APPENDICES, VOLUME 3 OF 3

Environmental ImpactAssessmentWest African Gas Pipeline

June 2004

8-A8-B8-C

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AdministratorE981v. 4

APPENDICES, VOLUME 3 OF 3

Environmental ImpactAssessmentWest African Gas Pipeline

Prepared for

West African Pipeline Company

June 2004

8-A8-B8-C

Disclosure Locations

Venues at which the Environmental Impact Assessments, Appendices, and Resettlement Action Plans and Other Documents Supporting the West African Gas Pipeline Project have been Disclosed to the Public are as Follows:

Country Venue Location UNITED STATES World Bank Offices Washington, DC MIGA Washington, DC NIGERIA WAGP EA Rep Office Lagos Lagos State Ministry of Environment Lagos Ogun State Ministry of Environment Abeokuta Liaison Office Federal Ministry of Environment Lagos Liaison Office Federal Ministry of Environment Abeokuta Badagry Local Government Office Badagry Ado Odo Ota Local Government Office Ado Odo Ota Ifo Local Government Office Ifo Ogun State Ministry of Lands and Housing Abeokuta Lagos State Lands Bureau Lagos Federal Ministry of Environment Abuja TOGO WAGP EA Rep Office Lom Ministre de lEnvironnement et des Ressources Forestires Lom Gbetsogbe Palace Gbetsogbe Domocile du chef traditionnel Gbetsogbe Baguida Baguida Ministre de lnergie et des Ressources Hydrauliques Lom Ministry of Land Affairs Lom BENIN WAGP EA Rep Office Cotonou Documentation Center of the Ministry of Environment, of

Habitat and Urbanism (MEHU) Cotonou

Beninese Agency for Environment (ABE) Cotonou Documentation Center of Ministry of Mines, Energy and

Hydraulic (MMEH) Cotonou

Mayoralty of Abomey-Calavi Abomey-Calavi Mayoralty of Ouidah Ouidah Institute of Endogenous Development and Exchanges (IDEE) Ouidah Documentation Center of the University of Abomey-Calavi Abomey-Calavi GHANA WAGP EA Rep Office Tema EPA Library Accra Greater Accra Regional Coordinating Council Accra EPA Greater Accra Regional Office Amasaman Accra Metropolitan Assembly Accra Shama Ahanta East Metropolitan Assembly Sekondi EPA Central Regional Office Cape-Coast Central Regional Coordinating Council Cape-Coast Western Regional Coordinating Council Sekondi EPA Zonal Office Tema Tema Municipal Assembly Tema EPA Western Regional Office Sekondi Volta Regional Coordinating Council Ho EPA Volta Regional Office Ho Ghana EPA Accra

Table of Contents Acronyms and Abbreviations Authors and Contributions Acknowledgements

Executive Summary........................................................................................................-ES-1 Project Benefits...................................................................................................... ES-1 Project Description................................................................................................. ES-3

Pipeline and Facilities ................................................................................ ES-3 Construction............................................................................................... ES-5

Alternatives ............................................................................................................ ES-6 Baseline Information.............................................................................................. ES-7

Natural Environment.................................................................................. ES-7 Human Environment.................................................................................. ES-8

Impacts and Mitigation .......................................................................................... ES-9 Secondary and Cumulative Impacts......................................................... ES-12 Results...................................................................................................... ES-12

Management and Monitoring Plan....................................................................... ES-17 Summary and Conclusion .................................................................................... ES-17

Chapter 1 Introduction....................................................................................................... 1-1 1.1 Project Overview .......................................................................................... 1-1 1.2 Project Justification....................................................................................... 1-4

1.2.1 Global Perspective ............................................................................ 1-6 1.2.2 Regional Perspective......................................................................... 1-8 1.2.3 National and Local Perspective ...................................................... 1-12 1.2.4 Project Implementation................................................................... 1-17

1.3 Legal and Policy Framework ...................................................................... 1-18 1.3.1 Introduction..................................................................................... 1-18 1.3.2 International Legislation ................................................................. 1-21 1.3.3 Relationship of Project to World Bank Safeguard Policies

and OPIC Prohibitions. ................................................................... 1-21

Chapter 2 Project Description ........................................................................................... 2-1 2.1 General Layout and Physical Description..................................................... 2-1 2.2 Natural Gas Sources (Upstream of WAGP)............................................ 2-10 2.3 Natural Gas Consumption (Downstream of WAGP) .............................. 2-11 2.4 Design and Other Pre-construction Activities ............................................ 2-13 2.5 Facility Descriptions ................................................................................... 2-13

2.5.1 Alagbado Tee .............................................................................. 2-13 2.5.2 Onshore Pipeline in Nigeria............................................................ 2-20 2.5.3 Lagos Beach Compressor Station ................................................... 2-34 2.5.4 Offshore Pipeline and Shore Crossings .......................................... 2-46 2.5.5 R&M Stations and Onshore Pipeline Laterals ................................ 2-56 2.5.6 Ancillary Works (Concrete Weight-Coating Plant)........................ 2-74

2.6 Waste from Operations ............................................................................... 2-79

Table of Contents

June 2004 Regional Final Draft EIA Rev 1 ii

2.7 Operational Control and Safety Systems .................................................... 2-80 2.8 Remaining Uncertainties............................................................................. 2-80

Chapter 3 Project Alternatives .......................................................................................... 3-1 3.1 Introduction................................................................................................... 3-1 3.2 Project Alternatives....................................................................................... 3-2

3.2.1 World Bank Regional Energy Sector Project Alternatives............... 3-2 3.2.2 EIA Project-Level Alternatives......................................................... 3-3

3.3 World Bank Regional Energy Sector Alternatives Analysis ........................ 3-4 3.4 EIA Project-Level Alternatives Analysis...................................................... 3-6

3.4.1 No-Project Alternative ...................................................................... 3-9 3.4.2 The Proposed Project Alternative: Developing a Gas Pipeline

and Piping Gas from Nigeria to Benin, Togo, and Ghana ................ 3-9 3.4.3 Power Generation and Delivery Alternative: Developing Gas-

Powered Electricity Generating Stations in Nigeria, and Transmitting the Electrical Power to Benin, Ghana, and Togo ...... 3-10

3.4.4 Natural Gas Fuel Export Alternative: Converting the Gas to LNG or CNG and Exporting via Tanker or Road from Nigeria to Benin, Togo, and Ghana ................................................................. 3-11

3.4.5 Renewable Fuels Alternative: Meeting Electricity Generating Demands in Benin, Ghana, and Togo with Renewable Resources (Hydropower, Solar, Wind, Agrofuels) .......................................... 3-12

3.4.6 Project-Level Alternatives Rankings .............................................. 3-13 3.5 Overall Pipeline Routing Options............................................................... 3-18

