LNG Terminal · The LNG terminal will allow the unloading of LNG imported via special LNG ships, storage and re-gasification of LNG at the terminal facility, and then transfer of

LNG Terminal

Świnoujście, Poland

Environmental and Social

Action Plan (ESAP)

November, 2010

PROJECT NO. P0114469, POLSKIE LNG SP. Z O.O DRAFT FINAL OCTOBER 2010

LNG TERMINAL IN ŚWINOUJŚCIE, POLAND 1 ESAP FOR LOAN DOCUMENTATION

Environmental and Social Action Plan ESAP

Brief Description of the Project

Polski LNG (PLNG) is planning to construct and operate a liquefied natural gas

(LNG) terminal in the port of Swinoujscie. The LNG terminal will allow the

unloading of LNG imported via special LNG ships, storage and re-gasification of

LNG at the terminal facility, and then transfer of gas via pipeline into the existing

Polish national gas distribution system.

The Project consists of four main Project Components. Besides the terminal that

will be developed by PLNG, the Project comprises the establishment of harbour

infrastructure (breakwater and tanker berthing/jetty facilities) for the LNG ships

developed by the Maritime Office in Szczecin (MOS) and Szczecin & Świnoujście

Seaports Authority (S&SSA), and construction of a connecting pipeline from the

LNG terminal to the national transmission grid built by Gaz-System.

PLNG, MOS, S&SSA and Gaz System are referred to as “Project Sponsors”, with

Gaz-System acting as the coordinator for the overall Project as per August 2009

Cooperation Agreement between the Sponsors.

A detailed Non Technical Summary can be found at http://www.polskielng.pl/

website.

Purpose and Scope of the ESAP

This Environmental and Social Action Plan (ESAP) compiles the organizational

requirements and mitigation measures (“Action Items”) to avoid potentially

adverse effects of the Project on the environment, on conditions of health, safety

and security of workforce and the public, and on social and socio-economic

conditions. The ESAP applies for all Project phases, i.e. project design,

construction, operation, and decommissioning.

The ESAP will form part of the loan agreement between the Lenders and PLNG;

consequently, the overall responsibility for the ESAP implementation lies with

PLNG.

This ESAP also presents Action Items required to make the Project compliant

with international requirements, international best practice, and Lenders

Requirements that are defined as follows:



Lenders Environmental and Social Requirements:

All elements of the Project will need to meet Polish environmental, health and

safety and social laws and regulations;

All elements of the Project will be carried out in compliance with the European

Union environmental and social standards, in particular SEA, EIA, Birds and

Habitat Directives and IPPC requirements.

Compliance with the IFC Performance Standards available at

http://www.ifc.org/enviro and Equator Principles (applicable standards)

available at http://www.equator-principles.com/

Compliance with the EBRD‟s Environmental and Social Policy and Performance

Requirements (PR‟s) 2008

http://www.ebrd.com/about/policies/enviro/policy/2008policy.pdf

Public consultation and stakeholder engagement will be meaningful and allow

for public participation in decision making (in accordance with UN ECE Aarhus

convention)

The project includes all necessary measures to avoid, minimize or mitigate any

adverse change in environmental conditions and impacts on public health and

safety.

The various decisions, permits and approval to date received by the Project

Sponsors for the different Project Components contain a large number of

mitigation measures and specific instructions and action items. The relevant

documents are referenced here in the ESAP, but the mitigation measures

themselves are not repeated in detail here; instead these are summarised as high-

level action items.

This ESAP will be made available to the Contractors working on behalf of the

Sponsors and will be expected to comply with and implement relevant

requirements (this includes their subcontractors). The ESAP will also be made

publicly available.

A Community Liaison Officer (CLO) will be established to handle

communication, answer questions, and make sure people are aware of the

Sponsors‟ commitments. The CLO will also be in charge of a grievance

mechanism that will handle any complaints or suggestions from the public or

stakeholders, including workers.

The implementation of the ESAP and compliance with Lenders Requirements

will be monitored by the Lenders with the assistance of an Independent

Environmental and Social Monitoring Consultant (IESMC), and an Independent

Technical Consultant (ITC) as required.

http://www.equator-principles.com/



Action Item Tables

The ESAP Action Items are contained in several tables as shown below. Included

within these Action Items are references to the Stakeholder Engagement Plan

(SEP) and the Biodiversity Action Plan (BAP), that were both developed for the

Project.

The Action item tables are structured as follows:

Table 1 for the Overall LNG Project (“OP”),

Table 2 for LNG Terminal (“T”),

Table 3 for Breakwater and Jetty (“BJ”),

Table 4 for Pipeline (“P”), and

Table 5 includes measures that result from the Social Review of the Project

(“SR”).

PROJECT NO. P0114469, POLSKIE LNG SP. Z O.O DRAFT FINAL NOVEMBER 2010


Table 1 Overall Project

Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue

Mitigation / Management Responsibility /

Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

OP1 Lender requirements

Overall commitment to implement the Lenders Requirements and EU standards.

PLNG, Gaz-System, Maritime Office, Port Authority

Personnel and office cost

Prior to signing the loan agreement

OP2

PS1/ PR1

Management Capacity

Gaz-System will take the role as coordinator for Project implementation by setting up a an Overall Operational Coordination Unit (OOCU) for the LNG Project and continue to coordinate between Project Sponsors on EHS / Stakeholder Engagement issues related to the lenders‟ requirements .

