminated environment cleaned to the satisfaction of the Company. A separate standard covers this in detail. Source: ArcelorMittal Liberia.

10.2 Standard for the Cleaning-up of Pollution by Hazardous Materials This standard covers the action to be taken in the event of the leakage or spillage of any environmentally hazardous material, such as fuel, oil, chemicals of any kind, or drilling slurry, into either a water course or standing water body, or into soil. It contains the minimum details that must be included in spill clean-up plans of all Contractors to the Company, and any Sub-contractors that may be engaged by the Contractors. Before bringing any hazardous materials to the site, the Contractor must prepare a spill clean-up plan in accordance with this standard and gain the approval of the Company. The purpose of a spill clean-up plan is to provide guidelines to prevent environmental contamination, and the procedures to be followed should hazardous materials enter the environment. It applies to all working areas of the Project. The Contractor must prepare on-site spill clean-up plans for all hazardous materials to be used on the site. This is a regulatory requirement of the Government of Liberia, and the minimum details that must be in the plan are as follows: (a) how incidents will be contained and controlled so as to minimise the effects and to limit danger to persons, the environment and property; (b) how the necessary measures will be implemented to protect people and the environment; (c) a description of the actions that will be taken to control the conditions and to limit their consequences, including a description of the safety equipment and resources available; and (d) arrangements for training staff in the duties they will be expected to perform. The emergency plan shall be simple and straightforward. The following principles must apply in the plan: (a) the source of the leak or spill must be stopped immediately it is discovered; (b) the alarm must be raised throughout the site; (c) work on the site must be stopped and all available resources directed into resolving the problem; (d) emergency measures must be taken to contain all remaining material; (e) where appropriate, measures must be taken to neutralise hazardous substances; (e) the Company shall be informed immediately; and (f) site-specific and material-specific details will be given for the disposal of contaminated soil and water, and mitigation of the damage caused. The Contractor shall ensure that all site supervision staff are aware of the plan and capable of implementing it. In the event of a leak or spillage, the Contractor shall bear all liability whether the plan is implemented or not. Spill response procedure: Every spill clean-up plan must contain, as a minimum, details of the following emergency procedures: The person who discovers any spill must notify fellow workers and inform the supervisor that a spill has occurred. If anyone is injured or in danger, they must be rescued if it is safe to do so, and appropriate rescue and medical assistance called if required. All site staff must be informed if there is a risk of fire or explosion, or of a collapse of infrastructure, and in these cases all unnecessary personnel must be evacuated to a safe location. All staff will react promptly to all spills, no matter how insignificant they may appear. Whatever resources are available will be diverted immediately to assist in resolving the spill. The Company‟s relevant sectoral Manager and the Safety, Health and Environment Manager will both be notified immediately if any spill or release occurs, however small. As much information as possible should be provided about the spill location, type of material, approximate quantity, and extent of damage.




The area surrounding the spill will be secured and contained to minimise additional contamination, for example by building an earth bund or the deployment of floating bunds. Emergency containment should be started as soon as possible. This will give time for a full pollution-control strategy to be designed, agreed and implemented. Source: ArcelorMittal Liberia.

10.3 Standard for Operation of the ArcelorMittal Liberia Incinerators (a) Inciner8 Industrial Incinerators Introduction Installed at each of the Buchanan and Yekepa hospitals is an Inciner8 Model P16 industrial incinerator. These are two-chamber incinerators designed to handle 60 kg per hour of waste on a 4-hour burnout time at temperatures between 950 and 1320 degrees centigrade. They are fuelled by oil and can be used to dispose of a wide range of medical and industrial waste materials. Pre-starting Checks and Actions The following pre-starting checks and actions shall be taken.

Ensure that the dedicated tools for the incinerator are always used only for the incinerator.

Always ensure adequate availability of fuel oil in fuel tank before attempting to start the incinerator. At no time should the incinerator be allowed to operate without fuel.

Check all fuel lines and tanks to ensure that there are no leaks whatsoever.

If there are leaks, ensure full tightness or repair.

The fuel pipe lines should always be completely clear of any obstruction.

Go to the fuel tank and open the fuel supply valve before start up.

The incinerator should not be modified in any way that is not in keeping with the manufacturer‟s instructions.

For health and safety reasons, the incinerator area should be kept locked at all times when not supervised.

Ensure that the incinerator is totally cleaned inside, and all ashes removed before loading.

Use the hoe provided at the front of the incinerator to scrape the ash remaining above the gate on to the hearth below. Remove ash through the ash door opening. Place all ashes in a fire proof container to avoid any possibility of fire.

Open the upper incinerator door and ensure that an extra weight is hung on both sides to hold the door in place while loading the waste into the incinerator.

Load the incinerator with the desired waste up to the cut level.

Ensure that at no time it should ever be overloaded.

Keep the waste 20 cm away from the burner port.

Now lock the unit door and ensure that no one can inadvertently access the chamber during the process of burning.

A full load will normally burn at 45 kg per hour.

Once the burner has stopped, heat will always be retained in the refractory liner causing the burning process to continue. For this reason the operator should be very careful.

The burner is excessively hot: do not open it until after five (5) hours of cooling down.

After burning for four hours, the burner will automatically switch off, leaving only the lower fan operational. If this does not happen, the operator should immediately report it for system checks.

After the burn and cool down periods, the fuel supply should always be closed before departure from the site.

For the best results, burn daily to a white ash.




Electrical Operation The following electrical matters must be understood and observed.

The electrical power panel is installed at the immediate right hand side of the entrance of the incinerator housing and the electronic control system is installed at the back of the incinerator.

Switch on the main power feeder breaker to the electronics control system to power it for start of operations.

NOTE! The entire system is cut off immediately whenever this breaker is switched off.

Go to the electronic control equipment itself to begin the switch on of the incinerator.

Pre-heat the secondary chamber for fifteen (15) minutes by selecting the upper burner timer to on (1) position.

After 15-minutes‟ pre-heat period, start the main burner to begin the burning process. This must be strictly followed.

It is imperative to check the temperature monitor regularly and make recordings.

The temperature cut off device should cut off and stop the primary burner when the heater reaches 950 degrees centigrade, and re-ignite at 850 degrees centigrade.

The burner will automatically cut off when the chosen burn time is completed.

The fan should remain on for a minimum of five (5) hours after the burn cycle or when the primary chamber is less than 50 degrees centigrade or less.

Actions to Avoid: Don’ts The following must be avoided.

Do not store waste in the incinerator chamber.

“Singe and burn” does not constitute an approved pre-incineration storage process.

Do not close the main tank valve while the incinerator is in operation.

Do not open any heating part of the incinerator while it is in operation.

The P-16 is designed as batch feed unit and should not be re-loaded until the waste is reduced to white ash and the unit is cool after four (4) hours.

Actions to Complete: Do’s The following actions must be taken as necessary.

In case of any form of breakdown, shut down the burner immediately. If possible, leave the fan running.

It is important that the burner is set correctly by adjusting the air and fuel flows.

Look at the burner flame. If it is producing black smoke at the ends of the flame, make small adjustments to make the flame more lean, so that it is clear.

The above should also be checked after periods of shutdown.

It is important to have a valid contingency plan to dispose of waste in the event of breakdown. Inspection Procedures These inspection and servicing procedures must be followed.

Periodic inspection and servicing of the unit is required to maintain optimum operation.

The first service (post-installation check-up) must be conducted after 50 hours of operation.

Regular services and inspections must take place every 1000 hours of operation or annually, whichever is the soonest time.

Check for leaks in all pipe work.

Tighten unit components to ensure that all waste gas travels up the chimney.

All safety shut-off valves and safety guards should be inspected regularly.

A temperature and combustion analysis should be performed to ensure that there is no deterioration of incinerator performance.

Timer and temperature probes should be calibrated to ensure that they reflect a true reading and ensure that the safety cut off applies.

Source: edited from ArcelorMittal Incinerator SOP, based on manufacturer’s instructions.




(b) Practical Action Low Cost Waste Incinerators Introduction Also installed at the Yekepa and Buchanan Hospitals are simple two-chamber natural-draught incinerators designed to be operated at temperatures of 800 degrees centigrade and higher. These were designed jointly by Practical Action and De Montfort University, and built on site using local materials. The performance of the incinerator will vary depending on the moisture content of the medical waste but a throughput of up to 15 kg/hour can be achieved. The incinerator has been designed so that it can be built on site, using standard building bricks or blocks and lined with refractory bricks. All the steel components, such as the loading door, the ash removal door and air inlet apertures can be made using basic workshop equipment. Wood, wood and dry waste soaked in kerosene or diesel is required initially to start the combustion process. Once the correct temperature is reached, the medical waste is loaded into the incinerator. Much of the medical waste will have value as a fuel and will contribute towards combustion but additional wood or kerosene may be required to ensure that adequate combustion temperatures are maintained. The initial combustion occurs in the primary chamber and then the hot gases pass into the secondary chamber where the combustion process is completed. The two-chamber design helps to ensure that the combustion time is sufficient to destroy the products of combustion and minimise any harmful emissions. The incinerator should be situated under a simple open-sided roofed structure, such as a lean-to, away from tall buildings and in an area free from air turbulence. Although it can be operated in the open, a roof will help to protect the incinerator from rain and provides shelter for the operator. The incinerator is capable of incinerating most types of medical waste including textiles, plastics and packaging. It can also incinerate most types of drugs, medicines, vaccines and sharps – as long as they are mixed with other wastes. However, as grease-based products, such as ointments, creams and Vaseline create large quantities of dense black smoke when burned, they are best disposed of by other means. Operating the Incinerator Opening the Loading Door: When opening the loading door always wear eye protection and a face mask. The reason for this is that the opening the loading door on either the wood or kerosene fired version during operation will mean that additional air will enter the combustion chamber. This may cause blowback to occur and the flame to flare up out of the loading door. The blow-back does not last long but it could cause injury to anyone standing too close to the incinerator. Particular care should be taken when using kerosene as atomised vaporised fuel may be present at the top of the combustion chamber which could ignite vigorously. The operator should open the door while standing at the front of the incinerator. The loading door is designed so that it hinges from the front of the incinerator and opens towards the operator. This provides the operator with some protection from any blowback and keeps him/her away from the opening to the combustion chamber. The operator should wait a few moments to allow any blow-back to die down before loading waste materials into the incinerator. Small Explosions: Some waste materials such as ampoules and glass bottles containing liquid vaccines and medicines may explode during incineration causing glass and other waste materials to be blown into the atmosphere. The operator should ensure that eye protection and a facemask is worn when opening the loading door or when visually checking the combustion process through the air inlet or when removing the ash door while the incinerator is in use.