3.5.1 Onshore Option............................................................................... 3-20 3.5.2 Offshore Option .............................................................................. 3-21 3.5.3 Onshore/Offshore Option Selected Overall Routing Option ....... 3-21 3.5.4 Comparison and Selection of Proposed Option .............................. 3-22

3.6 Conclusion .................................................................................................. 3-23

Chapter 4 Project Design Alternatives ............................................................................. 4-1 4.1 Introduction................................................................................................... 4-1 4.2 Evaluation Criteria for Alternatives.............................................................. 4-1 4.3 Routing Options from Existing Gas Transmission Network to Coastal Compressor Station................................................................................................... 4-8

4.3.1 Selection Criteria for Onshore Route from Alagbado Tee to Compressor Station Site................................................................................ 4-8 4.3.2 Onshore Routing Options within Nigeria ......................................... 4-8 4.3.3 Extending Pipeline Onshore for Gas Delivery to Benin................. 4-12

4.4 Onshore Lateral and R&M Station Alternatives......................................... 4-15 4.4.1 Onshore Lateral and R&M Station Alternatives in Benin .............. 4-15 4.4.2 Onshore Lateral Alternatives in Togo............................................. 4-23

4.5 Design Considerations ................................................................................ 4-23 4.5.1 Sizing of Offshore Pipeline and Midline Compression Facilities ..4-23 4.5.2 Future Compression Facilities at Takoradi ..................................... 4-27

4.6 Construction................................................................................................ 4-27 4.6.1 Pipeline Construction Methods....................................................... 4-27

Table of Contents

June 2004 Regional Final Draft EIA Rev 1 iii

4.6.2 Equipment Transport to Compressor Station.................................. 4-29 4.6.3 Ancillary Facility Construction....................................................... 4-30

4.7 Commissioning and Start-up....................................................................... 4-32 4.7.1 Treatment of Hydrotest Water prior to Discharge .......................... 4-32 4.7.2 Discharge of Hydrotest Water ........................................................ 4-32

4.8 Project Operations....................................................................................... 4-32 4.8.1 Liquid Storage Tanks...................................................................... 4-32 4.8.2 Waste Management......................................................................... 4-32 4.8.3 Sanitary Waste Water Disposal ...................................................... 4-33 4.8.4 Stormwater Management ................................................................ 4-33 4.8.5 Utilities............................................................................................ 4-33

Chapter 5 Existing Situation.............................................................................................. 5-1 5.1 Existing Environment and Resources ........................................................... 5-1

5.1.1 Onshore Environment ....................................................................... 5-5 5.1.2 Offshore Environment .................................................................... 5-45 5.1.3 Ecologically Sensitive Areas .......................................................... 5-66

5.2 Existing Socioeconomic Aspects................................................................ 5-66 5.2.1 Introduction on Data Sources and SIA Methodology..................... 5-66 5.2.2 Background and Geographic Detail................................................ 5-68 5.2.3 Macroeconomic Overview.............................................................. 5-70 5.2.4 Population and Demographics ........................................................ 5-71 5.2.5 Ethnic and Cultural Background..................................................... 5-72 5.2.6 Historical and Cultural Resources .................................................. 5-74 5.2.7 Infrastructure and Quality of Life ................................................... 5-75 5.2.8 Education ........................................................................................ 5-77 5.2.9 Land Tenure and Residential Ownership........................................ 5-78 5.2.10 Land and Water Use........................................................................ 5-79 5.2.11 Energy Consumption ...................................................................... 5-79 5.2.12 Microeconomic Situation................................................................ 5-80

5.3 Existing Public Health Situation................................................................. 5-86 5.3.2 Health Indicators............................................................................. 5-89 5.3.3 Food and Nutrition.......................................................................... 5-90

5.4 Existing Safety Situation............................................................................. 5-90 5.4.1 Overview......................................................................................... 5-90 5.4.2 Institutions Responsible for Health Care Delivery ......................... 5-91 5.4.3 Institutions Responsible for Fire Fighting ...................................... 5-92 5.4.4 Institutions Responsible for Disaster Management ........................ 5-94

5.5 Stakeholder Consultations .......................................................................... 5-95 5.6 Regulatory Oversight .................................................................................. 5-96

Chapter 6 Impact Assessment............................................................................................ 6-1 6.1 Introduction................................................................................................... 6-1 6.2 Project Activities and Affected Media.......................................................... 6-2

6.2.1 Project Activities............................................................................... 6-2 6.2.2 Affected Media ................................................................................. 6-3

6.3 Comprehensive Impacts Identification/Screening ........................................ 6-4

Table of Contents

June 2004 Regional Final Draft EIA Rev 1 iv

6.4 Impact Severity Assessment Methodology................................................... 6-4 6.4.1 Significance Criteria ......................................................................... 6-4 6.4.2 Likelihood Criteria............................................................................ 6-7 6.4.3 Severity Matrix and Conclusions...................................................... 6-8 6.4.4 Uncertainties ..................................................................................... 6-9

6.5 Beneficial Impacts ...................................................................................... 6-13 6.5.1 Beneficial Environmental Impacts.................................................. 6-14 6.5.2 Beneficial Socioeconomic Impacts................................................. 6-15 6.5.3 Community Development / Health and Safety Benefits................. 6-23

6.6 Potential Onshore Impacts .......................................................................... 6-26 6.6.1 Site Preparation and Construction .................................................. 6-26 6.6.2 Commissioning and Start-up........................................................... 6-56 6.6.3 Operations and Maintenance........................................................... 6-57 6.6.4 Decommissioning and Abandonment ............................................. 6-59

6.7 Potential Offshore Impacts ......................................................................... 6-60 6.7.1 Site Preparation and Construction .................................................. 6-60 6.7.2 Commissioning and Start-up........................................................... 6-67 6.7.3 Operations and Maintenance........................................................... 6-68 6.7.4 Decommissioning ........................................................................... 6-69

6.8 Emergency and Upset Conditions............................................................... 6-69 6.8.1 Controlled Gas Release................................................................... 6-69 6.8.2 Uncontrolled Gas Release............................................................... 6-70 6.8.3 Fire .................................................................................................. 6-74 6.8.4 Explosion ........................................................................................ 6-75 6.8.5 Offshore Fuel Spills ........................................................................ 6-77

6.9 Secondary and Cumulative Impacts............................................................ 6-78 6.9.1 Environmental Secondary Impacts ................................................. 6-78 6.9.2 Socioeconomic Secondary Impacts ................................................ 6-81 6.9.3 Upstream and Downstream Development Impacts......................... 6-81 6.9.4 Health and Safety Secondary Impacts ............................................ 6-93 6.9.5 Cumulative Impacts ........................................................................ 6-94