Statutory meetings will include EHS issues in the agenda.


Minutes of Meeting

Reports to IESMC


Prior to signing the loan agreement

OP3

PS1/ PR1

Contractor Management

“Lenders‟ Requirements” will be fulfilled including the requirements of this ESAP and will be monitored by the IESMC.


Implementation monitored and reported

Report from IESMC


Through construction, commissioning and operation

OP4

PS1/ PR1 + PR10

Stakeholder Engagement

Implementation of the Stakeholder Engagement Plan (SEP); dated November 10, 2010. (Including disclosure in Germany and fishermen focus group meeting).

PLNG, Gaz System

CLO at Project Coordination Level

Evidence / records that show that process has started and is operational

Report to Lenders


Ongoing



Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

Activities as per SEP carried out and documented in Annual Report

OP5

PS1/ PR1&10

Community Liaison

Establishment of a Grievance Mechanism for the overall Project which is made readily available to the public and other stakeholders.

Grievances will in general be responded to within 10 working days after receipt

Gaz System shall ensure that staff and contractors are informed about the grievance procedure.

Gaz-System in its role of Project Coordinator on behalf of all Project Sponsors - CLO

CLO person / team in place;

Monthly reporting on SEP implementation progress;

Grievance register and tracker demonstrate follow-up and project response to grievances from receipt to resolution


Start of consultation / information phase -asap

OP6

PS1/ PR1

Social Review

The Project Sponsors shall implement the mitigation measures defined in the Social Review and report on their implementation to the IESMC.

Remedial Action plans shall be agreed with the IESMC and Lenders in the event of any non-compliances being identified.

PLNG Note to Lenders

Annual reports


Start of consultation phase - asap

OP7 PS6/ PR6

Impact on Biodiversity

Disclose and implement the Biodiversity Action Plan (BAP)

Within the EHS reporting Sponsors will inform Lenders on the implementation of

PLNG

Gaz System

S&SPA

MOS

IESMC to monitor and verify compliance.

Report on status to

Consulting fees

Personnel and office

BAP to be disclosed prior to signing the



Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

the BAP. Lenders cost loan agreement

Report to Lenders

OP8

PS1/ PR1

Reporting – Construction

The Project Sponsors will compile every year EHS monitoring reports (additionally, during the initial phase semi annual EHS monitoring statements) during construction, to be review internally by senior management, and then provide to the IESMC for review. The reports formats and content are to be approved with Lenders prior to construction commencing.

Gaz System will take the coordinating role to ensure that EHS reports will be provided from Projects Sponsors

Yearly EHS monitoring reports from Project Sponsors. Additionally, during the initial phase semi annual EHS monitoring statements from Project sponsors


During Construction Phase

OP9 PS1/ PR1

Reporting – Operations

Annual monitoring reports will be compiled by Project Sponsors, review internally by senior management, and then provide and made available to the relevant authorities and the lenders, as requested and appropriate. The reports shall cover the status of EHS related aspects such as, status of compliance with obligations arising from licences or permits, exceeding of regulatory environmental standards with root cause analysis and corrective measures.

PLNG will take the coordinating role to ensure that annual reports will be provided from Projects Sponsors

Annual Report on environmental & social performance and ESAP implementation


Annual Report

During lifetime of project

OP10 Public A report on the EHS performance of the Gaz System – Annual Report on Personnel Annual



Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

PS1/ PR1 Reporting Project including ESAP implementation shall be issued to the public on an annual basis.

construction phase

PLNG – operation phase

EHS and office cost

Report During lifetime of project

OP11

PS1/ PR1

Change Management

A change management procedure that assesses EHS risks is in place satisfactory to the Lenders.

Lenders to be notified of significant changes with potentially high EHS or reputation risks on a timely basis. Such changes cover for example changes in design or operation.

Significant changes to be publicly disclosed.

A summary of all the changes to be reported to the IESMC.

PLNG

Gaz System

S&SPA

MOS

Notification of significant changes in Project to Lenders

Change management procedures reported satisfactory to IESMC


Ad hoc notification of lenders

OP12

PS2/ PR2

Local Recruitment

As part of the information to local communities, the Project's CLO will organise information meetings in Swinoujsce for LNG terminal and connecting pipeline and subsequently along the transmission pipeline in advance of construction commencement of works to present the staffing concept and point out the potential for local recruitment and provide information whom to contact with applications.

Gaz System CLO

Minutes of Meeting Personnel and office cost

Prior construction

OP13

PS2/ PR2

Quick response medical

The Project Sponsors must confirm and provide evidence to Lenders that the EPC Contractor has provided the medical risk

All Sponsors (Gaz System, PLNG, MOS, S&SPA) for

First-aid/medical response service plan


Prior to construction



Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

service assessment / medical response plan compliant with Lenders‟ requirements. The Project Sponsor must demonstrate the implementation of the appropriate on-site first-aid/medical response facility based on the medical risk assessment.

their contractors

OP 14 PS2/ PR2

Staff training operation

All operational personnel will be provided with training on basic safety and environmental issues and procedures specific to the projects components. This training should provide personnel with the necessary skills and knowledge needed to conduct their jobs in a safe manner, provide for health and safety of all persons, and protect the environment. Training records shall be maintained.