Handling Waste Always wear heavy-duty gloves and apron while handling medical waste. If the waste is bagged hold the bag by the top and away from your body. Drop the bag through the loading door opening and if it gets stuck use a stick to push the bag into the combustion chamber If the waste is loose, use a shovel to load it into the combustion chamber. Removing Ash and Other Solids from the Combustion Chamber Never handle the ash or other waste materials by hand. Use a stick or scraper to pull the solids out through the ash door and into a dustpan or box. Do not remove the ash or other waste materials from the combustion chamber until they have cooled down. This will take about five hours. If the incinerator is in operation on a daily basis then the ashes and other waste material can be removed the following day as part of the preparation for operation. Dispose of the ash and other waste materials carefully by burying or placing in a skip for disposal by local authority or other authorised disposal company. General Operating Notes The following notes are intended to give the operator a basic understanding of how to operate the incinerator. Optimum operation of this incinerator requires frequent attention to ensure that it performs effectively. It will take time for the operator to become familiar with the operation. Waste Management. Materials with high fuel values such as plastics, paper, card and dry textile will help maintain high incineration temperature. If possible a good mix of waste materials should be added with each batch. This can best be achieved by having the various types of waste material loaded into separate bags at source i.e. the wards and laboratories, and clearly labelled. It is not recommended that the operator sorts and then mixes the waste prior to incineration as this is potentially hazardous. The operator can then judge when to place which type of waste into the incinerator at any particular time. If possible some plastic materials should be added with each batch of waste as this burns at high temperatures. However, care and judgement will be needed as too much plastic will create dense dark smoke. Wet kitchen waste should not be placed in the incinerator. Operating Temperatures The incinerator does not have a temperature gauge and so adequate operating temperatures have to be judged by the operator based on experience. A visual guide is to look through the air inlet and at the colour of the smoke from the stack. If a good strong flame can be seen then the temperature should be more than 800

oC at this point and so will be adequate for good incineration. If the smoke is

dark grey or black then poor combustion is occurring and the temperature will be below that required. Starting and Operating the Wood Fuelled Version (the Yekepa Hospital Model) Open the loading door and ash door and remove any ash or other materials from the fire box, ensuring that the grate is clean and the entrance to the flue is not blocked. Before lighting the incinerator, prepare the fire wood, ensuring that it is dry and chopped or cut into short lengths (that fit horizontally through the loading door) and not more than 75 mm (3”) in section. If the wood has a high moisture content (i.e. above 15%) then it will be difficult to get the incinerator up to the operating temperature. Place paper on the grate and cover with dry kindling and small pieces of wood and/or dry textiles.




Light the paper through the ash door and NOT through the loading door. (This prevents the operator being burnt if paper and kindling material flare up unexpectedly). Once the fire is established and burning well, start adding the fire wood in small amounts. The loading door can be closed after about 5 minutes from lighting and once the fire is being drawn from the primary combustion chamber into the secondary chamber and up the stack. The ash door can be closed once the fire is well established. A well-established fire will roar and will be audible through the air inlet tubes. Practice will enable the operator to judge when the fire is established. Fire wood and/or dry waste is added at intervals until the incinerator is operating at the right temperature. The operating temperature will be achieved between half and one hour from lighting, depending on the ambient temperature, moisture content of the wood and the type of wood being used (i.e. hard, soft etc.) Once up to operating temperature, start to add the general waste material on small batches at regular intervals. The level of material in the incinerator should be such that the incinerator is always above half full. If the waste is predominately unwanted drugs, straw or wood may be placed in the incinerator before the drugs to hold the boxes in position for a longer period in order to prevent pills falling through the incinerator without burning. Sharps, including hypodermics, should be mixed with other waste to prevent them falling through the incinerator without being destroyed. If the waste material has a high moisture content or has a low fuel value, wood can be added to help maintain the correct operating temperature. The grate and flue entry should be checked every 15 minutes and raked clear of any obstruction. This is to ensure that the airways are kept clear. At the end of the operating session and all the waste has been placed in the incinerator, add more wood to ensure that any waste residue has been completely burned. Source: adapted from instructions provided by Practical Action and De Montfort University.

10.4 Standard for the Use of Wood Preservative The use of timber pre-treated with creosote is approved for railway sleepers (ties) on the Buchanan-Tokadeh railway. The only wood preservative approved for application by personnel of the Project is for products containing copper naphthenate at a concentration of 21.6%. It is widely recognised that the handling of creosote carries a risk of cancer. This is reflected, for example, in the Directive 2001/90/EC of the Commission of the European Communities, dated 26 October 2001, restricting the marketing and use of creosote as a “dangerous substance”. However, it is also widely accepted that creosote may be used for wood treatment in industrial installations or by professionals covered by appropriate legislation on the protection of workers. This is only for creosote preparations that contain: (a) benzo-a-pyrene at a concentration of less than 0.005% by mass; and (b) water extractable phenols at a concentration of less than 3% by mass. In Europe and North America, only certified companies may handle liquid creosote and undertake pressure treatment. No organisations are certified to do this in Liberia.




In the rehabilitation and operation of the Buchanan-Yekepa railway, the use of creosote conforming with the limits described in paragraph 3 above is therefore accepted as a means of preserving railway sleepers (ties), providing that workers handling timber so-treated are clothed with a minimum of: (a) overalls with long sleeves and legs; (b) boots; (c) thick waterproof gloves. At all times when sleepers are being handled, adequate washing water and soap must be available to workers in case of an accident. New railway sleepers need to be drilled to allow the rail fixings to be attached. This is to be done either in the lay-down yard inside the Buchanan port concession, or on the railway itself. The drill holes (eight per sleeper) need to be treated with further preservative before the fixing bolts are inserted. This site treatment of sleepers may be done using a substitute for creosote. The approved option is based on copper naphthenate (21.6%) and is supplied under the trade name of “Coppertreat”, although there are many other product names using the same active compound. A stronger concentration may not be used without the Company‟s approval. Wood preservative shall be considered a hazardous substance and shall be stored and used in accordance with the standard covering the use of such materials. The Contractor using the material shall prepare and seek approval of a spill clean-up plan to cover its use. No storage, handling or application of wood preservative, however temporary, is permitted within 100 metres of a water body of any kind (including creeks, streams, wells, springs, ponds, swamps, ditches and drains). Treatment of sleepers shall use the minimum amount of preservative required to saturate the newly cut wood so that effective treatment is achieved. Workers must wear the clothing described in paragraph 4 above plus breathing masks and eye goggles. The use of wood preservative will be subject to regular monitoring by the Company‟s environmental team. Source: ArcelorMittal Liberia.

10.5 Standard for the Use of Pesticides (Herbicides and Insecticides) Approved pesticides The table below shows the only pesticides that are approved for use by ArcelorMittal Liberia and its contractors.

Chemical Purpose Comments

Toilet chemicals - some contain formaldehyde

Sanitation Avoid use altogether as they are incompatible with the fluidised aerobic bio reactor sewage treatment facilities.

Decis Deltamethrine 2.5 EC Pesticide Domestic safety Malaria vector control.

Snake repellent - naphthalene-based Domestic safety

Glyphosate Herbicide

Prometron Herbicide Stronger than Glyphosate

Creosote Timber treatment Imported in timber; not approved for use as a liquid in Liberia.

Coppertreat (copper naphthenate) Timber treatment See Standard 10.4.

Sun methrin / Deltamethrin Insecticide

Masterline Kontrol Residual larvicide Malaria vector control.

AllPro ProVect Larvicide Malaria vector control.

SUNPAR Fogging insecticide Malaria vector control.




Banned pesticides The following pesticides are banned outright from use by ArcelorMittal Liberia and its contractors.

Chlorpyrifos, an organophosphate insecticide commonly sold as Brodan, Detmol UA, Dowco 179, Dursban, Empire, Eradex, Lorsban, Paqeant, Piridane, Scout, Stipend and Tricel, in any form.

DDT, an organochloride insecticide commonly sold as Anofax Cezarex, Dinozide, Gesarol, Guesapan, Guesarol, Gyron, Ixodex, Neocide, Neocidol and Zerdane, in any form.

Unlisted pesticides The following pesticides are not approved for use but might be considered under certain controlled conditions.

Dichlorvos, an organophosphate insecticide commonly sold as Apavap, Benfos, Cekusan, Cypona, Derriban, Derribante, Devikol, Didivane, Doom, Duo-Kill, Duravos, Elastrel, Fly-Bate, Fly-Die, Fly-Fighter, Herkol, Marvex, Nogos, No-Pest, Nuvan, Prentox, Vaponite, Vapona, Verdican, Verdipor, and Verdisol. This would not be considered for use in any form other than pre-impregnated strips.

Bifenthrin, a pyrethoid insecticide commonly sold as Talstar, Termstar, Maxxthor, Capture, Brigade, Bifenthrine, Ortho Home Defense Max, Bifen IT, Bifen L/P, Torant, Zipak, Scotts LawnPro Step 3, Wisdom TC Flowable, FMC 54800 and OMS3024. This would not be considered for use except with very low concentrations of bifenthrin.

Any member of the staff of ArcelorMittal Liberia or its contractors wishing to use either these or pesticides not listed in the table of approved chemicals given above, should contact the ArcelorMittal Liberia Environmental Adviser or Environmental Manager for advice. Details of the proposed substance, location, purpose and methods of use will be required. Herbicides The only herbicides approved for use by the Company are Glyphosate (41.1%), commonly sold as Roundup and other trade names, and Prometon (12.5%). Glyphosate is a post-emergent herbicide, to kill off existing weeds, and needs to have direct contact with green leaves to be effective. It is diluted at 2% concentrate in water before spraying (i.e. 20 ml of concentrate is added to every litre of water in the spray mix). Prometon is both a residual and post-emergent weed killer, and may be sprayed both before and after they have emerged. Recommendations for use vary but typically a dilution of around 5% concentrate in water appears to be effective in many situations. Locations of use Glyphosate and Prometon of the approved concentrations may be used for weed control on the railway and in other built-up areas, providing that they are mixed to the dilutions described above. No other concentrations are permitted on the Project site without the Company‟s prior approval. On the railway, spraying is to be restricted to the stone ballast area, and will not cover the earth embankment formation. The wider swathe of vegetation (14 metres each side of the track) will be managed by standard hand bush cutting. Under no circumstances may spraying be done within 5 metres of a water body. Safety Glyphosate and Prometon shall be considered as hazardous substances and shall be stored and used in accordance with the manufacturers‟ specifications covering the use of such materials. The Contractor using the material shall prepare and seek approval of a spill clean-up plan to cover its use.




No handling or storage of Glyphosate or Prometon concentrates, however temporary, is permitted within 100 metres of a water body of any kind (including creeks, streams, wells, springs, ponds, swamps, ditches and drains). The mixing of concentrates with water, and the filling and washing out of spray tanks must be done at least 100 metres from any such water body. Workers handling Glyphosate and Prometon must be clothed with a minimum of: (a) overalls with long sleeves and legs; (b) boots; (c) thick waterproof gloves; (d) breathing masks; and eye goggles. At all times when herbicide is being handled, adequate washing water and soap must be available to workers in case of an accident Application Spraying shall be undertaken using hand-held or knapsack sprayers, operated by hand pumps and emitting a fine spray of droplets. Mist sprayers are not permitted because of the risk of drift, even in light winds. The spray nozzle must not be raised more than one metre above the ground and must always be pointed downwards. There shall be no more than four sprayings of Glyphosate or Prometon per year in any one location. For obvious economic and environmental reasons, the Contractor should try to reduce the number of sprayings below this frequency. Glyphosate should only be sprayed on to the leaves of plants to be killed, and it is wasted if sprayed on to bare ground. On some plants the leaves take up to a month to turn brown. The Contractor should therefore wait at least a month before a second application if there is a suspicion of failure. Therefore spraying should not be undertaken if rain is expected within four hours; this would not only raise the risk of pollution, but would also render the spray ineffective and require another application. In general, herbicides need to dry on the foliage in order to be effective. Cleaning spray equipment Tanks must be emptied completely by spraying on to vegetation. They should then be completely filled with fresh water and emptied on to a gravel or bare soil area at least 100 metres from any water body. Spray pipes and nozzles should also be liberally rinsed with fresh water in a similar location. Gloves, boots and any splashed clothing should also be washed liberally, away from a water course. Monitoring The use of herbicide will be subject to regular monitoring by the Company‟s environmental team. Insecticides The use of insecticides must in all cases be undertaken either by the Health and Safety Department or under the H&S Department‟s direct supervision. Any member of the staff of ArcelorMittal Liberia or its contractors wishing to use any insecticide should contact the company‟s Health and Safety Manager for advice. Source: ArcelorMittal Liberia.