Chapter 7 Mitigation and Amelioration Measures.......................................................... 7-1 7.1 Introduction................................................................................................... 7-1 7.2 Required General Mitigation Measures ........................................................ 7-3 7.3 Required Specific Mitigation Measures........................................................ 7-3 7.4 Potential Mitigation Measures .................................................................... 7-24

7.4.1 Utilize Horizontal Directional Drilling for Wetland Crossings in Benin and Nigeria ....................................................................... 7-25

7.4.2 Utilize Horizontal Directional Drilling for Lagoon Crossing in Benin........................................................................................... 7-27

7.4.3 Perform the Shore Crossing from the North Side of the Lagos Lagoon Thus Avoiding the Barrier Island ...................................... 7-28

7.4.4 Replacement of Topsoil at R&M Station Site after Decommissioning ........................................................................... 7-29

7.4.5 Residual High Impacts from Onshore Construction in Nigeria...... 7-29

Table of Contents

June 2004 Regional Final Draft EIA Rev 1 v

Chapter 8 Health, Safety, and Environmental Management Plan................................. 8-1 8.1 Health, Safety, and Environmental Management System ............................ 8-3

8.1.1 Operational Controls......................................................................... 8-5 8.1.2 Change Management ...................................................................... 8-11 8.1.3 Biological and Cultural Resource Chance Finds ............................ 8-13

8.2 Monitoring .................................................................................................. 8-13 8.2.1 Performance/Implementation Monitoring ...................................... 8-13 8.2.2 Empirical Monitoring...................................................................... 8-14 8.2.3 Monitoring Oversight Responsibilities ........................................... 8-14

8.3 WAPCo Human Resources, Roles, Responsibilities, and Authority.......... 8-20 8.4 EPC Contractors.......................................................................................... 8-25 8.5 Government Regulatory Agencies.............................................................. 8-27 8.6 Financial Resources .................................................................................... 8-28 8.7 Institutional Strengthening and Capacity Building..................................... 8-29 8.8 Reporting..................................................................................................... 8-30 8.9 Health, Safety, and Environment Management Plan Sections ................... 8-31

8.9.1 Land Use ......................................................................................... 8-32 8.9.2 Topography, Geology, and Soils .................................................... 8-36 8.9.3 Habitats, Biological Resources, Water Resources, and Hydrology 8-41 8.9.4 Air Quality ...................................................................................... 8-49 8.9.5 Solid, Liquid, and Hazardous Waste............................................... 8-54 8.9.6 Cultural Conditions......................................................................... 8-58 8.9.7 Socioeconomic Conditions ............................................................. 8-62 8.9.8 Public and Worker Health and Safety............................................. 8-67 8.9.9 Emergency Preparedness and Response ......................................... 8-71

Chapter 9 Regional Conclusion ......................................................................................... 9-1

References

Appendices

Appendix 1-A: EIA Terms of Reference

Appendix 1-B: Nigeria Applicable Local and International Regulations

Appendix 2A-1: Air Pollution and Greenhouse Gas Emissions Analyses

Appendix 2A-2: Natural Gas Sources and Transmission Infrastructure (Upstream of WAGP)

Appendix 2-B: WAGP Waste Estimates

Appendix 2-C: Onshore-Offshore Commissioning Procedures and Specifications List

Appendix 2-D: Potential Hazardous Materials

Appendix 5-A: First Season EBS

Appendix 5-B: Second Season EBS

Appendix 5-C: SPI Study Report

Table of Contents

June 2004 Regional Final Draft EIA Rev 1 vi

Appendix 5-D: Stakeholder Consultations

Appendix 6-A: Anchor Handling

Appendix 6-B: Air Quality Impact Assessment

Appendix 6-C: Qualitative Risk Assessments

Appendix 7-A: Mitigation Measures for Baobab Tree in Tema

Appendix 7-B: HIV/AIDS Policy

Appendix 8-A: Project Execution Plan Chapter 15: HSE Plan

Appendix 8-B: Operational Controls

8B1.0 Tier 1: WAGP HSE Policy Statement 8B2.0 Tier 2: WAGP HSE Management System Procedures

8B2.1 WAGP External Communications Procedures (To Be Developed) 8B2.2 HES Training 8B2.3 HES Audit Protocol 8B2.4 WAGP Management of Change 8B2.5 WAGP Compliance and Permitting Plan

8B2.5.1 WAGP Project Authorizations 8B2.5.2 WAGP Pipelines Hydrotesting Discharge Ecotoxicity Testing Plan

(Rev A) 8B2.5.3 WAGP Waste Water Discharge Controls (To Be Developed) 8B2.5.4 WAGP Stormwater Management Plan 8B2.5.5 WAGP Air Emissions Management Procedure 8B2.5.6 WAGP Project Execution Plan Chapter 21: Operations Plan

8B2.6 WAGP Waste Management Plan 8B2.7 Emergency Response

8B2.7.1 WAGP Spill Prevention and Control Procedure 8B2.8 WAGP Habitat, Biological, Cultural Resource Management Procedures

8B 2.8.1 ROW Reinstatement Criteria 8B 2.8.2 Proposed Wetland PL Construction Methods Study 8B 2.8.3 WAGP Sea Turtle Nesting Protection Procedure 8B 2.8.4 WAGP Chance Finds and Archeological Salvage Procedure 8B 2.8.5 WAGP Anchor Handling 8B 2.8.6 WAGP Procedure for Preventing Salt Water Intrusion into Fresh

Water Lagoons and Creeks 8B2.9 Incident Investigation Procedure

8B3.0 WAGP Land Acquisition and Right of Way (ROW) Management Procedure 8B3.1 WAGP Resettlement Action Plan 8B3.2 WAGP ROW Access Policy

8B4.0 Risk Management 8B4.1 Onshore Pipeline and Facilities Design Basis 8B4.2 WAGP Environmental Design Basis 8B4.3 WAGP Loss Prevention Design Basis 8B4.4 Onshore-Offshore Technical Specifications List

8B5.0 WAGP Contractor Management Procedures

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June 2004 Regional Final Draft EIA Rev 1 vii

8B5.1 Exhibit F: HSE Standards 8B5.2 Exhibit N: WAGP Security Plan 8B5.3 Exhibit K: Drugs Standard-IFT

Appendix 8-C: Environmental and Social Advisory Panel Terms of Reference

Appendix 8-A

Project Execution Plan Chapter 15: HSE Plan West African Gas Pipeline

West African Gas Pipeline Project Execution Plan

Chapter 15-Health, Safety & Environment Management

System

TABLE OF CONTENTS

HSE MANAGEMENT SYSTEM OVERVIEW ................................................................................................ 3