PLNG

Gaz System

MOS

S&SPA

Training Plan and documentation of participation


Consulting cost

Prior to operation and annual refresher

OP 15

PS3/ PR3

Waste management

The Project Sponsor and contractors will implement procedures for waste minimisation, reuse, recycling, treatment and disposal in accordance with EU requirements and the applicable Polish laws and regulations as well as international guidelines.

Waste Management Plans (WMP) will be developed (i) in the construction phase by the respective contractors and (ii) in operation phase by the respective operator of the various Project Components.

The draft WMPs will be submitted to

PLNG

Gaz System

MOS

S&SPA

Waste management plans


Consulting fees


Prior to operation



Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

IESMC for comments prior to submission to the competent authority .

OP 16

PS1/PR1

Supply chain Overall sourcing of labour and materials will be in accordance with Polish/EU regulations proved by certificates, where relevant. The main resources/materials needed for construction and operation of the Project include the rocks for breakwater and steel tubing for the pipeline. Additional specifications are warranted for the contractors to ensure these materials are not obtained from any ecologically sensitive areas, nor low labour cost a factor.

PLNG

Gaz System

MOS

S&SPA

Tender specifications

Evidence of licenses and permits, compliance checks.

No extra costs

At construction start

OP 17

PR1

Independent Monitoring

Detailed stand-alone sub-plans will be developed to address ESAP issues (e.g. detailed Monitoring Plan, Emergency Response Plan). In case of delegation of responsibility, sub-plans shall be developed by contracted companies according to their area of responsibility in order to show how they implement the Projects‟ ESAP requirements. It is the responsibility of Sponsors to ensure that such plans are consistent with Lender Requirements and the overall ESAP. The compliance with the ESAP will be monitored by the IESMC to the Lenders. Within the scope of such IESMC will be the confirmation of compliance with the Lenders Environmental & Social Requirements and

PLNG

Gaz System

MOS

S&SPA

Engagement of IESMC

Consulting fees

Start of construction phase



Item No.

Lender „s

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

the ESAP.



Table 2 LNG Terminal

Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

T0

PS1/PR1

Compliance with the conditions of the decisions, permits and approvals and Lender requirements

Implementation of all mitigation measures stipulated in:

Decisions on environmental conditions for implementation of the LNG Terminal - for both on- and off-shore components as an output of EIA procedures (February 12, 2009; March 4, 2009);

Permissions for location of LNG terminal in flooding area (April 22, 2009; May 27, 2009);

Non-forest land use permissions for the forest areas within the planned LNG terminal site (June 12, 2008; June 15, 2009);

Permission for trees/shrubs clearance (June 10, 2009);

Wildlife derogations (transfer / removal / disturbance permissions regarding specified protected species and their habitats) (November 14, 2008 - January 25, 2010)

Water supply and sewage effluent disposal consent for intake and discharging water in LNG tanks hydrotesting process (April 30, 2009);

Rainwater discharge consent for LNG

PLNG

Environmental Design Requirements; specifications and instructions for Contractors ;

Monitoring and Audit reports

Permit Register with key requirements

Auditing time


Prior Construction

During Construction

During Operation



Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

terminal area (January 8, 2010);

Acceptance decisions on a design for a building and construction permits for the LNG terminal in Świnoujście (July 15, 2009; March 3, 2010).

PLNG shall submit to the Lenders on six monthly basis during construction and annual during LNG terminal operation update on compliance status

Annual report on mitigation measures and wildlife monitoring ( “Sprawozdanie roczne z działań ochronnych i monitoringu przyrodniczego”)

T1

PS1/ PR1

Social and Environmental Management System

The EPC Contractor will have to prepare and implement a Health and Safety Plan and a Quality Assurance Plan. A Construction Environmental Management Plan shall cover among others such issues as: waste management, pollution prevention, emergency response, which will be implemented in forms of plans / programs in accordance with Polish and EU legislation requirements. The EPC contractor will also incorporate procedures in case of environmental contamination (Spill Response Plan) and Social Management Plan.

The EPC Contractor shall provide the required plans, programs, processes and procedures to PLNG and IESMC for

PLNG

Implementation of Management systems and Plans

Delivery of plans and contractors management system to IESMC for review

Satisfactory to IESMC and Lenders


As soon as possible



Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

approval. The measures to be implemented in each plan shall be specified in detail by including priority, timeline, performance indicator, acceptance criteria that can be tracked over defined time periods, and should also indicate the resources, including budget, and responsibilities required for implementation.

The process for dealing with non-conformances shall be in line with international standards for management systems.

T2 PS1/ PR1

Organisational Capacity

An EHS Team shall be established for the construction phase and their roles, duties, responsibilities, authority, and reporting lines to be specified in the Management System.

The EPC Contractor will establish the following positions: H&S Coordinator, Environmental Manager and a fire fighting specialist. The team members shall be competent and trained. The Management System shall also specifically indicate the minimum number of staff required for the overall team and for each position identified.

PLNG

EHS Plan for construction phase and for operation phase

Satisfactory to IESMC and Lenders


Prior Construction

T3 PS1/ PR1

Training The EPC Contractor for construction works will provide project specific EHS (BHP) and social training to ensure that all staff

PLNG

Training Matrix

Training records

Satisfactory to





Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

working on site are aware of their duties and responsibilities relating to EHS and to maintain documents for all training provided. EHS critical posts must have training and competence requirements defined.

IESMC/Lenders

T4 PS1/ PR10

Community Engagement

As per ESAP item OP1, the Project Sponsors will designate a Community Liaison Officer (CLO) as part of the implementation of the SEP.