10.6 Standard for the Removal of Paint from Steel Bridges Introduction Paint shall be removed only from structural steel in areas in proximity to any hot work. This standard is to ensure that the removal of paint, which may be lead-based, is undertaken in a safe manner so as to prevent injury to personnel and damage to the environment. The risks of lead contamination depend on the extent of surface preparation, the scale of the work, and the paint removal method to be used. Three methods can be used, to suit the various local conditions:

PeelAway ST1 – Water based paint remover;

Sikkens Vervex Special – Universal Paint Remover; or

Electric “Blister” Hot Air Paint Stripping Guns. Personal protection Workers shall wear good-quality and properly fitted, respiratory protective equipment (RPE), safety glasses, disposable coveralls, safety boots, disposable rubber hand gloves and safety helmet. Respirator filters shall be replaced as required and all protective equipment shall be cleaned and stored properly before leaving the work area. Boots shall be cleaned at the site or left there, so that lead dust is not carried to the vehicle or home. Workers shall not be permitted to smoke, eat or drink in the work area, as hand to mouth contact may increase the risk of eating or inhaling lead paint dust. Site preparation and operation The following measures must be observed when the removal of paint is being performed.

Access to the areas of work will be from a safe ground position, or from scaffolding erected for the purpose.

At all times when working on scaffolds, safety harnesses are to be worn and the lanyard connected to a secure strong hold.

The area around the place of work is to be clear and heavy duty polythene sheeting is to be laid to catch and contain stripped paint debris. The area is to be regularly swept up and the paint debris collected in a bucket. Once there is sufficient paint debris collected, it is to be transferred to a heavy duty plastic bag and sealed. This bag is then to be placed in a second bag and stored securely until it can be disposed of as hazardous waste.

Work shall be undertaken in such a way as to minimise dust generation and the transfer of debris away from the immediate work area.

Accumulated debris shall be removed as often as is necessary to prevent it spreading from the immediate work area.

Procedures The most appropriate method of removal shall be selected, to suit the particular application. When using the hot air blister gun:

Be sure not to overheat the area being stripped;

Use only sufficient heat to “blister” the paint;

At this point using the scraper, with the heat gun directed at the blade, bring the blade downwards in smooth even strokes until all of the paint is removed;

Reheat the area and while the paint is soft, clean the area with a cloth damped with paint thinners to remove any residue of paint;

Finally scrub the area with a wire brush to remove any stubborn patches of paint.




When using Sikkens Vervex Special or PeelAwayST1:

Paint or spread the product on to the area to be stripped;

When the paint starts to blister, follow the same procedure as with the hot air blister gun above, until the area is clean.

After paint removal in the area being worked, and before moving to the next place of work, all debris must be swept up, bagged and stored, until it can be disposed of in a safe manner. Source: ArcelorMittal Liberia, adapted from procedures by Sandwell and Odebrecht.

10.7 Standard for the Disposal of Waste Containing Asbestos This standard shall apply until such time as the Environmental Protection Agency has formally issued Liberian National Standards to cover this matter. No asbestos may be used in any new equipment or building. Asbestos present in existing equipment or buildings may continue to be used provided that fibres remain fully bound or sealed and cannot become detached. Any opportunity should be taken for the safe removal and disposal of asbestos. This standard applies only to low-grade white asbestos waste, such as the disposal of old cement-asbestos roofing sheets from domestic buildings. If waste containing blue or brown asbestos is found or suspected (colour is not usually obvious), further detailed instructions should be sought from the Company. Blue or brown asbestos may be found in old machinery, including pre-civil war mining, railway, workshop and power generation equipment. Asbestos waste should only be moved when it is known to be a threat. In the case of roofing sheets, this is when it has been broken, or when modifications would require it to be cut or drilled. Danger signs are typically the broken corners or edges of sheets, with a ragged edge showing loose fibres. This is when the asbestos can come loose from the concrete bonding. Workers involved in asbestos waste removal must have the following minimum equipment: (a) complete overalls, with long sleeves and legs; (b) tightly fitting hoods to cover hair completely; (c) breathing masks; (d) eye goggles; (e) rubber gloves; and (f) rubber boots. There must be an adequate supply of water and soap for personal decontamination following completion of the job. The following steps shall be followed:

Once a site is identified as needing asbestos to be removed, it shall be dealt with as quickly as possible. People close to the problem area are to be warned immediately not to touch the affected parts.

Workers shall be required to put on all of the personal protective equipment listed above before entering the site.

Warning signs shall be erected and all people evacuated from the vicinity to locations where there is no danger of them inhaling dust from the site.

The workers shall then remove the affected materials, causing as little damage and fragmentation as possible. Cutting and breaking shall be avoided as far as it can be.

The asbestos-containing material shall then be wrapped in thick polythene sheet and sealed with heavy-duty sticky tape.

The package shall then be wrapped again in a second layer of thick polythene, and once more sealed with heavy-duty sticky tape.

All surfaces throughout the site shall then be cleaned completely to ensure the removal of asbestos fibres. All dust and debris shall be collected and double-wrapped as described above. Vacuum cleaners with new filters may be used for this work if it is feasible to do so, and the filters disposed with the waste. Brushes used should also be disposed with the waste. Sticky tape can be used to pick up small fibres from awkward corners.

If there is any doubt as to the complete removal of asbestos fibres from a surface, it should be painted with polyvinyl acetate (PVA) glue as a sealant.




Once the site is deemed to be clean and all waste material is securely packaged, workers must remove their clothing, disposing of any contaminated articles as for the waste described above. They must immediately wash themselves thoroughly. The double-wrapped waste material shall be buried immediately in a permanent landfill site. This shall be in a location approved by the Company. Disposal sites must be situated at least 400 metres from any dwelling and at least 400 metres from a water body or water course. They should not be on cultivated land. Wherever possible, they should be on a permeable but not sandy soil. Holes shall be a minimum of two metres deep when first excavated and all materials must be buried under at least one metre of soil. Source: ArcelorMittal Liberia.

10.8 Standard for the Use of Explosives in Quarries and Mines Legislative background The Minerals and Mining Act (2000) makes the following provisions, which must be complied with under all circumstances. “The conditions for the import, export, manufacture, storage, handling, purchase, sale and use of explosives shall be as strictly prescribed by the laws of Liberia.” [Section 16.11] “All Mine or Quarry operators shall apply to the Ministry of State for Presidential Affairs, or to such other agency of Government as required by the laws of Liberia, for permission to import, export, buy, sell, manufacture, store handle, purchase, use, dispose of or otherwise deal in or with explosives.” [Section 16.12] Meanings of terms In this standard, the following meanings shall apply. (a) “Operator” in relation to a site where blasting is taking place means the person in overall control of the working of the mine or quarry. (b) “Shot” means a single shot or a series of shots fired as part of one blast. (c) “Shotfirer” means a person appointed to be responsible for shotfiring operations. (d) “Shotfiring operations” include:

(i) checking to ensure that the blasting specification is still appropriate for the site conditions at the time the blasting is to take place; (ii) mixing explosives; (iii) priming a cartridge; (iv) charging and stemming a shothole; (v) linking or connecting a round of shots; (vi) withdrawal and sheltering of persons; (vii) inspecting and testing a shotfiring circuit; (viii) firing a shot; and (ix) checking for misfires.

Transport and storage of explosives Explosives shall be transported in escorted convoys, in accordance with all prevailing transport and safety rules.




Explosives shall be stored in locked shipping containers in a secure compound sealed from the rest of the mine or quarry site, and with permanent guards to ensure no unauthorised access. Separate containers shall be used for different components (detonators, fuses, charges etc.) and shall be placed at least 10 metres apart with earthen bunds in between. Clearance of the site and safety zone (a) The Company shall not permit any blasting to take place without a 500-metre safety zone cleared around the site. This zone shall be cleared of people, structures and all other infrastructure. (b) Warning notices shall be posted around the site, giving at least 24 hours warning of a blast. (c) The Operator shall notify the Company in good time to allow deployment of its Community Liaison staff at least one week before a blast or series of blasts, to prepare communities for the blasting and to notify them of the times of blast(s). The signalling system shall also be explained. (d) A siren shall be sounded 30 minutes, 10 minutes, 5 minutes and 1 minute before a blast takes place. The siren shall be loud enough to be heard clearly throughout the site and safety zone. This shall include persons operating machines or required to use ear protection. (e) Where farms occur within the 500-metre safety zone, patrols shall be sent out to ensure they are cleared of people in good time. The warning signal sequence for the blast shall not be started until the patrols have reported that the farms are clear to the best of their knowledge and that they themselves are in places of safety. (f) Where a footpath runs into the safety zone, guards shall be posted at least one hour before the blast to prevent people from entering the safety zone. (g) The site is to be cleared of personnel as soon as the first warning siren is sounded. Operator’s duties (a) The operator shall:

(i) ensure, so far as is reasonably practicable, that all explosives are stored, transported and used safely and securely; (ii) appoint one or more competent individuals to organise and supervise all work involving the use of explosives (“the Explosives Supervisor”); (iii) ensure that at no time is there more than one person acting as the Explosives Supervisor at the site; and (iv) keep a copy of the written statement of duties of the person or persons appointed under paragraph (a)(ii) for at least twelve months after the date on which the appointment ceased to have effect.

(b) It shall be the duty of the operator to ensure that:

(i) there are suitable and sufficient written rules and procedures for:

shotfiring operations;

appointing shotfirers and storekeepers;

authorising other persons who will be involved with the storage, transport or use of explosives;

dealing with misfires; and

ensuring, so far as is reasonably practicable, that such rules and procedures are complied with;

(ii) an adequate written specification (whether produced by or for the operator) is prepared for each shotfiring operation to ensure, so far as is reasonably practicable, that when such firing occurs it will not give rise to danger; and (iii) a copy of the specification referred to in sub-paragraph (b) is given to any person upon whom it imposes duties.




(c) The operator shall ensure that operations involving the storage, transport or use of explosives are carried out by

(i) a duly authorised and competent person; or (ii) a trainee under the close supervision of a duly authorised and competent person.

(d) The operator shall ensure that:

(i) such facilities and equipment as are necessary to enable shotfiring operations to be carried out safely are provided; (ii) any vehicle which is provided for use in relation to shotfiring operations is so marked as to be readily identifiable from a distance; (iii) detonators are stored in separate containers from other explosives; and (iv) explosives are kept at all times either in a locked explosives store or under the constant supervision of a suitable person.

(e) The operator shall ensure, so far as is reasonably practicable, that each shotfiring operation is carried out safely and in accordance with the rules required to be made in pursuance of paragraph (b)(i) and any specification required to be prepared in pursuance of paragraph (b)(ii). Supervision of shotfiring and records of appointment (a) The operator shall take all reasonable steps to ensure that:

(i) a trainee shotfirer does not fire shots and is not required to fire shots, except when he is under the close personal supervision of a shotfirer, until the operator is satisfied that he has completed a suitable period of training and has appropriate practical experience; and (ii) all shotfiring operations are carried out under the close personal supervision of the shotfirer.

(b) The operator shall ensure that a record of the appointment of any shotfirer or trainee shotfirer is kept at a suitable place until three years after that shotfirer‟s employment or trainee shotfirer‟s employment ends. Shotfirer’s duties Before a shot is fired, a shotfirer shall:

(i) check that the procedure has been followed for clearing the site and the 500-metre safety zone; (ii) check the shotfiring system or circuit to ensure that it has been connected correctly; (iii) where electrical detonators are used, ensure that they have been correctly connected to the shotfiring system or circuit and that the shotfiring system or circuit is tested with an instrument suitable for the purpose from a position of safety; (iv) where appropriate, ensure that the electrical integrity of the shotfiring system or circuit is such as to make a misfire unlikely; and (v) ensure that the shot is fired from a safe place.

Misfires In the event of a misfire the operator shall ensure, so far as is reasonably practicable, that:

(i) apart from himself, no person other than the Explosives Supervisor, shotfirer, trainee shotfirer or any other person authorised by him enters the danger area until a period of five minutes has elapsed since the misfire and any shotfiring apparatus has been disconnected from the shot; (ii) appropriate steps are taken to determine the cause of and to deal with the misfire; (iii) a suitable record is kept of the misfire for at least three years; and (iv) appropriate steps are taken to prevent theft of the explosives and detonators or their initiation by an unauthorised person.