STRATEGIC HSE FOCUS AREAS................................................................................................................... 5

INCIDENT FREE OPERATIONS .............................................................................................................................. 5 POLLUTION PREVENTION .................................................................................................................................... 5 EMERGENCY PREPAREDNESS & RESPONSE ......................................................................................................... 5 COMMUNITY AWARENESS & OUTREACH ............................................................................................................ 5 LEGISLATIVE & REGULATORY ADVOCACY......................................................................................................... 6 COMPLIANCE ASSURANCE .................................................................................................................................. 6 PROPERTY TRANSFER ......................................................................................................................................... 6

1 HSE MS ELEMENT-LEADERSHIP & PROJECT TEAM INVOLVEMENT.................................... 6

1.1 SYSTEM PRACTICES ...............................................................................................................................7

2 HSE MS ELEMENT-HSE POLICY & STRATEGIC OBJECTIVES................................................... 8

2.1 HSE POLICY STATEMENT ...................................................................................................................... 8 2.2 SYSTEM PRACTICES ...............................................................................................................................8

3 HSE MS ELEMENT-EVALUATION AND RISK MANAGEMENT.................................................... 8

3.1 SYSTEM PRACTICES ...............................................................................................................................8

4 HSE MS ELEMENT-PLANNING & RESOURCES ............................................................................... 9

4.1 LEGAL AND OTHER REQUIREMENTS........................................................................................................... 9 4.2 GOALS AND TARGETS & WORK PLANS .................................................................................................... 10 4.3 PROJECT TEAM ORGANIZATION, ROLES, AND RESPONSIBILITIES ............................................................ 10 4.4 HSE MANAGEMENT PROGRAMS .............................................................................................................. 11

4.4.1 Health Management Programs....................................................................................................... 11 4.4.2 Safety Management Programs........................................................................................................ 11 4.4.3 Environmental Management Programs.......................................................................................... 12 4.4.4 Contractor HSE Program(s)........................................................................................................... 12

5 HSE MS ELEMENT-IMPLEMENT AND OPERATE ......................................................................... 13

5.1 PROJECT HSE GUIDELINES, PROCEDURES AND OPERATIONAL CONTROLS .......................................... 13 5.2 DOCUMENTATION AND RECORD KEEPING ........................................................................................... 14 5.3 TRAINING & COMPETENCE .................................................................................................................. 14 5.4 COMMUNICATION AND AWARENESS .................................................................................................... 14 5.5 EMERGENCY PREPAREDNESS & RESPONSE .......................................................................................... 15

6 HSE MS ELEMENT-MONITOR AND REVIEW................................................................................. 15

6.1 PERFORMANCE & PROCESS MEASURES ............................................................................................... 15 6.2 AUDITS ................................................................................................................................................ 16 6.3 MANAGEMENT REVIEWS...................................................................................................................... 16 6.4 INCIDENT INVESTIGATION, NON-CONFORMANCE AND CORRECTIVE ACTION....................................... 16

7 REFERENCES .......................................................................................................................................... 17

HSE MANAGEMENT SYSTEM OVERVIEW

Purpose

The West African Gas Pipeline facilities will be constructed and operated in Nigeria, Benin, Togo and Ghana. This Health, Safety and Environmental (HSE) Plan provides a framework for the WAGP HSE Management System.

The Health, Safety and Environment Management System is intended to be used by WAGP personnel and design, fabrication and construction contractors. It provides guidance on how to manage and continually improve the HSE program adopted by the Project Team. It also meets the following international HSE Standards and Guidelines:

- International Oil & Gas Producers (OGP, formerly E&P Forum) Report No. 6.36/210,

Guidelines for the Development and Application of Health, Safety and Environmental Management Systems

- International Standards Organization (ISO) 14001, Environmental Management System Specification

- American Petroleum Institute (API) 9100, Model Environmental, Health & Safety Management System and Guidance Document

It should be recognised that this HSE Plan is a living document, which will be updated and re-issued as the Project develops through its defined phases including detailed engineering, construction, commissioning, and ultimately WAPCo operations.

HSE Management System Model

WAGP has adopted the following model for HSE Management:

HSE Issues Identification & Evaluation- EIA- Process Safety Management

Risk Management-Probability-Consequence

RiskEvaluation

&Assessment

Policy&Strategic Objectives

System Audits

Management Review

Measures

Incident InvestigationNonconformance &Corrective Action

Monitor&

Review

Procedures & ProcessesDocumentationTraining & CompetenceCommunication & AwarenessEmergency Preparedness& Response

Implement&

Operate

Leadership Support & Participation

Project Team Involvement

3rd Party Services

Leadership & Project Team Involvement

Legal and Other Requirements

Goals, Targets, Resources & Plans

Roles & Responsibilities

3rd Party Services

Planning&

Resources

Management Programs

The HSE management system will effectively control HSE activities and includes the following six elements: 1.0 Leadership and Project Team Involvement Addresses managements commitment to the project HSE policy statement, Project Team participation and ownership, and the HSE culture essential to success.

2.0 Policy and Strategic Objectives Addresses the projects HSE intentions, principles, and high-level objectives.

3.0 Evaluation and Risk Management Addresses identification and evaluation of HSE issues and risks for operations and services, and the development and decision making associated with risk-reduction and management measures. See also PEP Chapter 19

4.0 Planning and Resources Addresses the setting of HSE goals and targets and establishment of resourced work plans to achieve them. Components within this element of the HSE Management System include:

4.1 Legal and Other Requirements See also Chapter 17 Compliance Assurance/Permitting Plan

4.2 Goals and Targets 4.3 Project Team Organization, Roles, Responsibilities and Work Plans 4.4 HSE Management Programs

including integration of Contractor HSE Programs

5.0 Implement and Operate Addresses common program requirements necessary to operate in control and to implement defined system and process improvement changes. Specific elements of this section of the HSE Management System include:

5.1 Procedures, Processes and Operational Controls 5.2 Documentation and Record Keeping 5.3 Training and Competence 5.4 Communication and Awareness 5.5 Emergency Preparedness and Response

6.0 Monitor and Review Addresses HSE performance monitoring and periodic assessment of system performance, effectiveness and suitability, including:

6.1 HSE Performance Measurement, including leading indicator metrics. 6.2 HSE Management System Audits 6.3 Management Review of the HSE Management System 6.4 Incident Investigation, Non-conformance and Corrective Action Processes

The HSE Management System and its actions are intended to apply, as appropriate, at all levels of the organization and this wording is frequently used in the text. This ensures all levels within the Project Team, Sponsors and contractors team have both cyclical and catchball dialogue. It aligns the organizations direction from management to the Project Team members. It also stimulates participation and ownership at all levels and is intended to apply across all of the WAGP Strategic Areas of Focus as detailed below.