The EPC Contractor shall designate a responsible person who will liaise with the CLO to follow up on complaints and grievances from local communities involving the contractor and to otherwise support the CLO as requested.

PLNG

Gaz System

Records of consultations, Grievance mechanism, employment contract, organisation chart

PLNG Personnel and office cost


T5 (PS1/ PR10)

Social Issues

The PLNG Project Social Review defines mitigation measures to be adopted to address social impacts. The EPC Contractor shall develop and implement a Social Management Plan SMP to address mitigation measures related to the construction phase of the project. The Plan is to be approved by PLNG and the IESMC/Lenders prior to construction works.

PLNG

Social Management Plan.

Addressing the findings in the Social Review in form & substance satisfactory to Lenders/IESMC


SMP to be provided prior to signing the loan agreement

IESMC six monthly reports

T6 PS1/ PR1

Monitoring For the construction phase, monitoring and reporting procedures shall be established by the EPC Contractor (to be consistent

PLNG Monitoring documented by reports


Monthly reports to PLNG



Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

with the ESIA, ESAP, and Project Standards) and approved by PLNG and IESMC / Lenders.

Formats of Monitoring reports provided by the EPC contractor shall be agreed with PLNG and the IESMC / Lenders.

Monitoring reports will include information on safety issues, incidents/accidents, inspections by regulators, need for corrective measures, conflicts amongst construction workforce or with local residents, grievances of workforce or stakeholders. Sub-contractor related issues shall be included.

Effective corrective actions tracked to remedy unsatisfactory situations

IESMC six monthly reports

T7 PS1/ PR1

Audits / Internal Reporting

PLNG and the EPC Contractor shall implement a programme of EHS audits and reviews to ensure compliance with Lenders‟ requirements and the ESAP during construction and commissioning, and report to IESMC and Lenders.

PLNG

Audit programme


Monthly/ Quarterly Reporting

T8 PS1/ PR1

Noise A noise monitoring programme shall be established during construction and operation which shall include night time measurements in compliance with Polish regulation. Non-compliances will be investigated and corrective actions shall be notified to the IESMC.

Additional noise abatement measures such as acoustic shielding shall be implemented

PLNG

EPC Contractor

Noise monitoring programme

Cost for noise measurements


Quarterly Reporting during construction and annual reporting during operation



Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

during operations, where it is confirmed that admissible limits are exceeded.

T9 PS3/PR3

Energy efficiency / Green House Gas Emissions Reduction

EBRD policy and EPs (IFC PS) require that facilities emitting significant amounts of CO2 (i.e. greater than 100,000 tons per year of CO2 equivalent) must establish a yearly reporting programme to the Lenders. The LNG Terminal will be obliged to implement such a programme, which must include information on energy use/CO2 emissions and an evaluation of feasible options for minimizing such emissions.

PLNG Initial CO2 report and annual updates


Annual Report during operation

T10 PS4/ PR4

Emergency Preparedness and Response Plan – Seveso Plan

The LNG Terminal is subject to the EU Seveso II Directive (96/82/EC) and the respective Polish regulation (April 9, 2002), the following documents will have to be prepared

- Major-Accident Prevention Program

- Safety Report

- Emergency Plan

- Information on Safety and Response Measures to be provided to the Community

These documents will be based on the detailed design for the project and need to be provided and agreed with PLNG and IESMC prior to obtaining the operation permit. All measures are to be developed in consultation with relevant authorities and with institutional stakeholders.

PLNG

Major-Accident Prevention Program

Safety Report

Emergency Plan

Information on Safety Measures has been provided to the Community


Consulting fees

Prior to obtaining the operation permit

(recommended 30 days prior obtaining the operation permit )



Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

T11 PS4/ PR4

Emergency Response construction

EPC contractor to set up a Plan of Safety and Health at the Construction Site (BIOZ) with compliance with Polish legislation and including annual partial evacuation exercise of construction site.

PLNG

Written BIOZ

Annual BIOZ update



T12

PS3/ PR3

Technical State of the Art / Best Available Technique

In accordance with the Polish Law, EU IPPC Directive, the design, construction and operation of all equipment installed for use on this project will be compliant with following industry norms: EN 1473, EN 12259 and will be reference BAT.

PLNG PLNG to provide performance compliance statement of Detailed Design

Compliance of technical design of installed equipment to be confirmed by ITC during site visits


Prior Construction

T13 PS4/ PR4

Natural hazards

Risk analysis to be completed before start of operation detailing the possible impacts to the project caused by natural hazards. Mitigation measures to be addressed in the emergency response plans.

PLNG

See above

Detailed QRA Report


Prior to start the operation

T14 PS1/ PR1

Transportation

The EPC Contractor shall develop a Transport Management Plan for the construction phase including road safety on and off site aimed at ensuring there are no adverse effects to local communities (alternatively this item should be covered by the Construction Logistics Plan). The Plan shall be agreed with PLNG and the IESMC. Information on the plan shall be made publicly available and include

PLNG

Transport Management Plan

Transport Management Plan satisfactory to IESMC.





Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

advance notification of traffic restrictions to potential affected parties.