Use of ANFO Where an ANFO (ammonium nitrate / fuel oil) mixture is used, special precautions shall be taken to ensure that there is no pollution. Both of the ingredients can be extremely damaging if they are




leached into water courses. For this reason, the following precautions shall be taken when ANFO is used as an explosive. (a) Ammonium nitrate shall be stored in sealed bags in a dry location. (b) Fuel oil shall be stored and transported as per the fuel standards (see section 11). (c) Mixing of ANFO shall be done in such a way that there is no spillage or contamination of the ground. Should any spillage occur, then the spilt material shall be cleaned immediately and all contaminated soil shall be removed for remediation as per standard 11.7. (d) The filling and blasting of holes shall be done in the same day to avoid the leaching of ANFO into the water table and polluting of groundwater. Prohibited activities (a) A person other than a person appointed by the Ministry of Lands, Mines and Energy as an Explosives Inspector, a person engaged in the transport of explosives to or from the work site, a shotfirer, a trainee shotfirer, a person authorised to handle explosives at a work site or a person appointed to be in charge of the explosives store shall not handle explosives. (b) A person shall not bring any substance or article (other than explosives) likely to cause an unintended explosion or fire within ten metres of any explosives or take any naked flame within ten metres of any explosives. (c) A person shall not forcibly remove any detonator lead or other system for initiating shots from a shothole after the shothole has been charged and primed. (d) A person shall not charge or fire a shot:

(i) unless there is sufficient visibility to ensure that work preparatory to shotfiring, the shotfiring operation and any site inspection after the shot is fired can be carried out safely; (ii) in a shothole which has previously been fired, unless he is dealing with a misfire in accordance with action taken in pursuance of standard 5; or (iii) in any tunnel or other excavation (not being merely a shothole) in the face or side of the mine of quarry wall for the purpose of extracting minerals or products of minerals.

(e) A person shall not fire a shot:

(i) unless he is a shotfirer or trainee shotfirer; and (ii) other than by means of a suitable exploder, and the purpose of these standards, a safety fuse shall not be deemed to be a suitable exploder.

(f) No person shall be in possession of a mobile telephone when:

(i) within 50 metres of a charged blast hole; (ii) inside an explosive storage compound; or (iii) on a vehicle transporting detonators.

Sources: Liberian law; ArcelorMittal; and adapted from UK Health and Safety Executive Guidelines.




11. FUEL HANDLING STANDARDS

11.1 Standard for Bunding Fuel Tanks All fuel tanks placed above ground or in floating vessels shall be fully bunded. This means that they will be provided with secondary containment in the event of a leak or rupture in the primary containment structure. The secondary containment shall have a capacity adequate to contain the entire contents of the tank. Bunding shall consist of a strong structure that is well founded and built without joints, around the entire tank. On land this might typically be a masonry wall of 150 mm minimum thickness around the tank being bunded; the ground inside the tank needs to be cleared of topsoil or other loose material, and given a thick concrete screed, and the bunded area must be lined throughout, floor and sides, with waterproof cement plaster or a similar coating to contain liquids. In vessels the bunding should typically consist of leak-proof steel sheeting or heavy-duty, impact-resistant polypropylene. Fuel tanks placed below ground shall have a secondary heavy duty impervious structure, lining or membrane separate from the primary structure of the tank. This secondary arrangement shall be capable of the indefinite retention of fuel leaking through the primary tank structure. A sampling pipe should be inserted at the time of construction, from the ground surface to the lowest sump point of the secondary containment, to allow sampling to check for fuel leaking out of the primary structure. The sampling pipe should be checked during regular inspections. Should there be evidence of fuel leaking out of the primary tank, then it should be emptied and replaced as soon as possible. Source: ArcelorMittal Liberia.

11.2 Standard for Dispensing Fuel at Site Camps This standard shall apply only to the dispensing of diesel fuel at site camps. Permanent establishments shall have a higher standard of protection. An area shall first be designated that is as far as possible from living and eating areas. It shall also be as far as possible from water courses and swamps. The surface of the area for dispensing fuel shall be graded so that it has a very gentle slope (2 to 3 degrees). A thick polythene sheet shall be laid over an area of approximately 50 square metres. The sheet shall then be covered with sand or gravel to a depth of 80 to 100 mm. Vehicles and machines shall be parked with their tanks over this area when being filled. A self-closing nozzle shall be fitted on the fuel pump. The pump nozzle shall be placed on a portable spill containment tray when not in use (if it does not hook back up to the pump). If jerricans are being filled, they shall be placed on the spill tray. If the sand or gravel becomes badly contaminated through spillages, and when the site is restored, it shall be removed and buried in an appropriate landfill site (see separate standard). If fuel is to be dispensed from a mobile tanker, a portable spill tray shall be placed below the pump and the tank of each vehicle or machine being filled. Any spillages shall be collected from spill containment trays in a suitable container for filtration and re-use. Contractors are encouraged to consider using a semi-rigid containment tray and a fuel-water separator as an alternative to the simple procedures given in this standard. Source: ArcelorMittal Liberia.




11.3 Standard for Pollution Prevention from Above Ground Oil Storage Tanks In this Standard, the word oil means liquid hydrocarbons that float on water such as diesel, petrol and engine oil. The storage container Location. Safety, security, access and maintenance needs must be considered when storing oil. Position tanks or take other steps to minimise the risk of damage by impact. Ensure that, in the area where deliveries are made and oil is dispensed, the surface is impermeable to the oil stored and isolated from surface water drainage systems. This will reduce the risk of spilt oils causing pollution by preventing the downward passage of fuel or contaminated water into the soil and groundwater below the site, by directing any spilt liquids away from surface waters. Tank specification. Storage tanks should be type tested to a recognised standard and manufactured to that standard under a quality assurance system complying with BS EN ISO 9001:2000. Ensure that steel tanks comply with BS 799-5:1987 and are protected against corrosion. Use drain valves to prevent frost damage. There is no British Standard for prefabricated steel tank systems. However, the Oil Firing Technical Association (OFTEC) has developed a standard for steel tanks, OFS T200, which does include them. Ensure that polyethylene tanks and tank systems comply with OFS T100. Tank decommissioning. Ensure that a tank is fully drained before it is taken out of use or removed. Suitably qualified technicians should undertake this work. Never carry out hot work until the tank has been degassed and the appropriate certificate issued. After decommissioning or removal, check the area to ensure the procedure has not caused soil or groundwater contamination (this includes taking soil and groundwater samples). If contamination is found, take action as soon as possible to remove the pollution. Secondary containment Secondary containment will prevent oil escaping to the environment in the event of leakage from the tank or ancillary equipment. Situate all tanks and their ancillary equipment within an oil tight secondary containment system such as a bund. It is necessary to consider the potential escape of oil beyond the bund area in the event of the tank developing a hole (known as jetting). The risk of this can be minimised by:

keeping the primary container as low as possible;

increasing the height of the bund wall;

leaving sufficient space between the tank and bund walls;

not siting one tank above another;

providing screens or curtains. For steel tanks in open bunds, a minimum distance of 750 mm between the tank and the bund wall and 600 mm between the tank and the base is recommended to allow access for external inspection. General integrity. The secondary containment system should be impermeable to oil and water, and there should be no direct outlet such as:

connecting the bund to any drain, sewer or watercourse;

discharging onto a yard or unmade ground. Ideally, pipe-work should not pass through the bund wall. If unavoidable, seal the pipe into the bund with a material that is resistant to attack by the oil stored to ensure the bund remains leak-proof. The use of un-reinforced materials is not recommended for bund wall construction. Detailed specifications and drawings are available for bunds of reinforced construction using concrete, bricks and blocks. Make sure that any valves, filters, sight gauges, vent pipes or other ancillary equipment are situated within the secondary containment system and arranged so that any discharges of oil are contained




Capacity. The secondary containment system must provide storage of at least 150% of the tank‟s maximum capacity (or 110% for single tanks where the entire containment area is roofed). If more than one container is stored, the system must be capable of storing 150% of the biggest container‟s capacity or 50% of the total tank capacity within the bund, whichever is the greater. When calculating bund capacity, take account of any volume taken up by tank supports within the bund and consider the volume of any of the primary tank, pipe-work or pumps. The 50% margin is intended to take into account a range of factors, including:

loss of the total contents, for example due to vandalism or an accident;

sudden tank failure or leaks;

overfilling;

containment of fire-fighting agents;

dynamic factors such as overtopping caused by surge and wave action following tank failure;

an allowance for rainwater in the bund. In Europe it is normal to use a figure of 110% capacity, but research by the UK Construction Industry Research and Information Association (CIRIA) involving tanks of 25 m

3 or less suggests that, in some

circumstances, the 10% safety margin is inadequate to provide protection from loss of oil due to these factors. Based on this, ArcelorMittal Liberia has set a standard of 150% mainly by taking into account typical rainfall volumes for the area. Deliveries Remote fill points are not recommended, but where they are unavoidable, they should comply with BS 799-5:1987, OFS T200 or OFS T100 as appropriate. Fit an automatic overfill prevention device if the tank and any vent pipe cannot be seen by the person controlling the delivery. Surface drainage from the delivery area should pass through a suitably sized oil separator of an approved design (reference PPG3). General maintenance Inspect all bunds, tanks and pipe-work regularly for signs of damage and check them at least weekly. To ensure the bund retains its integrity, repair any defects in the bund wall or lining promptly using an appropriate technique. Deal with damage to the tank or pipe-work immediately. Draw off any condensation water that accumulates within the tank regularly and dispose of it through a filter drain. Although rainwater will often evaporate from within an open bund, a collection sump should be included in the base. If there is no rainwater in the bund after heavy rainfall, the bund may not be sealed properly and should be inspected and repaired as appropriate. If it is necessary to remove accumulated rainwater, perform this with a manually operated pump or by baling from the sump. This water may be contaminated and should be disposed of through a filter drain. In the long term, it may be more cost-effective to roof the facility. Dealing with spills Those storing and using oils are advised to consider the risks of a spillage and to prepare a contingency plan. Keep a stock of absorbent materials (e.g. sand, earth or commercial products) on site to deal with spillages and train staff in their use. If a spill should occur, immediate action should be taken to contain the oil to prevent it entering any drains or watercourses. Do not hose the spillage down or use any detergents. Checklist for oil storage tanks Completing this checklist will help you decide whether you need to improve your oil storage facilities in order to comply with this Standard.




General requirements or x Comments

Is the tank “fit for purpose” and in good condition (unlikely to leak or burst in ordinary use)?

Is the tank situated more than 50 m from a watercourse, well or borehole?

Is the tank situated within a secondary containment system?

Are the tank and containment system located or protected so that they cannot be damaged by an impact or a collision?

Is the secondary containment storage capacity at least 150% of the primary tank?

See calculation table below this checklist.

For two or more tanks in one secondary containment system, is the secondary containment at least 150% of the biggest tank‟s maximum storage capacity or 25% of the total maximum storage capacity of all the tanks, whichever is the greatest?

Secondary containment: integrity

Is the secondary containment impermeable to water and oil?

Is the containment system intact and without openings or valves for drainage?

Ensure any cracks or other damage are carefully repaired.

Are any draw-off pipes and fill pipes that pass through the containment system sealed adequately?

Tank ancillary equipment

Are all valves, filters, sight gauges, vent pipes and taps within the secondary containment system?

If the tank has a sight gauge, is it supported properly and fitted with a valve that closes automatically when the gauge is not in use?

Are fill and draw-off pipes located or protected so that they cannot be damaged by an impact or a collision?

Are they protected from corrosion?

If above ground, are they supported properly?

Are vent pipes, taps and valves arranged so that any oil lost will be retained within the containment system?

Are all taps and valves fixed to the storage tank, through which oil can be discharged to the open, fitted with locks and locked shut when not in use?