STRATEGIC HSE FOCUS AREAS

Incident Free Operations

The WAGP Project is dedicated to continuous improvement toward incident free operation, because incidents of any kind can result in injuries, illness, environmental damage, adverse public impact and opinion, government enforcement actions and lower profits. Commitment to this effort should lead to the long-term viability of WAGP operations and to a competitive advantage. Prevention of incidents through continuous Quality Improvement and Process Hazards/Safety Management (PHM/PSM) initiatives requires implementing risk-management strategies that involve dealing with design, construction, start-up, operation, inspection, maintenance, transportation, modification of facilities and decommissioning. These plans will be detailed in the project Site Specific HSE Management Plans and Loss Prevention guidelines.

Pollution Prevention Pollution prevention is a process to reduce the environmental and health impacts of emissions and releases from WAGP construction, facilities, operations and products. It includes applying the principles of risk management to achieve on-going reductions of releases of contaminants into the air, water (both surface and ground water) or on land (wastes). Specific guidance on how to meet the intent of this section will be included in the project Waste Management Plan. The scope of the Waste Management Plan will include a cradle to grave approach to unavoidable waste generation that includes an assessment of 3rd Party waste storage, transportation, recycling, treatment and/or disposals facilities.

Emergency Preparedness & Response

Emergency Preparedness and Response involves assessing the hazards and risks of incidents; developing a plan for managing those hazards and risks; communicating relevant information to Project Team members, contractors, government agencies and the public; conducting emergency response exercises, and responding immediately and appropriately to incidents. Well-prepared and tested Emergency Preparedness and Response plans give Project Team members, contractors and the community confidence that each facility has an emergency-response process to respond rapidly and effectively to emergencies, including transportation and distribution and other off-site emergencies. Emergency response plans will be included in the Site Specific HSE Management Plans for design, fabrication and construction locations.

Community Awareness & Outreach

The goal of Community Awareness and Outreach is to foster understanding and a two way dialogue between the WAGP Project and the external stakeholders on issues related to health, environment and safety. The intent is to ensure that WAGP locations and WAGP operations, especially those that manufacture, process, use, distribute or store potentially hazardous materials, initiate and maintain a community outreach program to openly communicate relevant, useful information responsive to the public's

questions and concerns. The primary objective is to enhance WAGPs reputation. Another objective is to promote an open, ongoing dialogue with Project Team members and the community and to provide information on subjects such as waste minimization, emission reduction, health effects of chemicals and efforts to ensure the safe transport of potentially hazardous materials. Office-based locations should also develop programs appropriate for their size and the local community. Specific guidance on how to meet the intent of this section will be developed in the project External Affairs Community Relations Plan (See PEP Chapter 11).

Legislative & Regulatory Advocacy The goal of Legislative and Regulatory Advocacy for HSE is to promote timely, reasonable and cost-effective health, safety and environmental legislation and regulation, harmonized to the extent possible across the 4 countries associated with WAGP. Through effective legislative and regulatory advocacy, including the identification of emerging issues, WAGP can, over the long term, establish further credibility with the public and improve its competitive position. Specific guidance on how to meet the intent of this section will be developed through Concession Agreement negotiations and in the project Compliance Assurance/Permitting Plan (PEP Chapter 17).

Compliance Assurance Compliance with government laws and regulations , Sponsor HSE policies and all other relevant HSE policies is a critical management responsibility. Full compliance requires certain proactive processes and procedures for ensuring that all compliance requirements are recognized, implemented and are periodically audited. Specific guidance on how to meet the intent of this section will be developed in the project Compliance Assurance/Permitting Plan (PEP Chapter 17).

Property Transfer WAGP must assess and work to resolve potential safety, fire, health and environmental liabilities prior to the sale, lease, transfer, purchase or other transaction involving rights to real property. Such potential liabilities may be created by past operations, practices or handling of products, wastes or hazardous materials. There are many different types of property transactions whose environmental aspects could have economic impacts on the WAGP Project. They include sales, acquisitions, leases, foreclosures and condemnations, as well as transfers of real property rights involving easements and rights of way, surface use rights, condemnation, abandonment of leased property, access agreements, leasing of storage or staging space and other types of transactions. Specific guidance on how to meet the intent of this section will be included in the project Risk Management plan.

1 HSE MS Element-Leadership & Project Team Involvement

Leadership at all levels is the key to providing for and improving HSE performance. WAGP Management will provide strong, visible leadership participation and commitment and ensure this commitment is translated into the necessary resources

to: develop, operate and maintain the HSE Management System and, to meet the policy and strategic objectives.

1.1 System Practices System practices are tactical methods and best practices adopted by WAGP that are proven as critical HSE success factors for this HSE-MS Element. 1.1.1 Project management will be knowledgeable in the HSE management system and

will communicate their HSE vision and expectations towards continuous improvement in HSE performance. This commitment will be reaffirmed annually and at the beginning of each project phase. This commitment will be expressed in written form through memo, email or newsletter article and also expressed verbally during project town hall meetings or safety meetings.

1.1.2 Project management will ensure that HSE is integrated into processes at all levels

of the organization. HSE issues will be included in the Project Execution Planning. HSE issues will be discussed at all management meetings along with project cost and schedule updates.

1.1.3 Project management will demonstrate commitment through active and visible

participation in key HSE Management System activities (Policy & Strategic Objectives, Planning & Resources, Monitor & Review) and in the implementation of relevant HSE work processes. Management will track this commitment by monitoring its participation in HSE Leadership Events1. Project management will participate in regularly scheduled HSE meetings and HSE tours of the fabrication and construction sites. Project management will participate in conducting internal HSE audits, regularly scheduled review sessions and incident investigations as defined in Section 6 of this document.

1.1.4 Project management supports the HSE Management System and work processes

by allocating adequate resources to implement, sustain and improve. Project management will define, document and communicate specific HSE roles and responsibilities and authorities in order to establish, implement, maintain and report progress on the HSE Management System. See Section 4.2 for details.

1.1.5 Project management fosters broad Project Team and contractor involvement and

participation in a) the HSE Management System and related work processes, and b) sharing and transfer of HSE best practices. The Project Management Team (PMT) will meet at regularly scheduled intervals to set goals, objectives and respond to HSE issues on the Project. See Section 4.3.2.

1.1.6 Individual and team contributions to HSE performance will be recognized, rewarded and considered during Project Team and unit performance evaluations, and Project Team members will be held accountable for job performance. HSE performance awards will be personally presented by Project management.

1.1.7 Project Team and contractor suggestions for improvement in the HSE program

and related work processes will be actively solicited. The suggestion system will be anonymous and accessible at all work sites. Project Team members and contractors will receive timely feedback on suggestions.