T15 PS2/ PR2

Construction Workforce

Prepare and implement a Construction Worker Management Plan (CWMP) to address the requirements identified in the Social Review and SEP and meet Lender requirements for EPC contractor and subcontractors. (Note: many components of the CWMP are addressed in the H&S Programme SNC-Lavalin 2008). This CWMP shall be reviewed and approved by the IESMC. The CWMP will address inter alia:

code of conduct related to site work and community relations

prevention measures and awareness training regarding potential diseases introduced/spread by construction workforce

on-site accommodation plan (if applicable) according to Polish legal requirements and in addition considering the IFC/EBRD‟s worker accommodation guidelines (http://www.ebrd.com/enviro/tools/workers.pdf ).

free access to medical service, healthcare and preventative treatment.

provision of transport for workers to/from worksite and for non-work

PLNG

Detailed Construction Worker Management Plan

Plan satisfactory to IESMC/Lenders and in compliance with construction camps workers accommodations process & standards


As soon as possible (prior to signing the loan agreement)

http://www.ebrd.com/enviro/tools/workers.pdfhttp://www.ebrd.com/enviro/tools/workers.pdf



Item No.

Lender

Standard

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

needs so as not to affect local transport systems.

For any foreign workers, appropriate training and information will be provided in their primary language and translators available to assist with communication.

T16 PS4/ PR4

Local Economy

The PLNG will work with local authorities to identify ways the local community can benefit from the influx of workers (e.g. opportunities to supply foodstuffs, sell snacks, etc.).

The EPC Contractor will address the requirements of the Stakeholder Engagement Plan regarding advertisements of local job and procurement opportunities, and will monitor and track number and origin of local people in the construction workforce (including subcontractors) and track amount of local procurement.

PLNG

Protocol of meetings

Posted adverts in local media

Records of local hiring and procurement

Personnel and office costs

Meetings prior to construction

Records update annually

T17 PS4/ PR4

Site Security and Access

PLNG have developed a Site Security Concept (SSC) . This includes Site Security and Access issues. A detailed site security plan (SSP) will be developed by EPC Contractor and approved by PLNG in accordance with applicable law and prior to start of construction. Adequate security arrangements will be put in place.

If necessary, PLNG will consult with the local police. If they propose any specific

PLNG

EPC Contractor to follow during construction, PLNG during operation

Detailed Site Security Plan in place.





safeguards in relation to the project and the construction workforce, the the SSP will be amended accordingly.

T18 PS6/PR6

Groundwater

Development of a Construction Site Groundwater and Surface water Management Plan to prevent drainage or other adverse impacts to nearby habitats

PLNG Construction Site Groundwater and Surface water Management Plan (sign off by IESMC)



T19 PS6/PR6

Sewage Water

PLNG must confirm that the potential additional water and sewage needs of the worker camp and construction activities can be handled by the local systems in Warszow. If needed, additional portable treatment capacities must be provided.

PLNG

Confirmation by Operator of Sewage treatment plant or similar document


Prior construction



Table 3 Water Side Installations: Breakwater (New External Harbour) & Jetty (LNG Berth)

Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

BJ 0 Breakwater: Compliance with the conditions of the decisions, permits and approvals


Construction of the Protective Breakwater for the External Port in Świnoujście – the Offshore Section (The Regional Director for Environmental Protection in Szczecin (6 May 2009): Decision on environmental conditions

Construction of the Protective Breakwater for the External Port in Świnoujście – the Offshore Section (The Regional Director for Environmental Protection in Szczecin (19 May 2009): Decision on environmental conditions – Repeal and amendment

Construction of the Protective Breakwater for the External Port in Świnoujście – the Onshore Section (The Mayor of the Town of Świnoujście (June 9, 2009): Decision on environmental conditions

Project Sponsor shall submit to the Lenders on annual basis an update on compliance status.

MOS

Environmental Design Requirements specifications Audit reports

Auditing time


As per the Decisions – annual status reports

Satisfactory to IESMC/Lenders

BJ 1 Jetty: Compliance with the


Establishment of a berth in the external

S&SPA Conditions transposed to Environmental

Auditing time

Personnel

As per the Decisions – annual status

Satisfactory to ITC/IESMC/



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

conditions of the decisions, permits and approvals

port in Świnoujście (The Regional Director for Environmental Protection in Szczecin (18 June 2009): Decision on environmental conditions

Project Sponsor shall submit to the Lenders on annual basis an update on compliance status.

Design Requirements specifications and construction work instructions

Audit reports

and office cost

reports Lenders

BJ 2 (PS4/ PR4)

Navigation Safety and Emergency Preparedness and response to ship accidents

A navigation risk assessment (QRA) was undertaken by the Maritime Academy in Szczecin for the LNG port facilities and the navigation access and the required measures for safe navigation and emergency response were identified. As a result of the QRA, an improved Vessel Tracking System (VTS) will be installed by the Maritime Office, and a fire fighting ship, tug boats and support vessels will be provided by the Port and mariner staff will be trained prior to commencement of harbour operation.

Further for the new external harbour a Port Regulation will be established by the Maritime Office Szczecin prior to commencement of harbour operation.

Accordingly, the Port will update the present Emergency and Oil Spill Response Plan (OSRP) of the port to cover the new external harbour and LNG vessel traffic, and additional equipment and services will be purchased as needed and staff will be

MOS

S&SPA

VTS installed and functioning – local demonstration

Ships/vessels provided and training protocols

New Port Regulation is announced

Revised OSRP

Costs for VTS,

Ships/vessels


Draft OSRP six months prior to operation

Other items six months prior to operation

Safety and Emergency Preparedness and Response Plan satisfactory to IESMC/Lenders



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

trained by the Port in advance of the start of LNG ship operations, i.e. by mid 2014.