Can the tank and vent be seen from the point where the filling operation is controlled? If not, is the tank fitted with an automatic overfill prevention device?

Deliveries to the tank (filling)

Is the fill pipe situated within the secondary containment system?

Ensure the drip tray is part of the containment system.

If the tank has a screw fitting or other fixed coupling, is it in good condition?

Are fittings or couplings being used when the tank is filled?

You may need to discuss this with your oil supplier.

Underground pipes (for filling and/or draw-off)

Are underground pipes for filling or draw-off protected from physical damage?

Are all mechanical joints situated at a place




General requirements or x Comments

accessible for inspection, such as under a hatch or cover?

Are there adequate facilities for detecting leaks?

If permanent leak detection is provided, is it maintained in working order and tested at appropriate intervals?

If permanent leak detection is not provided, have the pipes been tested before use?

Is pipework with mechanical joints tested every five years?

Is all other pipework tested at least every ten years?

Flexible draw off pipes

Is the flexible draw-off pipe fitted with a tap or valve that closes automatically when not in use?

Is the pipe kept within the secondary containment system when not in use or enclosed in a secure cabinet equipped with a drip tray?

Is there a lockable valve where the pipe leaves the container which is locked shut when not in use?

Pump set draw-off (non-gravity draw off)

Is the pump set fitted with a non-return valve in the feed line to the pump?

Is the pump set protected from unauthorised use (locked or isolated when not in use)?

Is the pump set located or protected so that it cannot be damaged by an impact or a collision?

Calculation of capacity for existing secondary containment systems The capacity of a tank located within an open containment system can be calculated by making the measurements shown in the table below. If the tank supports take up significant space, the calculation must take this into account. Where the tank is enclosed within a proprietary system, you will have to refer to the manufacturer for this information.




Calculation Result

Maximum capacity of primary tank(s) A If unknown, use tank length x width x depth in metres and multiply by 1000 to convert to litres.

.................................... litres

A

Containment capacity = length x width x depth of secondary container in metres

.................................... m

3

Then multiply by 1000 to convert to litres .................................... litres

B

Volume lost due to tank supports (if significant) in cubic metres .................................... m

3

Then multiply by 1000 to convert to litres .................................... litres

C

Actual containment capacity = B – C (C = 0 if tank supports do not occupy a significant volume.)

.................................... litres

D

Minimum containment capacity (150%) = (150/100) x A

.................................... litres

E

If D is equal or greater than E, then the containment system volume is adequate and will comply with the Standard. If D is less than E, then the containment system capacity is insufficient and will not comply with the Standard. Note that for installations where the tank takes up a significant part of the bund, the capacity available in the event of overfilling may be inadequate. This will require consideration of delivery procedures and alarm systems if the risk is to be managed Source: adapted from UK Environment Agency Guidelines.

11.4 Standard for Oil Separators in Surface Water Drainage Systems Introduction This Standard is designed to assist in deciding whether an oil separator is required and, if so, what size and type of separator is appropriate. In this Standard, the word oil means liquid hydrocarbons that float on water such as diesel, petrol and engine oil. Oil separators can be fitted to surface water drainage systems to protect the environment from pollution by oils. They separate the oil from the water, and then retain the oil safely until it is removed. They are installed to contain oil leaks from vehicles and plant, and accidental spillages. To be effective, oil separators need to be correctly designed, installed and maintained. Surface water may be contaminated by oil at a number of different sites. These sites need to have measures in place to prevent this oil from polluting the environment. These sites include:

car parks and areas where goods vehicles are parked or manoeuvred;

vehicle maintenance areas;

industrial sites where oil is stored or used;

refuelling facilities;

any other site with a risk of oil contamination. Trapped gully pots can provide adequate protection for car parks that are too small to justify the installation of a separator, but they must be properly maintained. If you do need an oil separator, you will need to consider where it will discharge. If you install a separator discharging to surface water you will need a Class 1 separator.




Drainage from areas such as scrap yards, storage and handling areas for chemicals (solvents, acids etc), and washing bays are likely to be contaminated with substances other than oil, and should normally drain to the foul sewer with the approval of the sewer provider. Discharge from such areas is not suitable for drainage to surface water drains, a watercourse or to the ground. Drainage containing detergents should not pass to a separator that discharges to surface water because the detergents prevent the separator from working properly. Choosing the right separator More than one separator might be required on larger sites or a site with many activities. You will need to consider the local circumstances and risk factors including:

the discharge point of your proposed separator;

the environmental sensitivity of your location;

activities on your site. There is a two-part European Standard (BS EN 858-1:2002 and BS EN 858-2:2003 as used in UK) for the design, use, selection, installation, operation and maintenance of prefabricated oil separators. BS EN 858 refers to two „classes‟ of separator, based on performance under standard test conditions. Class 1 separators are designed to achieve a discharge concentration of less than 5 mg/litre of oil under standard test conditions. These separators are required for discharges to surface water drains and the water environment. Many Class 1 separators contain coalescing devices, which draw the oil droplets together and facilitate the separation. Class 2 separators are designed to achieve a discharge concentration of less than 100 mg/litre of oil under standard test conditions. They are suitable for dealing with discharges where a lower quality requirement applies such as discharges to the foul sewer (check first with your sewer provider). Both classes can be produced as „full retention‟, „bypass‟ or „forecourt‟ separators (see below). The oil concentration limits of 5 mg/litre and 100 mg/litre only apply under standard test conditions. It should not be expected that separators will always perform within these limits under field conditions. In addition, these levels of oil might be too high in some environmentally sensitive areas to allow the discharge to pass into the water environment without additional treatment. Full retention separators. These treat the full flow that can be delivered by the drainage system. The „full flow‟ is normally equivalent to the flow generated by a rainfall intensity of 65 mm/hour. Full retention separators are used where there is a risk of regular contamination with oil and a foreseeable risk of significant spillages, such as vehicle maintenance areas and retail fuel forecourts. Bypass separators. This type treats all flows fully generated by rainfall rates of up to 65 mm/hour. This covers most rainfall events. Flows above this rate are allowed to bypass the separator. These separators are used when it is considered an acceptable risk not to provide full treatment for high flows, such as where only small spillages can occur and the risk of spillage is small. In cases where a large spillage might occur, it is not acceptable to use a bypass separator. Forecourt separators. These are appropriate for all forms of liquid-fuel dispensing outlets, including those where only diesel is dispensed. A forecourt separator must be a „full retention‟ separator, large enough to serve the catchment area of the site and have a sufficient oil storage volume to retain any foreseeable spillages. Separator size Separators are tested in accordance with the standard test procedure in the European Standard. Each separator is allocated a nominal size (NS) on the basis of the test results. Full retention and bypass separators are referred to as NS and NSB, respectively.




The nominal size of a full retention separator that is required for a catchment area (A) is obtained using the following formula: NS = 0.018 x A (in m

2).

For a bypass separator, the formula is: NSB = 0.0018 x A (in m

2).

Oil storage capacity The oil storage capacity is defined as the volume of separated oil that can be stored in the separator without any of the stored oil entering the inlet or outlet of the separator. The oil storage volume (V) is given by the following: V (in litres) = NS x 10 or V (in litres) = NSB x 15. On sites where significant oil spillages are foreseeable, make sure the oil storage capacity is sufficient to retain any such spillage and select a separator of adequate size. Maintenance and use To prevent pollution and minimise costs, you need to manage your separator effectively. To make this easy, all parts of the separator that have to be regularly maintained must be accessible at all times. Every six months, or in accordance with manufacturer‟s instructions, experienced personnel should:

Physically inspect the integrity of the separator and all mechanical parts;

Assess the depth of accumulated oil and silt;

Service all electrical equipment such as alarms and separator management systems;

Check the condition of any coalescing device and replace it if necessary;

Some heavily used or high-risk sites might require more frequent inspections. All sites should empty their separator as soon as a significant quantity of oil or silt has built up. The retained waste, including the silt, must be removed and the separator must be refilled with clean water before being put back into service to prevent damage and to prevent oil passing through it. In addition to normal emptying of the separator, it will also need to be emptied right away if oil or silt levels exceed 90 per cent of the storage volume of the separator and the alarm is activated. When the oil or silt reaches this level or after a spillage, employ a registered waste removal company to empty the separator. For all waste removal operations you must make sure that the waste removal company has experience in emptying separators and that they do not allow any of the contents to escape from the outlet during emptying. Every five years it is recommended that separators be emptied and given a general inspection to test the integrity and performance of the system. The separator must be refilled with clean water following such an inspection. Simple oil separator design Where the optimal size of an oil separator cannot be determined, then the simple design shown on the next page should be used. This can be achieved using in situ cast concrete. Temporary oil filter design For temporary servicing or fuelling sites that are to be used for less than 6 months, and where the installation of an oil separator would not be appropriate, a simple filter design can be used. The sketches on the next page show a recommended design for a sand filter to trap residual fuel in water discharged from such locations. The intention is to have a simple but effective way of cleaning the residual contamination from bund drainage water by filtering it through a bed of sand. The sand should be changed when it has become polluted, and treated with bioremediation agent to remove the diesel contamination. Source: adapted from UK Environment Agency Guidelines and ArcelorMittal Liberia.




Simple oil separator (elevation)

350

1250

250

Inlet pipe

1250

Outlet pipe

3560

750 750 7501250

Oil

retainer

baffle

Sludge

retainer

baffle

Flow

diffuser

baffle

Cover slabs (removable)

Other dimensions

Main tank floor and sides: 150 thick

Cover slabs: 150 thick

Baffles: 100 thick

Overall internal width: 2000

Overall external width: 2030

Inlet and outlet pipes: normally 100 diameter

All dimensions in millimetres

1530

1250

250

Simple sand filter (plan and elevation)

A A‟

Trough filled with sand 1000 mm min.

2500 mm min.

Pipe and valve from tank bund (inlet to filter)

Concrete wall 100 to 150 mm thick

Pipe and rock erosion protection (outlet from filter)

Plan view

Cross-section A-A’

Pipe and valve from tank bund (inlet to filter)

Pipe and rock erosion protection (outlet from filter)

Trough filled with sand 1000 mm min.

Ground level varies Filter to stop sand from washing out




11.5 Standard for Preventing Pollution from Refuelling Facilities Introduction Oil is the most common water pollutant, with the potential to harm watercourses and groundwater. In addition, certain fuels, such as petrol, are highly flammable and are tightly regulated for safety reasons. The guidance in this Standard is applicable to all refuelling facilities and should be consulted regardless of the type of facility. Types of drainage system Clean water. All clean, uncontaminated rainwater should be channelled to:

a surface water drainage system;

a combined drainage system downstream of the oil separator;

directly to a local watercourse or soak-away. This includes roof water and uncontaminated drainage from those areas of the site where vehicles are not stored, repaired, refuelled or washed. Such discharges may require prior permission from the EPA or the local sewer provider. Contaminated water. The entire area where fuel is delivered, stored and dispensed should be isolated from the surface water drainage system, open ground or other porous surfaces. This can be achieved using drainage grids, gullies or kerbs in conjunction with surfaces impermeable to the products used. Potentially contaminated water and spills should be directed through an oil separator (see Standard 11.4) and prevented from seeping into the soil and groundwater below the site. The separator should be of an adequate size to serve the surface area catchment of the site. Sustainable drainage systems. The use of sustainable drainage systems (SUDS) should be considered. SUDS such as constructed wetlands or reed beds may offer an environmentally sound alternative to traditional methods of treating drainage effluent. Wetland or equivalent technology can be used for a variety of wastewater treatment purposes at refuelling facilities. It may also be suitable as a replacement for on-site separators for oily water run-off, provided the system is compatible with local groundwater conditions. Wetlands systems can offer an acceptable level of environmental protection provided they are properly designed, installed and maintained. In some situations, they may provide better environmental protection than conventional drainage systems. Washing activities. All washing and cleaning operations, including the washing of all vehicles or plant, should be carried out in a designated area clearly marked on the ground and in any plans. The cleaning area should be isolated from both the surface water drainage system and unmade ground or porous surfaces (e.g. using drainage grids, gullies or kerbs). Wash water should be re-circulated whenever possible. Otherwise it should drain to, or be disposed of, via the foul sewer (where available). Cleaning agents such as detergents (including biodegradable ones) should never be allowed to enter the surface water system or to soak into groundwater unless specifically permitted after appropriate treatment. They should not enter oil separators because they reduce their effectiveness (the oil will be dispersed and washed through). Training in dealing with emergencies. Staff should be trained to deal with an environmental incident. Set up a system of written training records and make these available for inspection. Training should include a background to environmental sensitivities around the site and a formal emergency procedure that details actions to be taken in the event of:

a spillage;

a fire;

a collision with equipment;

odours being detected off-site;

a suspected leak being identified.