2 HSE MS Element-HSE Policy & Strategic Objectives

2.1 HSE Policy Statement

Scope - The WAGP HSE Policy2 applies to Project Team members and contractors in all phases of the Project and all work locations, including design, fabrication, construction and start-up activities. Responsibilities Project Team members and contractors are responsible for compliance with all WAGP policies, procedures, practices and laws applicable to the assigned duties and responsibilities. Accordingly, Project Team members who are unsure of the legal or regulatory implications of their actions will be responsible for seeking management or supervisory guidance. Project managers have the primary responsibility for complying with this policy within their respective function and authority limits. Project managers will communicate this policy to their respective Project Team members and will establish programs as necessary to ensure its implementation.

2.2 System Practices

2.21. The Project HSE policy shall be signed by the Project Management Team. 2.2.2 The Project HSE policy will be communicated to all Project Team members and

contractors, available to the public and posted visibly on project bulletin board(s) and website(s).

3 HSE MS Element-EVALUATION AND RISK MANAGEMENT This HSE MS element addresses the identification of HSE issues, hazards, threats and opportunities, and evaluation of their risk for all activities, and services for all levels of the project organization. Strategic issues evaluation and risk management provides a means for the project to comprehensively identify and prioritize issues for further evaluation and action, and provides input on potential work items to the Planning & Resources element of the system. See also PEP Chapter 19

3.1 System Practices 3.1.1 WAGP will identify and evaluate the potential impact of strategic-level HSE

issues, threats and opportunities using methods such as past performance and environmental impact assessments. These will be incorporated in an HSE Objectives Analysis3 performed in Phase 3A of the project and continually updated as new information is made available .

3.1.2 WAGP will utilize a systematic process for identifying, and periodically re-

evaluating, potential HSE risks or concerns and for evaluating solutions. It will include application of risk management processes to:

- systematically identify HSE concerns or hazards which may arise from operations, products or services

- evaluate (assess) and prioritize the risks and effects from the identified concerns and hazards which takes into account the consequences, existing safeguards and likelihood (probability) of the impacts,

- generate a range of possible risk reduction alternatives (mitigation and prevention). Utilize a hierarchy of controls that emphasizes reduction of likelihood of occurrence first and reduction of impact second,

- make consistent decisions on what to do among different risks and mitigation alternatives which considers the impacts to people, the environment, public opinion, and assets and financial objectives, and the costs (i.e. cost-benefit analysis, decision analysis),

- follow-up reviews to ensure that solutions have been implemented and are effective in mitigating the risk.

3.1.3 Specific risk evaluations are defined further in the Strategic Areas of Focus

section above and will include at a minimum: Process Hazards Analyses (PHA) during project design, using a method

approved by API RP 14J. Quantitative modelling of potential explosions and toxic releases as

appropriate . Evaluation of potential HSE impact of wastes, releases and products to

Project Team members, contractors, the community and environment which is done as part of the project Environmental Impact Assessment.

Risk assessments necessary to establish an environmental baseline for all sale, lease, purchase or other transactions involving rights to real property.

4 HSE MS Element-PLANNING & RESOURCES Using the results of the work items and issues identified for potential action in the previous phases, the project will establish goals and targets and provide the plans, resources, and organizational structure to achieve them. Legal and other requirements will be determined and established as givens in developing work plans and processes. Roles and responsibilities will be clearly defined and communicated. HSE planning will be integrated with the project execution planning process to ensure alignment with overall project objectives and ensure broad commitment of responsibilities and resources.

4.1 Legal and Other Requirements The Project Team will identify and be knowledgeable in the HSE requirements of the 4 countries associated with the West African Gas Pipeline. Compliance with these HSE requirements will be established as givens and integrated into project planning. Detailed Compliance Assurance/Permitting plans will be developed and integrated into the Project Schedule to ensure compliance and alignment with project timing objectives. International standards and guidelines, where appropriate, will be used where there is an absence of regional standards and guidelines or where country requirements can be enhanced. HSE legal requirements identified to date can be found in Chapter 17 of the PEP (Compliance Assurance/Permitting Plan)

4.2 Goals and Targets & Work Plans The Project Team shall develop documented HSE goals, targets, and work plans

which: - establish clear HSE goals and targets, with associated work activities, and with

related measures, (e.g. Total Recordable Incident Rate, Lost Work Day Incident Rate, number of spills, cost of incidents per work hour, etc.)

- designates responsibilities for achieving goals and targets at each relevant function and level of the project organization (see Section 4.3 below),

- sets the time-frame by which they are to be achieved, - sets resources required and the organization structure to implement operate

and sustain the HSE Management System to meet goals and targets and execute the approved work plan (resources include human resources and specialized skills, technology and financial resources),

- integrates HSE work planning activities with the project execution planning process,

- amends HSE goals and targets, and work plans as necessary to adjust for new developments and projects; new or modified activities, new products or services; and newly recognized HSE issues and concerns

A detailed work plan for the HSE Management System is provided in the Appendix.

4.3 Project Team Organization, Roles, and Responsibilities

4.3.1 Roles, responsibilities and authorities will be defined, documented and communicated for all levels of the project organization, in order to facilitate effective HSE system and process management. Project Team members will have written HSE responsibilities and have the authority, accountability and resources to fulfil them. A Project Team HSE Matrix4 of roles and responsibilities will be established and maintained.

4.3.2 The WAGP Project Manager is responsible for ensuring:

- Ensuring the HSE management system requirements are established, implemented and sustained in accordance with these requirements.

- Reporting on the performance of the HSE management system to the Sponsor Management Committee (SMC) for review and as a basis for improvement of the system.

4.3.3 The Project Team will meet regularly to carry out the following roles &

responsibilities: Build commitment to the ZERO LTA vision for all stakeholders. Endorse this project HSE Management Plan Endorse the Contractor Safety Management Plans to be developed by each

Contractor which covers the Contractor and its subcontractors of any tier. Endorse and ensure communication of the safety objectives, goals, targets. Monitor compliance with the HSE Management Plan Review HSE Management Plan initiatives, review their effectiveness, and

recommend upgrades/changes as necessary. Establish guidelines for proper reporting of all Project HSE statistics Encourage management commitment to actions supporting goals. Discuss incidents, near misses, and corrective actions taken to mitigate

concerns and to minimize chance of reoccurrence, and recommend corrective actions.

4.3.4 The responsibilities of the Contractors are to:

Prepare HSE plans covering individual scope of work activities, and integrate these plans with Project Team efforts, particularly in the Strategic Focus Areas listed above

Implement HSE plans and contractual commitments Report HSE incidents and submit periodic statistic reports As appropriate help develop and participate in HSE Committees at the

management and field level Evaluate and implement the HSE Committee recommendations Verify that subcontractors HSE plans are adequate See Section 4.4.4 for contractor HSE Management Program expectations.