The preparation of the new response plan will be consulted with the competent authorities and responsible response organisations and include information relating to potential trans boundary impacts.

The Port Authority shall provide the IESMC and Lenders with a draft copy of the OSRP for review and comment. The OSRP will be completed a minimum of 6 months prior to operation.

BJ 3

PR2/ PR4

Vessel traffic management

Existing VTS to be improved (see above)

A vessel exclusion zone will be in place around the construction, dredging and dredge disposal operations. This zone will have a safe radius to be determined by the Competent Authority (CA) prior to construction.

Safety of construction vessel traffic is regulated in Navigation Safety Plan, which was approved by the competent authority (MOS).

The Project sponsor will inform shipping control networks, shipping companies, fishery organisations, navies, etc. regarding the exclusion zone. A Notice to Mariners will be issued.

MOS

Contractor specifications.

Safe radius is defined and communicated

Notice to Mariners, shipping networks etc. documented

Navigation charts modified

Navaids installed

Sign off by IESMC on adequacy.


Costs for VTS and navaids

Consulting costs

(all items MOS and S&SPA budget)

Prior to operation



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

Navigation charts will be modified during detail engineering, in consultation with local authorities, to signal the presence of the new breakwater. If necessary shipping lanes will be modified.

Regulatory marking, illumination and marine navigation aids (navaids) on the breakwater and jetty will conform to the recommendations of the International Association of Lighthouse Authorities. Navaids will be located such that they can be maintained.

BJ 4

PS1/ PR1

Management Capacity of the Port to handle environmental, safety and security aspects of LNG vessels

Port Authority will carry out

(i) an analysis of the adequacy of the management capacity and facilities (port reception facilities, security arrangements) and capabilities (fire fighting, emergency response) vis-à-vis its future use by LNG tankers in accordance with relevant IMO (MARPOL 73/78 and Annexes) and HELCOM requirements, EU directives and international standards, Polish Labour law /ILO regulations. and

(ii) take necessary measures (such as training, procurement of equipment, etc.) to ensure compliance with all the requirements by the start of commissioning of the new harbour.

S&SPA

Analysis performed and plan of action in place.

Reporting

Relevant criteria implemented in detailed design. All requirements built into the design and EMS which will assist in ensuring that the project remains compliant.

Training and capacity building programmes

Procurement plans for equipment


Auditing time

Gap Analysis by June 2014

Implementation before commissioning of the new harbour



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

Respective update of the Part regulation the Port regulations that conform to highest environmental standards

IESMC sign off

BJ 5

PS3/ PR3 PS6/ PR6

Protection of marine environment

The Project will comply with IMO requirements (MARPOL 73/78 and Annexes), HELCOM recommendations and IFC guidelines where relevant.

Regulatory Change Management: A number of IMO Conventions and/or HELCOM recommendations and EU Directives will enter into force as the Project progresses and therefore a system will be in place to incorporate any changes in the Project design or its activities.

The aforementioned considerations will equally apply to the Project contractors and suppliers. EPC contractors and supplier shall develop and implement similar environmental management procedures relevant to its activities.

MOS and S&SPA during Construction and Operation

EPC contractors during marine site construction

Relevant criteria implemented in detailed design. All requirements built into an Environmental Management System (EMS) which will assist in ensuring that the project remains compliant.


Auditing time

BJ 6 PS1/ PR1

Supply Chain: LNG tanker operation

LNG transport to the Project shall be safeguarded by a Ship Owners Management System that includes the provisions of the Safety of Life at Sea

PLNG to require from the gas supplier that LNG vessel transport

Ship owners management system in place and evidence that it includes


Auditing

Prior to first delivery of LNG to the Project



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

Convention, including in particular Chapter IX pertaining to the International Safety Management (ISM) Code, The International Convention on Oil Pollution Preparedness, Response and Co-operation OPRC), and the International Convention on the Prevention of Pollution from Ships (MARPOL 73/78), among others. Further, it should include guidelines, codes and relevant international conventions to safeguard those additional requirements of the Baltic Sea Special Area such as those established by the Marine Environment Protection Committee (MEPC) and Maritime Safety Committee (MSC) of the International Maritime Organization (port regulation will comply with IMO and HELCOM regulations).

complies with all relevant legal requirements as per international conventions and guidelines.

PLNG responsible to check compliance

relevant guidelines, codes and international conventions.

Criteria implemented into vessel contractor specifications and contractors scope for procurement and port regulations.

EMS procedures implemented into contractor scope and supervision required.

time

BJ 7 PS6/ PR6

Piling noise / impacts to marine mammals and fish

Vibration piling will be the primary method of piling. Exceptionally, if due to technical reasons the vibration piling will not be possible to conduct, a hydraulic hammer will be used. Soft start procedures shall be applied to piling operations.

If piling will have to be executed during herring spawning, the piling will be reduced to technologically possible minimum.

Sponsors (MOS, S&SSA) to agree work instruction for piling with the Contractors

Supervision and reporting on hammer piling exceptions by environmental supervisor

Contractor scope specifications and contractor QMS

Inspection and monitoring of piling activities according to overall EMS and QMS


Auditing time




Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

BJ 8 PS3/ PR3

Source of rock for breakwater

Rock is to be sourced from an established and duly licensed/permitted quarry. Rock is to be free of contaminants and fines.