Make this procedure available on-site in case an emergency arises. Waste management. To avoid pollution, all waste (including separator waste and oil spill adsorbent materials) must be handled, stored and disposed of correctly. Waste producers and holders must ensure that waste:

does not escape from their control;

is passed only to a registered waste carrier for recycling or disposal at a suitably licensed facility;

is accompanied by a transfer note with a full written description of the waste. Fuel tank bund rain water discharge procedure Diesel fuel is a hazardous substance which can cause extensive pollution to soil and water. Fuel tanks must be bunded to ensure that if a tank leaks, the fuel does not escape into the environment. However, if the bunded area is not roofed, rain water will accumulate in the bund. This needs to be drained out under controlled conditions. The supervisor is responsible for ensuring that no leaked fuel within the bund is allowed to get out of the bund. Should there be an accidental spill or leakage, then the supervisor is responsible for ensuring that it is cleaned up immediately and the matter reported to his manager. In any event, the fuel must be cleaned before any water is drained from the bund. The following procedure shall be followed.

1. The supervisor shall be present throughout the process of draining the bund.

2. The valve on the bund outlet must be kept closed at all times except when it is being drained.

3. At a designated time on each working day, the supervisor must inspect the bund and assess: (a) whether there has been any spillage or leakage of water from any tank; and (b) whether any rain water has accumulated and needs to be drained off.

4. If any fuel has leaked, then the cause of the leak must be investigated immediately and the leak stopped if possible. This might be done using a tank repair compound such as “Plug Pattie”, which is contained in the re-fuelling station‟s fuel and oil spill kit. After this it must be reported to the manager. The leaked fuel must then be mopped up using appropriate pads from the spill kit. Once used, these must be placed in the polythene bags provided in the spill kit and disposed of correctly.

5. If there is water in the bund that appears uncontaminated with fuel, it may be drained off. This is done by opening the valve at the outlet, and allowing the water to flow out through the filter or water-oil separator. The supervisor must watch this process carefully, and must ensure that the flow from the valve is adjusted so that it does not flood the filter. Normally the filter will not cope with the full flow from a valve opened completely.

6. Once the bund has been drained, the valve must be screwed shut again.

7. All other staff, including security guards, are to be instructed that it is forbidden for them to drain water from the bund except when the supervisor is present.

Re-fuelling spill prevention procedure Diesel fuel is a hazardous substance which can cause extensive pollution to soil and water. It is also a valuable company asset. The supervisor is responsible for ensuring that no fuel is spilt. Should there be an accidental spill, then the supervisor is responsible for ensuring that it is cleaned up immediately and the matter reported to his manager.




Only a trained pump operator may use a fuel pump. Drivers are not permitted to do this. The following procedure shall be followed.

1. The hard standing in front of the fuel pump must be kept clean at all times. It must be swept at least once per working day.

2. Vehicles must be positioned on the hard standing, with the fuel filling location between 1 and 2 metres from the pump.

3. The fuel filler cap must be removed from the vehicle before the hose is taken from the pump.

4. When moving the hose from the pump, the nozzle must be kept upright at all times.

5. The nozzle is to be inserted carefully into the vehicle filler pipe, and pushed in as far as it will go.

6. Only when the nozzle is fully inserted may the pump be started.

7. While filling the vehicle, the pump operator must watch the nozzle and reduce the pump speed if there is any splashing from the filler pipe.

8. If the nozzle does not have an automatic shut-off valve, the filling must be done slowly and the filler pipe watched carefully to ensure that the pump is stopped well before the tank overflows.

9. Once filling is complete, the pump must be switched off before the nozzle is moved.

10. The nozzle must be removed slowly and carefully, and held in an upright position as it is moved back to its cradle on the pump. The hose must then be stowed neatly beside the pump.

11. The filler cap is then to be replaced on the vehicle, and screwed down firmly.

12. If any fuel has been spilt, it must be mopped up immediately using appropriate pads from the re-fuelling station‟s fuel and oil spill kit. Once used, these must be placed in the polythene bags provided in the spill kit and disposed of correctly.

Source: adapted from UK Environment Agency Guidelines.

11.6 Standard for Pollution Prevention in Vehicle and Plant Workshops Introduction Workshops and service centres carry out a number of operations and processes that have the potential to damage the environment. These include the cleaning of vehicles, the storage, use and disposal of polluting liquids such as oils, paints, solvents, coolant additives, brake fluids and solid waste such as oil filters, exhaust systems, batteries and tyres. Unless the site drainage is correct, waste is properly managed and spillage control procedures are in place, environmental harm could occur. Vehicle and plant maintenance areas Internal gullies or grids must not drain to the surface water system. If the workshop pit is subject to water infiltration, and is served by a gully and pump, then this should be directed to the foul sewer. Areas where maintenance or dismantling activities are carried out must have an impermeable surface and a raised edge with drainage to a sealed sump or via an oil separator to the foul sewer.




Disposal of waste liquids. Used liquids, such as lubricating oil, hydraulic fluid, coolant and solvents from degreasing activities, must not be disposed of into surface water systems. They should be collected in a suitably bunded tank. This oil can be taken for use in the furnaces of rubber factories until such time as Liberia has recycling facilities. Batteries. Batteries containing acid should be stored intact and upright in an acid resistant bunded compound or purpose built bin. Both the lead and the plastic cases can be recycled, so they should be collected for sale to an authorised contractor. Storage can be minimised by the use of one-for-one exchange schemes, whereby old batteries are collected when new ones are delivered. Tyres and other discarded dry parts. Tyres must never be burnt on site. They can be treated as a dry material for storage, but if burnt, release compounds that are extremely polluting. Tyres should be disposed of by a suitably licensed tyre incinerating or recycling company. Oil filters and other oil contaminated components. There are certified contractors for used oil filters, and so these should be stored. Alternatively, discarded oil filters can be crushed on site and the oil and metal recovered. Intact or crushed filters and other oil contaminated parts such as engines, gearboxes and axles should be stored either in a sealed container or within an impermeable bunded area, preferably roofed to prevent the entry of rain. Other wastes. Skips should have a designated use and be clearly marked to indicate what materials they may be used for. Material stored in skips should be drained or dry and the skips covered to prevent the entry of rainwater and kept watertight to prevent leakage. If any contaminated liquid does accumulate, it should be removed and suitably disposed of. Note that scrap metal is a potential asset and Company disposal rules apply. Oil, fuel and chemical storage Above ground storage tanks. These are covered by a separate Standard. All oil storage tanks and drums, including waste oil, should be sited on an impermeable base within an oil-tight bund wall. Any fill and draw pipes, valves and sight gauges should be enclosed within its curtilage and tank vent pipes should be directed downwards into the bund, so that in the event of overfilling the discharge is contained. Bunds should be examined on a regular basis and any rainfall that accumulates removed by bailing or by pumping under a manually controlled system. This water may be contaminated and should be disposed of with care. Internal storage tanks should also be bunded as above and, if served by a remote fill point, the drainage from the area should pass through a suitably sized oil separator. A high level alarm, which provides an additional safeguard against overfilling, is recommended for all storage tanks. Underground storage tanks. Underground tanks and pipelines are susceptible to damage and corrosion, and above ground facilities are preferred. In areas of high groundwater vulnerability, the EPA may object to the installation of underground storage tanks. Where underground storage is necessary, a number of protective measures, such as double skinned tanks and piping, and leak detection, may be required. Regular inspection, stock reconciliation and pressure testing are essential, especially where groundwater pollution could occur. The location of underground piping should be identified and clearly marked in order to avoid damage through excessive surface loading. Chemical storage. Chemicals such as detergents, degreasers, solvents and hydraulic fluids should be securely stored with storage vessels labelled to show their contents and should be kept as close to the point of use and as far from surface water drains as possible. Refuelling facilities. These are covered by a separate Standard. The risk of pollution from refuelling areas is especially high. Such areas should be isolated from general yard drainage, (for example by using a raised kerb or roll-over bund). Particular care should be taken in the cleaning of such areas.




Degreasing and cleaning The cleaning and degreasing of vehicles and components must be carried out in a designated wash-bay and not on unmade ground or in areas which discharge to surface water drains, watercourses or soak-away. A wash water recycling system will reduce water use and associated costs. The wash-bay should be impermeable and isolated from the surrounding area by a raised kerb or roll-over bund, with the effluent directed to foul sewer. Particular care should be taken when using hydrocarbons such as paraffin and white spirit as degreasers, as these substances are toxic to river life. In no circumstances should these substances be discharged to surface water drains. Source: adapted from UK Environment Agency Guidelines.

11.7 Standard for the Remediation of Oil-contaminated Soil Purpose Any soil contaminated by diesel fuel, waste oil or any other type of hydrocarbon shall be treated to bring it back into a healthy condition. The treatment process to be used will normally be bioremediation. Soils treated by this process should contain only hydrocarbon contamination and not contain mixtures of any other contaminants. Bioremediation is a process where naturally-occurring soil bacteria use the hydrocarbon contamination present in the soil as a source of food. It is normally done by adding a proprietary mixture of bacteria, that is then aided by applications of a nutrient solution. Careful watering and tilling of the soil are also necessary to ensure that the process is successful. The operation is to be undertaken with the assistance of the company‟s environmental staff, and should not be attempted without their guidance. Specifications for bioremediation agent Bioremediation is a process where naturally-occurring soil bacteria use the hydrocarbon contamination present in the soil as a source of food. It is normally done by adding a proprietary mixture of bacteria to contaminated soil to bring it back into a healthy condition. Bioremediation agent is to be a powder-based bacterial additive to accelerate the degradation of petroleum hydrocarbons in soil and non-soil media (but not in water). It must be able to accommodate and degrade gasoline, diesel, kerosene, lubricant oils, benzene, toluene, xylene and other hydrocarbons. It must be designed for use in sites such as earth roads, road shoulders and embankments, agricultural land, forest land, beach sites, compacted earth vehicle standing areas, factory sites, railway tracks, sidings and embankments, and high spill areas such as garage forecourts and fuel storage depots. It must be designed to work in either very high clay content or very sandy soils. It must tolerate waterlogging and soil temperatures of up to 50 degrees centigrade. Bioremediation agent is to be supplied in robust plastic tubs that are airtight and watertight. It is to have an active shelf life (unopened) of at least 3 years. If the bioremediation agent normally requires more than one application to completely decontaminate soil, the supplier must give details of this as part of the offer. If the bioremediation agent requires a nutrient additive to be effective, the supplier must give details as part of the offer. The manufacturer‟s recommended treatment procedures are to be supplied with the bioremediation agent, along with a list of ingredients and the material safety data sheet (MSDS).