4.3.5 The roles defined should not reduce the responsibility of Contractors or WAGP line management in the program. The organizational structure and allocation of responsibilities should reflect the responsibility of line managers at all levels for developing and sustaining the HSE Management System in their particular areas.

4.4 HSE Management Programs Specific Health, Safety and/or Environmental programs (described below) will be developed to assist the Project Team in meeting the goals and objectives established for the following WAGP Strategic Areas of HSE Focus, including the Project Team groups that will have the primary role in implementation.

- Incident Free Operations (Engineering/Construction and Operations) - Pollution Prevention (Engineering/Construction and Operations) - Emergency Preparedness & Response

(Engineering/Construction and Operations) - Community Awareness & Outreach (External Affairs) - Legislative & Regulatory Advocacy

(Commercial Development and External Affairs) - Compliance Assurance (All groups) - Property Transfer (Engineering/Construction)

4.4.1 Health Management Programs Health Management Programs identified to date include: - Medical Protection Program

Including identification of infectious diseases and processes for outbreak notification, personnel protection and emergency medical services.

- Industrial Hygiene

4.4.2 Safety Management Programs The following Safety Management Programs and Best Practices have been identified as critical components of the Incident Free Operations Focus Area and will be developed in co-ordination with the Contractor HSE Program described in Section 4.4.4 - Security Planning (See also PEP Chapter 18) - Stop Work for Safety - Drug and Alcohol Program - Fitness for Duty Program

- Ergonomics - JSA-Job Safety Analysis - Constructability Analysis (see also Section 3 Risk Management) - Incentive Programs (as appropriate) - SID-Safety in Design - Site Safety Councils (as appropriate) The ChevronTexaco Safety VIP (Value Improving Practice) will be used as a tool to further develop the IFO components described above, ultimately leading to the development of an integrated Project Safety Management Plan

4.4.3 Environmental Management Programs Pollution Prevention is a Strategic Area of Focus for the Project Team, and Waste Minimization and Management Plans will be developed. The majority of Environmental Management Plan components, however, will be developed consistent with Environmental Management Plan requirements associated with the Environmental Impact Assessment processes within the 4 countries and with input from other stakeholders.

4.4.4 Contractor HSE Program(s)

The WAGP Contracting Plan and Program will establish HSE terms and conditions5,6 that have equal weight with cost and schedule commitments. Contractors will set and enforce safety and environmental goals and will be responsible for all actions associated with work being conducted on behalf of WAGP. Furthermore, contractors will be expected to have comprehensive programs in place that will be integrated with Project programs, particularly in the areas of Incident Free Operations, Pollution Prevention, Community Awareness/Outreach and Emergency Preparedness and Response.

More specifically, the contracting process will include the following elements, as appropriate to the activitys risk and WAGP exposure, and as allowed by the contractual relationship:

- assessing job risk, - contractor performance and risk evaluation, - pre-qualification and selection7 - pre-job planning, - orientation & assurance of adequate training, - mutual communication of hazards, needs and requirements, - monitoring performance and periodic review - incident investigation

The HSE plans of the Contractors should include a written, formal program that includes the following:

Stated HSE policy, including statements identifying management commitment to safety, environmental leadership and compliance

Emergency response and evacuation requirements including fires, injuries, spills, severe weather, medivac, and security incidents

A process to report accidents, near misses, and non-compliance issues, Designated HSE Representatives at each job site who are responsible for all

safety related activities Defined HSE program goals/milestones for Project

Enforcement policy/accountability A description of each employees safety related responsibilities HSE training requirements, program and documentation methods Job site supervisory orientation program Employee orientation program Hazard communication program Personal protective equipment training and documentation methods Provisions for periodic informal and documented formal HSE meetings. HSE suggestion system aimed toward improving HSE performance Written HSE incentive program Craft specific written safe practice code Drug and alcohol testing program

Prior to mobilization, contractors and project team personnel will review the elements described above via pre-job checklists8, perform pre-job Job Safety Analyses (JSA) and conduct field inspections and audits to ensure incident free operations. The Project Team will implement a process to ensure that contractors authorized to act on behalf of WAGP (agents) understand and comply with relevant WAGP HSE policies and procedures. This process will include but not be limited to the following:

- Review of the agents HSE policy, - Contract forms contain language to carry out the process, - Audits of agent performance to check compliance with relevant WAGP policy

and procedures,

Procedures will exist for the agent to freely report existing or potential compliance problems to the WAGP.

5 HSE MS Element-IMPLEMENT AND OPERATE HSE operational and improvement work plans and management programs- developed MS Element 4 - are implemented here. The purpose of this HSE MS Element is to adequately support and control operational work activities and processes to provide for consistent and quality performance. The processes addressed include procedures, processes and operational controls, documentation/record keeping, training, general program communication .

5.1 Project HSE Guidelines, Procedures and Operational Controls

The project will identify and document those operations and activities, which if not followed, could lead to HSE incidents or non-compliance events. The project will write appropriate procedures and guidelines to ensure Project Team members at all levels of the organization can perform these operations and activities reliably and consistently. At a minimum these guidelines will include:

- Loss Prevention Guidelines (Including process safety management, and fire protection design guidance)

- HSE Risk Management Plans (Including HSE risk identification, assessment and mitigation)

- Environmental Design Guidelines (Including air, water, waste and groundwater environmental standards and waste management plans)

- Compliance Assurance/Permitting Plans (Including environmental impact analysis, greenhouse gas analysis, compliance monitoring)

- Site specific HSE Management Plans (Including design, fabrication and construction safe work practices). Where appropriate co-ordination with existing CNL procedures for fire, explosion, medivac, spill and security incidents will be encouraged)

- Community Awareness and Outreach Communication Plan (Including co-ordination with the Project External Affairs Group to promote outreach efforts with external stakeholders-See PEP Chapter 11)

The Project Team will maintain a Procedures Compendium including a To-Be-Developed Procedures Task List9.

5.2 Documentation and Record Keeping

5.2.1 A system for documentation and records will be established and maintained in order to demonstrate the extent of compliance with the Policy and the HSE Management System requirements and to record the extent to which planned goals and targets and performance criteria have been met.

5.2.2 The retention of documentation and records will be established and recorded, and

procedures will be maintained regarding their availability, confidentiality and destruction.

5.2.3 To the extent possible, the HSE documentation and records system will be

consistent with the HSE Management System hierarchy and numbering scheme10 for ease of filing and retrieval.