MOS

Contractor

Contractors scope for procurement



BJ 9 PS6/ PR6

Dredging & dredge disposal – impacts on water quality and aquatic life

1) Timing: As per the environmental studies for dredge spoil disposal, sediment disposal will be undertaken only outside the herring spawning season (usually April-May, but subject to real environmental conditions of the spawning activity)..

2) Selection of vessels: Use of Trailer Suction Hopper Dredgers TSHD to reduce the overall period of high turbidity from dredging-related activities. Reduce overflow allowed from TSHD whilst dredging.

3) Selection of equipment and methods:

use excavation and dredging methods to

minimise suspension of sediments (e.g.

adjust the size of grabs, use of

environmental grab, silt screens (if needed)

and green valves (where possible),

recycling (part of) overflow water, overflow

with bottom exit).

4) Apply Feedback Monitoring depending on actual construction

MOS, S&SPA

Implementation: Contractor

Contractor scope specifications;

Contractor QMS;

Ongoing monitoring of dredging activities and turbidity according to overall EMS and QMS.





Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

sequence: It is planned that all the dredging will be carried out in the area enclosed by the existing and new breakwater - with just about 10% access to the open sea. Currently (beginning Nov.2010) there is 800 m of breakwater built and it is planned to be 70% complete prior to any dredging. In case of changes in the above envisaged sequence (i.e. dredging takes places with wider open access to the sea), feedback monitoring will be applied as follows: Turbidity levels generated by dredging in the near shore area are to be monitored at the time of dredging. Should turbidity measurements taken at 1 m below surface at 600m down drift of dredging operation exceed the range of natural background levels, then the Contractor shall adjust the operation by either (i) slow down dredging; (ii) move dredge location to areas less prone plume dispersion; or (iii) cease dredging.

5) Inspection and monitoring: of dredging activities to be conducted to evaluate the effectiveness of impact



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

prevention strategies, and re-adjusted where necessary.

BJ 10

PR6/ PR6

Impact on water quality and aquatic life from Dredge spoil disposal in Natura2000 site.

Monitoring will be carried out prior, during and after completion of dredging works. Such monitoring will comprise inter alia:

• bathymetric surveys of topographic conditions in disposal area: pre-disposal and post-disposal (i.e.to confirm the cell boundaries and spoils pile height maintained);

• evaluation of recovery of benthic organisms at dredge site and disposal site/surroundings; via benthic baseline survey at and around the disposal site before disposal starts, and post dredging monitoring

• monitoring of seawater turbidity at discrete intervals downdrift of actual dredging and disposal operations to confirm if dispersion predictions in the Dredging Environmental Reports are accurate and to confirm that any sensitive areas have not being impacted.

The Regional Director for Environmental Protection in Szczecin, on the basis of the provided results of the monitoring, may decide, for example, to take mitigative actions.

MOS, S&SPA Survey completed Monitoring results submitted to IESMC

Monitoring contract.

Consulting fees

Monitoring to commence at the same time as dredging (Project to provide a timetable for these works to the IESMC)

Monitoring plan prior to construction

Semi-annual updates

BJ 11 Maritime Implement chance find procedure cultural MOS, S&SPA Chance find Personnel Prior to



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost /

Budget

for Activity

Timeline

/ Milestones

Note on

Specific

Loan

Conditions

PS8/ PR8

heritage heritage objects. Contractors procedure (CFP) documentation

and office cost

construction



Table 4: Pipeline

Item No.

Lender „s

Standard

Reference

Potential Impact /

Issue


Implementatio

n

Monitoring /

Key

Performance

indicators

Cost / Budget

for Activity Timeline

/ Milestones

Note on

Specific

Loan

Conditions

P1

PS1/

PR1

Compliance with

the conditions of

the decisions,

permits and

approvals and

Lender

requirements


Decision on Environmental Conditions to Consent for

the transmission high-pressure gas pipeline from the

Świnoujście LNG Terminal to the Gas Entry Point to the

System (Świnoujście – Szczecin), issued by Chief

Regional Officer for Environmental Protection in

Szczecin (RDOS), Szczecin, 12 January 2010,

Ref.: RDOŚ-32-WOOŚ.TŚ-6613/37-9/09/at.

Gaz-System

Environmental

Design

Requirements

specifications

Audit reports

Personnel and

office cost

Prior to and

during

construction

P 2

PR5/PS5

Land Issues

As per LNG Act, the Voivode after the Decision on the Location will retain independent property assessors to determine value of assets and level of compensation.

Information of the affected land owners and users about land acquisition process and compensation issues.

Preparation of a Brochure and distribution in the project area as per agreed SEP.

Gaz-System Information

Meetings held,

Information

Brochure

prepared and

distributed

Personnel and

office costs

Prior to

construction

P 3

PR4/PS4

Emergency

Response/ Public

Safety

Active participation in preparation of an Emergency Response Plan, which will be consulted with the relevant response organisations that are coordinated by Crisis Management Centres of the Districts (fire brigades, police, other relevant agencies) where the pipeline route passes.(Świnoujście, Międzyzdroje, Wolin, Stepnica, Goleniów ). For establishing such plans the local municipalities are responsible (in accordance with Polish regulations, inter alia Crisis Management

Gaz-System Emergency

Response Plan

agreed with

relevant public

organisations

Gaz System to

notify Lenders

Local

municipalities

To be agreed

with Local

municipalitie

s



Item No.