Quantities: sufficient bioremediation agent should be supplied to treat completely 100 cubic metres of contaminated soil in a humid tropical environment. Preparation For small volumes of contaminated soil, select a location where it can be stockpiled and secured. Prior to excavating the contaminated soil, the ground surface where it will be placed shall be lined with heavy duty plastic, such as 8 mil polyethylene. Excavate the contaminated soil and place it on the plastic. The purpose of the plastic is to prevent any contamination of the soil from leaching downwards into unpolluted soil below. As a safety precaution, it is good to place 150 to 300 mm of sand on top of the plastic: this layer will serve as a warning layer when the soil must later be tilled, and will also aid aeration and biological activity. For large areas of contamination, isolate the affected soil by creating a bund around the affected area, and excavating a trench around the outside of the bund. The bund will control runoff and erosion, and the trench will prevent the contamination from leaching outwards and affecting a greater area. Method with a proprietary bioremediation agent This is a generic methodology, which may need to be altered according to the detailed instructions of specific bioremediation products. Introduce the bioremediation agent to the soil in the quantities specified by the manufacturer. This may require a calculation of the volume of contaminated soil: if necessary, use an extendable soil auger to judge how deep the pollution has penetrated. Till the soil after application, to ensure good mixing of the agent. Spray the soil with water to moisten it, as for a garden, but ensure that the soil does not become totally waterlogged. Ensure that any run off water stays within the bunded area, to limit dispersal of oil and active bacteria. Cover the soil with plastic and secure the edges to prevent erosion and run off. If possible, it is best to surround the treated soil mound completely, to prevent both water runoff and soil loss. Covering and securing the plastic will also serve to reduce air emissions from evaporation of contaminants, and the plastic will not tear as easily or blow off the pile. Every week, the treated soil shall be checked by removing the covering sheet of plastic. It shall then be treated by spraying on a dilute solution of the nutrient additive that is recommended to be used with the chosen bioremediation agent. After each application, the soil should be tilled again to introduce fresh oxygen and ensure good mixing, and sprayed with more water if needed to keep it moist. The top sheet of plastic must always be replaced as described above. The process for monitoring treatment progress is given below. In the tropical heat of Liberia, the process should be complete in two to three months. Method without a bioremediation agent If no bioremediation agent is available, natural soil bacteria can be encouraged. This is a much slower process than using proprietary bacterial bioremediation additives, and may take up to a year. Apply an ordinary agricultural fertiliser that is high in nitrogen and phosphorous (such as 10-10-10 fertiliser) evenly over the top surface of the soil pile at the rate of about 25 kg per 100 square metres of surface area. The purpose of this step is to add nitrogen and phosphorus to encourage the growth of bacteria already in the soil. These bacteria will use the hydrocarbon contaminants as food, resulting in the destruction of the hydrocarbons and the formation of water, carbon dioxide and additional biomass. After the hydrocarbons are consumed, the numbers of bacteria decline to pre-existing levels. Carefully till the soil pile with suitable tools. Special care should be taken to prevent tearing or ripping through the bottom plastic layer. If sand was first placed on the plastic beneath the contaminated soil,




you will be warned before you till through the plastic. Be sure to break up all large pieces of soil in order to aerate the soil (to provide oxygen) and thoroughly mix the fertiliser. Moisten the soil pile by spraying water as for a garden. Take care that the soil is not saturated or flooded by the spraying, because run off may occur. Cover the soil with plastic and secure the edges to prevent erosion and run off. If possible, it is best to surround the treated soil mound completely, to prevent both water runoff and soil loss. Covering and securing the plastic will also serve to reduce air emissions from evaporation of contaminants, and the plastic will not tear as easily or blow off the pile. Every two weeks, the soil shall be checked by removing the covering sheet of plastic, cultivating the soil to introduce fresh oxygen, and spraying it with more water if needed. The top sheet of plastic must always be replaced as described above. Monitoring of progress shall be as described below. Fresh applications of fertiliser should be considered if there is no measurable progress after four months, or if the amelioration slows down. The application of animal manure or treated sewage may also assist in the activation of soil bacteria. Monitoring The company‟s Environmental Department has the capability of conducting tests of hydrocarbon contamination in soil. Samples from the contaminated soil should be tested monthly during the bioremediation process to monitor the degradation of the contaminants. This will also allow the completion of the process to be determined, when the soil reaches an acceptable environmental level. Post-treatment Once the soil remediation is complete, all plastic shall be taken away, and the bund and trenches removed. If the soil had been excavated and moved from the area of actual pollution, it should now be replaced there. The soil shall then be cultivated and planted with local grass plants and trees. It should not be used for food crops for at least five years. Source: ArcelorMittal Liberia, proprietary guidelines and material adapted from Delaware State Department of Natural Resources and Environmental Control guidelines.




12. ENVIRONMENTAL EDUCATION STANDARDS

12.1 Standard for Briefing Site Crews

Western Range DSO Iron Ore Project

Environmental Briefing for Site Crews

May 2011

What is this document for? All site crews of the Company or Contractors must be briefed on key environmental issues before starting work in the field. This is to ensure that our operations do not cause environmental damage. This document describes the messages that need to be given, and a simple way to deliver them.

Purpose To ensure that all site workers are made aware of the importance of the environment and its protection, and reminded of this at frequent intervals.

Timing The briefing shall be done at the start of each package of work and at the beginning of each working week.

Duration It is expected to take only about ten minutes.

Process 1. Read the company‟s Environmental Rules

to the workers.

2. Invite questions and provide appropriate responses.

3. At the first briefing, and whenever they have been updated, hand out paper copies of the company‟s Environmental Rules.

4. Ask the workers if there are any rules which they cannot follow. Discuss the problems with them, and find solutions if possible. If there are no apparent solutions, note the details down and send them to the Environmental Officer for action.

5. Thank the workers for their interest and ask for their co-operation in safeguarding the environment.

Other actions The Environmental Rules shall also be displayed in notices on the site, which shall be painted or laminated in large size, and maintained for the duration of site works.

Western Range Iron Ore Concentrator Project, Liberia

Environmental and Social Studies, 2008-2011 Environmental Standards Manual


ARCELORMITTAL LIBERIA: ENVIRONMENTAL RULES

1. Respect the environment, the land, the soil, the forests, the rivers, the swamps and the ocean. Everyone depends on these things for food and health.

2. Respect the fact that other people and animals depend on the environment for their

lives and livelihoods. 3. No employee or contractor is allowed to hunt or deal with bush meat (including marine

mammal and reptile species) during working time or at any time within company work sites. No bushmeat may be carried in company vehicles. It is preferable to raise and eat domesticated animals (goats, chickens, etc.).

4. Off site, employees and contractors should only buy and eat the following animals:

Ground hog (cane rat);

Opassum (giant rat);

Ground squirrel. Trading in and eating most other bushmeat is against the law.

5. No smoking or lighting of fire in bush areas. This could cause bush fires that can

destroy important animals and plants. 8. Do not fish in sacred streams or cause damage to other sacred sites. We must respect

our culture. 9. Where latrines or toilets are provided at work sites, you must use them and not the

bush. Latrines must be filled in when abandoned. Chemical toilets must only be emptied in the specified and approved location.

10. No one should leave litter (plastic bag, paper, etc) in any water body (including the

ocean), on the port, railway, roads or any other work sites. Carry it back to the town or camp for proper disposal.

11. All hazardous materials (i.e. fuel, oil, other chemicals and sewage) must be stored or

disposed of in appropriate ways and specified locations. 12. Never dispose of hazardous materials in the port, the ocean, streams, water courses

and soil. It might poison someone. 13. In the event of an accident, damage or pollution, contact the nearest ArcelorMittal

office immediately. We are here to help! DO NOT TRY TO HIDE OR COVER IT UP: THIS COULD LEAD TO YOU BEING PUNISHED UNDER THE LAW.





12.2 Standard for Briefing Professional and Technical Staff

Western Range DSO Iron Ore Project

Safeguarding the Environment

May 2011

What is this document for? It is to explain how and why we must safeguard the environment.

Who is it addressed to? It is a guide for all managers and site supervisory staff of ArcelorMittal Liberia, its consultants and contractors.

What does the environment consist of? The environment is everything around us: the air we breathe, the water we drink, the land and soil where we produce food, the rivers and sea from which we catch fish, the forests that supply oxygen and house the plants that give medicines and animals that regulate the ecosystems, and the communities we live in. Our survival and well-being depend on a healthy environment. The resources we are exploiting are part of this environment. Our mining will alter some aspects of it forever. We must compensate for this by:

avoiding damage wherever possible;

leaving what we can unaffected; and

improving some other parts of the environment.

Our legal obligation The laws of the Republic of Liberia state that everyone has a right to a clean and healthy environment. This is a common international view. They recognise that:

the environment serves the national, economic, social, cultural, spiritual, and aesthetic needs of Liberia and its people;

Liberia‟s natural resources are a gift of nature for the welfare of both present and future generations;

the rights of local communities over their biological resources, knowledge and technologies are of a collective nature, and therefore, are a priori rights which take precedence over rights based on individual interests.

A mountain catchment in good ecological condition




ArcelorMittal’s obligation The company‟s Environmental Policy commits to:

Achieve a high standard of environmental management;

Comply with all relevant laws and regulations;

Continuously improve environmental performance;

Use low impact production methods, taking benefit from locally available materials;

Use natural resources, energy and land effectively;

Achieve employee commitment and responsibility in environmental performance;

Ensure supplier and contractor awareness and respect of company environmental policy;

Maintain open communications with all stakeholders affected by company operations.

A paradise flycatcher. Around 250 bird species are known in the Nimba mountains

What we are concerned about in the environment Overall We submit Environmental and Social Impact Assessments to the Government of Liberia for each major phase of mining. These show how the environmental damage from mining can be mitigated. Once the government, other stakeholders and the Environmental Protection Agency (the regulating authority) are convinced, we are issued with an environmental permit. If we do not get this, we are not allowed to start mining. The award of environmental permits is judged partly on whether we have performed well in our care of the environment during previous works. Therefore we must always do things properly! Communities All of the areas where we are working are inhabited and used by communities for their livelihoods. We are obliged to avoid causing any losses to them. If this cannot be avoided, then we must pay full and fair compensation.

At the mine sites The mine sites are located on rainforest-covered mountains. There are few such areas left in West Africa. The forests have a very high diversity of plants and animals, and so are of international importance because so much rainforest has already been destroyed. We must minimise the loss of further forest. Other environmental concerns are to safeguard soil resources for the future (the mine sites have to be restored afterwards) and to avoid pollution to the water courses. Air quality must also be safeguarded and noise minimised. On the railway The railway forms a line right across the centre of Liberia. The main environmental concern is damage to the numerous watercourses that it crosses, from eroded soil or other pollution. Vegetation must be managed carefully, so that plants and animals are not damaged unnecessarily. At the port Pollution of the sea is a concern here. Also that the city of Buchanan is not disturbed by dust or noise, and that pollutants do not get into the groundwater. In the townships Water supply and sewerage are the main concerns, along with malaria prevention. Good management of the housing areas is essential to ensure a pleasant environment for all residents.

15,000 people live around the mine sites and at least 100,000 live along the railway (within 1 km of the track)

What must each of us do about these things? The tables on the next pages give the practical details of what we must do, and what we must not do, to safeguard the environment. All managers and supervisors must ensure that they, their workers and contractors comply with these rules.




What we MUST do What we must NOT do Why must we do this or not do this?

Overall

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

Let our workers or contractors, or anyone else, damage any part of the environment.

To ensure that people can continue to lead healthy, prosperous lives. We have only one planet, so we must respect its environment!

Environmental awareness

Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main environmental messages (see site Environmental Rules and the Environmental Briefings).

Allow staff and workers to neglect environmental issues.

Site workers can cause considerable damage to the environment if they are not made aware of the ways in which they must take care. Ensuring this happens is a standard management responsibility in every industry.

Environmental compliance

Do everything possible to avoid causing damage to any part of the environment during all operations.

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

This may lead to offences under the Environment Protection and Management Law (2002). This allows for offenders to be fined, and imprisoned in some cases.

Vegetation

Only cut vegetation that is in the way of particular operations. This means plants that are in the direct area required for a track or other infrastructure.