Lender „s

Standard

Reference

Potential Impact /

Issue


Implementatio

n

Monitoring /

Key

Performance

indicators

Cost / Budget

for Activity Timeline

/ Milestones

Note on

Specific

Loan

Conditions

Act) .

P 4

PS2/

PR2

Workers Health

and Safety

(Construction)

Preparation of work lot specific EHS plans, implementation of Permit-to-Work system.

Implementation

by contractor

Supervision by

Gaz-System‟s

Construction

supervisor

EHS system in

place,

supervisory

reports,

corrective action

records.

Personnel and

office costs

Prior to

Construction

P5

PS6/

PR6

Best practice

Construction

Technology

Horizontal Directional Drilling (HDD) will be used as specified in the decision on environmental conditions;

The IESMC will be allowed to monitor works.

Implementation

by contractor

Supervision by

Gaz-System‟s

Construction

supervisor

Plan for HDD

works in place

Personnel and

office costs

Prior to

Construction

P6

PS6/

PR6

Biodiversity Measures as specified in the Biodiversity Action Plan (BAP) shall be implemented.

Implementation

by contractor

Supervision by

Gaz-System‟s

Construction

supervisor



Table 5: Social Review

Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

Note on

Specific Loan

Conditions

SR1

PS5/ PR5

Impacts on Local Fishermen

A Focus Group Meeting with the fishery community (Fishermen / Fishery Group) will be held by the Project Sponsors in Autumn 2010 to discuss potential impacts of the Project on their operations and livelihood and corresponding mitigation measures as required.

PLNG, Gaz-System - CLO

Meeting protocol


Meeting Autumn 2010

After this meeting, commitments of the Project Sponsors and potential mitigation measures/compensation will be agreed in writing.

Potential cost of mitigation measures to be determined

Agreement within 6 months of meeting

SR2

PS5/ PR5

Impacts on Local Fishermen

During Project Implementation, in order to make fishermen aware of construction times, navigation constraints and the temporary closing of the dredge spoil disposal areas, the MOS will provide appropriate information to the fishery base of Swinoujscie before any such restrictions apply

MOS Information is distributed in writing and posted at the fishery base


Prior to the start and during construction



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

Note on

Specific Loan

Conditions

SR3

PS1/ PR1

Construction Jobs

As part of the information to local communities, the Project's CLO will organise information meetings in Swinoujsce for LNG terminal and connecting pipeline and subsequently along the transmitting pipeline in advance of construction commencement of works.

Representatives of the EPC Contractor to participate in these meetings to present the staffing concept and point out the potential for local recruitment (either directly to the EPC Contractor or through subcontractors) and provide information whom to contact with applications.

Once recruiting begins, the EPC contractor will make job advertisements available including in local newspapers and bulletin boards at the local communities.

The effects on local employment will be recorded. The CLO will analyse contractor records regarding actual employment of local people.

PLNG, Gaz-System - CLO

Meeting protocols

Job adverts posted


Prior to the start of construction

SR4

PS2/ PR2

Worker Health – construction

As part of the liaising with local medical services, the local clinics must be advised about the specific types of injuries stemming from cryogenic exposure and methane gas exposure and encourage them to be trained and equipped to treat such injuries.

PLNG

Meeting protocols

Correspondence from clinics confirming ability to handle such specific medical treatments


Prior to Construction of terminal



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

Note on

Specific Loan

Conditions

SR5

PS2/ PR2

Worker health – Operation stage

At least six months prior to the operation a suitable and sufficient First Aid Needs Assessment (FANA) is to be undertaken to assess the first aid provisions necessary for the commissioning and operational phases of the Project. The provisions should take account of the;

workplace hazards and risks

the nature of the undertaking and accidents associated with similar facilities

the size of the establishment and distribution of employees

the location of the establishment and the locations to which employees go in their workplace; and

Emergency facilities available in the local area.

Following the assessment all first aid provisions which have been identified from assessment, shall be put in place prior to commissioning.

PLNG Revised FANA


First Aid equipment costs

Prior to operation of terminal

SR6

PS4/ PR4&10

Community health and security

The EPC Contractor shall (i) adopt and implement a Security Plan during terminal construction; (ii) provide appropriate training to all contractors and subcontractors on the Security Plan and acceptable social behaviour as commensurate with the local conditions at the job site and Warszow community; (iii)

PLNG

Protocols of meetings, discussions; confirmation statement from PLNG

Contract language amended


Prior to the start of terminal construction



Item No.

Lender s

Standards

Reference

Potential

Impact /

Issue


Implementation

Monitoring / Key

Performance

indicators

Cost / Budget

for Activity

Timeline

/ Milestones

Note on

Specific Loan

Conditions

liaising with the local police and other community representatives in Warszow and Świnoujście if they propose any specific further safeguards in relation to the project and the construction workforce. Contractors shall adopt a Code of Conduct for workers

Lokalne Biuro Koordynacji Projektu ul. Brama Portowa 4 70-225 Szczecin CLO Sebastian Bawankiewicz GAZ-SYSTEM S.A. tel.+48 91 431 40 12 Fax: +48 91 434 08 75

e-mail: [email protected] http://www.polskielng.pl/

mailto:[email protected]://www.polskielng.pl/

Documents

LNG Terminal · The LNG terminal will allow the unloading of LNG imported via special LNG ships, storage and re-gasification of LNG at the terminal facility, and then transfer of