Allow small plants to grow back on the edges of roads, and on tracks and other disturbed areas when their use is finished.

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

Cut any tree with a diameter greater than 300 mm (the length of a foot) without prior consent.

Use fire to remove vegetation.

Burn cut vegetation.

Cut any plantations without following procedures under “cultivated land”.

Vegetation protects the soil against erosion and provides valuable products as part of the local agriculture-forestry system. It also forms the basis of all habitats. Damaging it has knock-on effects on water regimes, people‟s livelihoods and animal ecosystems.

Heavily degraded hills in Guinea, about 30 km north of Liberia still has a vibrant cover of secondary forest in Yekepa: this is what we must avoid creating most places: we can keep it that way


Soils and earthworks

Only disturb the soil where it is necessary to do so.

Grade any newly formed slopes to the minimum angle possible.

Use existing tracks or previously disturbed areas as far as possible.

Undertake soil erosion prevention and sediment controls as required by the environmental staff if this should be deemed necessary, to protect areas from slips and erosion.

Take rapid measures to stop erosion if it should start.

Disturb any more of the ground surface than is absolutely necessary for access and working.

Make work sites larger, or roads wider, than necessary.

Create earth piles close to the edge of steep slopes or close to watercourses.

Leave soil slopes steeper than 10° completely bare and unprotected.

Drive unnecessarily often or use very heavy equipment on earthen access tracks (thereby compacting the soil excessively).

Soil is a dynamic biological resource that takes a very long time to form. It is the most essential medium for growing plants and food. Once lost, land is ruined for hundreds of years. In water courses, soil pollutes drinking water and damages aquatic ecosystems (including fisheries). Stopping the erosion of soil is the single most important aspect of ensuring environmental sustainability.





Water resources

Keep works sites as far as possible from water courses or bodies.

Where works sites are within 50 metres of water courses, take special care to ensure that fuel, oil, wood preservatives, herbicides etc, and any earthworks, are properly contained.

Ensure that all private and community water supplies are safeguarded.

Confirm the location of local water supplies with the company‟s Community Liaison Officer.

Allow leakages of fuel, oil, herbicide, wood preservative, drilling slurry or any other hazardous substance.

Dispose of anything into a water course or standing water body.

Extract so much water from a supply that the normal users are short.

Nearly every water course is used for drinking water and fishing. This is also of great importance to poor rural households. Watercourses are also important habitats for plants and animals.

Drainage

Provide drainage to all construction sites, and drainage structures wherever water needs to flow, such as across access roads.

Ensure water from drains is discharged at low energy via drop structures and aprons.

Make temporary drains as necessary to avoid waterlogging or erosion. These must be adequate to accommodate water discharged from works operations as well as rainfall.

Discharge drains into well vegetated areas. Provide mini silt collection ponds if drains must discharge straight into water courses.

Leave long gaps between drainage structures, so that a lot of water flow builds up.

Allow sediment from bare eroding surfaces to be washed into water courses.

Careful management of runoff water is the key to controlling soil erosion. If water flow is controlled, it will not wash soil away.

Animals

Ensure that the workforce does not hunt, deal in or transport bushmeat on site and during working hours.

Encourage workers to avoid prohibited meats at all times.

Expect workers to live in places where there is no source of meat from domesticated animals without providing an alternative.

Throughout West Africa the bushmeat trade is leading to the extinction of many wild animals. This causes irreparable damage to natural ecosystems.

It’s an opassum: there are lots of these, so you can eat But you must not buy or eat not this meat of monkeys and as many of them as you like duikers





Local people’s livelihoods

Follow an equitable and fair employment strategy. Work with the CLO* to ensure this is understood.

Give priority to those who used to earn their living on concession land.

Pay local people below the usual wage rates.

Demand unpaid work by local farmers or others.

In a poor society it is easy to exploit people who are desperate for any type of waged job. We must be fair, and ensure that communities are satisfied that we are treating them reasonably.

Use of cultivated land

Avoid the use of cultivated land wherever possible. This includes rubber and other tree plantations.

Where use of such land is required, check with the CLO* at least four weeks prior to commencement of activities (ideally earlier) that compensation has been agreed and implemented.

Start using cultivated land before the occupier has fully agreed the compensation strategy, all amounts have been paid and this is confirmed by the Resettlement Officer.

Damage crops or land beyond agreed boundaries.

It is both wrong and illegal to damage any property before full agreement is in place and all compensation completed. Land used for agriculture and tree crops is part of a household‟s livelihood. Most households in rural Liberia have a subsistence economy and are close to the survival line.

Damage to cultural sites

Check with local people, through the CLO*, as to whether any activities will affect cultural or religious sites.

If damage to cultural sites cannot be avoided, agree compensation measures through the CLO*.

Damage any sites of cultural or religious importance without first agreeing compensation arrangements.

Religious sites are very important in all cultures. In Liberia they are found in many rural locations. As with employment, we must ensure that the communities around us feel that we are treating them respectfully.

Noise

Provide communities, through the CLO*, with the works programmes.

Schedule works to avoid disturbance at night.

Deviate from the previously agreed timing of work.

It is unreasonable to disturb people with noise. Over a long period, even moderate levels of noise cause health problems.

Sanitation

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

Fill in the latrines when work finishes.

Allow latrines to become full or overflow.

Allow site workers to defecate at random in the bush.

Good sanitation is a simple but obvious way of helping to ensure good health.

Pollution from camps and stores

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

Devise on-site emergency spillage plans (see detail in the Standards Manual for guidance) and train staff in their implementation.

Remove all debris and litter from site.

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

Pollution can come in many forms. In most cases it takes very little to cause damage to some part of the environment. Accidents can happen easily and we must be prepared so that we can act quickly if they occur.

* The company‟s Community Liaison Officer.

Unnecessary bulldozing of rubber trees along a road A Nimba otter shrew. These are endemic to the mountains before compensation was paid: you could be fined of Nimba (i.e. they are found only there and nowhere else). heavily for actions like this. Their survival or extinction is in our hands.





12.3 Standard for Safety Awareness

SAFETY ABSOLUTES Working at Height – tie-off when working at unprotected elevations higher or deeper than 1.8 m from ground level. All safety rules to be implemented and adhered to, to prevent people and/or objects from falling.

Energy Isolation Procedures – adherence to safety lock-out and tag-out requirements for electrical, mechanical, pneumatic and hydraulic isolation. No unauthorised removal of isolation tags or locks.

Safe Work Permit – compliance to permit requirements (confined space entry, ground disturbance, hot work etc.).

Drug and Alcohol Policy – no selling or possessing drugs or intoxicants on the project site. An employee whose actions and demeanour show symptoms of possible narcosis or drunkenness shall be removed from the site.

Travel Management and Road Safety Plan – respect all traffic and road transportation rules.

No Smoking – in hazardous areas (flammable areas, “live plant areas”), confined working areas or vehicles.

Lifting Operations – respect all the rules of load handling at all times and never stand under or close to a suspended load.

No Tampering with safety devices or emergency response equipment.

No Operating Equipment without the proper authority or qualifications.

Negligent, Careless or Wilful Damage to property is forbidden.

Blatant Disregard for imminent danger in properly demarcated or barricaded zones in not tolerated.

Rolling Stock – respect rail property and stay out of clearance areas unless appropriate precautions have been taken.

Confined Space – no unauthorised entry into confined space.

Incident reporting and Investigation – all incidents must be reported and properly investigated to determine causes, learn lessons and engage preventative measures. Refusing to give evidence or deliberately making false statements during investigations connected with safety aspects will not be tolerated.

Emergency Preparedness – arrangements must be adhered by all and emergency drills are to be tested regularly

Fraternisation between Expatriates and Local Nationals – no sexual exploitation or sexual abuse will be tolerated.

Basic HSSE Arrangements – respect all the basic HSSE rules, standards, signals and signs, and wear the required PPE. Blatant or continual breaches of this and specifically horseplay will not be tolerated. Unauthorised bypassing of standard operating procedures is forbidden.

Assault, abuse or intimidation of any person is forbidden.

Dangerous Weapons – bringing on to site or possessing firearms, lethal weapons or explosive power tools are forbidden. Upon written request, explosive-powered tools may be authorised for use on Site subject to ArcelorMittal approval. Source: edited from Nimba Western Range Iron Ore Project Safety Absolutes.




13. ENVIRONMENTAL POLICIES

13.1 ArcelorMittal Corporate Environmental Policy

Source: ArcelorMittal.




13.2 Government of Liberia’s Environmental Principles The environment is safeguarded in Liberia by means of the Environment Protection and Management Law (2002). This adopts the following main principles. The principle of sustainable development. Natural resources must be used sustainably and wisely while pursuing social and economic development, in ways that do not undermine the capacity of ecosystems to renew and re-supply its elements (e.g. clean air and water). A policy framework is to be developed that sustains the use of resources through appropriate technology, efficient production processes, minimal waste and reduced wasteful consumption. The precautionary principle. Activities which might significantly alter the environment or use significant natural resources are to be subject to environmental assessments beforehand. It is incumbent on any developer to demonstrate that their activities will not affect the environmental adversely. Adequate environmental protection standards are to be adopted and environmental quality monitored. The polluter pays principle. Any polluter must pay the true and total costs of environmental pollution. The principle of inter-generational equity. The environment and natural resources will be used and conserved equitably for both the present and future generations, taking population growth and resource productivity into consideration. Future generations should inherit natural resources in as good a condition as possible. The principle of public participation. People are to be educated on, and made aware of, environmental issues. Decision making on the environment and natural resources is to be done with the maximum encouragement for public participation. Access to, and disclosure of, environmental information are to be ensured. Conservation of biodiversity. The restoration, protection and conservation of biological diversity must be managed, to ensure the maintenance of ecological systems and processes. Liberia is to align with international conventions to which it is a signatory. Right to a healthy environment. All people have a right to a clean and healthy environment. A system of legal recourse is to be maintained so that anyone is able to uphold this right, should it be infringed by another. Source: An Act Adopting the Environment Protection and Management Law of the Republic of Liberia, Approved 26 November 2002, with some interpretations by ArcelorMittal Liberia.




13.3 ArcelorMittal Liberia’s Policy on Caring for Nature




The reasons for a policy on caring for nature The natural environment in Liberia Liberia has a relatively small human population in a country of forests, rivers and swamps. It has abundant warmth and moisture, and these have led to exceptional diversity of plants and animals. The tropical soils are not very rich, but if managed wisely they can support good farms, plantations and forests. Traditional shifting agriculture gave rise to an environment of bush and forest in constant flux. The growing population and the transition to commercial plantations, logging and mining mean that Liberia‟s special natural environment is under threat. ArcelorMittal as a company is aware of the importance of managing nature and its resources wisely so that future generations can thrive here. Depleted nature Parts of the world where nature has been damaged by over-use become degraded and poor. In history, societies which did not care for nature ended up impoverished or forced to move into other areas. Modern technology can slow this process, but cannot stop it. Humans depend on their natural environment whether they live in the forest or in a city. Natural resources As a mining company, ArcelorMittal Liberia accepts that its exploitation of minerals is not sustainable. The company benefits from a one-off realisation of wealth from some of the natural resources of our working areas. It is right and just that we use some of that wealth to ensure that the other natural resources are improved and that ways are found to manage them sustainably. This approach forms the basis of compensating for, or offsetting, permanent changes that result from mining. The business case Long term prosperity is only possible by ensuring that we can create wealth sustainably. Commerce and trade are the sources of prosperity in the human world. Wealth is created by human labour using the elements of nature. Our investors and customers, and the communities in which we operate, will trust us only if we can show that we can manage natural resources wisely. [VERSION DATE: 2 NOVEMBER 2012] Source: ArcelorMittal Liberia.

Documents

Environmental and Social Standards Manual · EPA Environmental Protection Agency EPML Environmental Protection and Management Law ESIA Environmental and Social Impact Assessment FDA