5.3 Training & Competence 5.3.1 A process will be in place to ensure Project Team Members have the skills and

knowledge to perform their jobs competently - in an incident free manner and in compliance with all applicable laws, regulations, WAGP policies and other requirements. This process will include the following attributes:

- training requirements and frequency, including initial (orientation) and

refresher training, are identified and periodically reviewed for each job (i.e., a needs assessment). The COPI Wilcrest Training Matrix11 will be followed for the Houston based Project Team members and a West African Training Matrix12 will be developed for Project Team members based in the region.

- a record of all training provided. - a process is in place and responsibilities defined to ensure required training is

completed. - training programs are documented and training materials are updated in each

Project phase 5.3.2 WAGP, and later WAPCo will develop and maintain a job selection process to

ensure that those selected for defined HSE-sensitive jobs (including changes and temporary assignments) have the knowledge, skills, performance history, abilities and demonstrated behaviors to allow them to conduct their activities in an incident free manner, in compliance with applicable laws, regulations and WAGP policies and requirements.

5.4 Communication and Awareness In addition to the communication of HSE Policy (Section 1.1.7):

5.4.1 Communication of HSE best practices13 will be encouraged with the behavioral

intent of shamelessly stealing ideas and processes from any sources that could lead to incident free operations.

5.4.2 Communications with external stakeholders, particularly the communities in which

we will operate, is a strategic area of focus and is discussed in more detail in WAGP Strategic Areas of Focus section above and in the External Affairs Section of the Project Execution Plan (Chapter 11). Internal communications processes will be established to support the External Affairs plans and integrate efforts between External Affairs, HSE, and Engineering. External Affairs plans will also be integrated with the Stakeholder Consultations component of the Environmental Impact Assessment.

5.5 Emergency Preparedness & Response 5.5.1 Emergency Preparedness & Response is a Strategic Area of Focus and is

discussed in terms of objectives and development processes in WAGP Strategic Areas of Focus section above. Specific WAGP Emergency Preparedness & Response processes and programs identified to date include: - Emergency Notification Procedures for significant medical, security and

environmental release situations (completed) - Identification of Emergency Medical Resources (completed) - Co-ordination of Emergency Response resources within the region, particularly

CNL (ongoing) - Crisis Management Plan development (ongoing)

All Emergency Preparedness and Response processes and programs will include components to test and evaluate our readiness for significant events.

6 HSE MS Element-MONITOR AND REVIEW Regular joint monitoring, by the Project Team and Contractors, of goals and targets, plans and performance including an array of measures/metrics, checks and audits, and regular system review is essential in ensuring that the HSE management system and HSE performance, is being sustained and continually improved. Incident investigation, although an after-the-fact exercise, can also identify opportunities for improvement. Follow up and close out of management review, incident investigation or audit recommendations, including accountability, is essential in ensuring that improvements are being made. Enhancements and changes identified will be used to develop future policy, strategic direction, goals and objectives and work plans.

6.1 Performance & Process Measures 6.1.1 WAGP will establish and maintain appropriate measures to regularly monitor

aspects of HSE performance. These measures will include monitoring progress on goals and targets, and on work plans and other characteristics of its operations and activities, including proactive system, process and leading indicator measures, end of pipe (reactive) performance measures and HSE financial measures (i.e., cost of incidents).

6.1.2 Processes to manage legally required monitoring will be developed consistent with country specific requirements and/or through the development of the Environmental Management Plan in the EIA process (see also PEP Chapter 16).

6.1.3 Key HSE performance measures will be reviewed on a regular basis with management to monitor real-time HSE system and process performance.

6.1.4 The management review process will include follow-up provisions to ensure that

solutions have been implemented and are effective.

6.2 Audits 6.2.1 The project will perform at least one internal audit of the HSE management system

during each Project phase to ensure the system conforms to these requirements (implemented and maintained) and is suitable and effective for meeting goals and targets.

6.2.2 Audit procedures will include audit scope, frequency, business areas,

methodologies, auditor competency and responsibilities for conducting system audits. It will cover all aspects of management system requirements and the extent to which these are integrated into the projects execution planning. They will include procedures and protocols for documenting, reporting, distributing and control of system audit reports. Written checklists14 should be used for audits.

6.2.3 HSE Management System audits will be analyzed and addressed in a timely

manner to correct gaps in the system 6.2.4 System findings will be communicated to and reviewed with management. 6.2.5 There will be a system for tracking and reviewing the status of audit

recommendations.

6.3 Management Reviews 6.3.1 Project management will at least annually review the management system and its

performance to ensure its continuing suitability and effectiveness. The review shall be documented.

6.3.2 The management review will address the possible need for changes to policy, objectives and other elements of the management system in the light of performance measures, audit results, changing environmental circumstances and the need for improvement.

6.3.3 Management roles and responsibilities for addressing and monitoring the status of

review recommendations will be assigned and a process will be in place to ensure resolution of findings from the reviews and oversight for follow-up

6.4 Incident Investigation, Non-conformance and Corrective Action 6.4.1 The Project will have Incident Reporting and Incident Investigation procedures.

Thresholds for increasing levels of investigation, depending on the severity of the incident, or the potential for the incident to have a significant HSE impact will be included in the procedures.

6.4.2 Project Management will require prompt incident investigation and will provide the

resources necessary for investigation, consistent with the degree of incident

impact or potential impact. Outside or independent investigations will be conducted at Project Management discretion.

6.4.3 Project Management will promptly review the results of incident investigations and

address the possible need for changes to policy, objectives and other elements of the management system in the light of the investigation results, changing HSE circumstances and the need for improvement.

6.4.4 Management roles and responsibilities for addressing and monitoring the status of

investigation recommendations will be assigned and a process will be in place to ensure resolution of findings from the reviews and oversight for follow-up

7 References

REFERENCE NUMBER

REFERENCE HSE MS PLAN CROSS REFERENCE

1 WAGP Leadership Events Tracking Sections 1, 6.1 2 WAGP HSE Policy Section 2 3 WAGP HSE Objectives Analysis Section 3 4 Safety VIP Roles and Responsibilities Section 4.3 5, 6 Typical Contract Exhibit D and Exhibit E Section 4.4 7 Example Pre-Qualification Questionnaire Section 4.4.4 8 Example Pre-Job Checklist

Section 4.4.4

9 2001 HSE Procedures Task List.

Section 5.1

10 HSE Electronic File System Section 5.2 11 COPI Wilcrest Training Matrix Section 5.3 12 West African Training Matrix

(to be developed) Section 5.3

13 ChevronTexaco PRC HSE Lessons Learned Website

Section 5.4

14 Audit Checklists WAGP CPDEP Road Map PEP Assistant Module-Safety COPI HSE Supplemental Checklist Incident Free Operations Pollution Prevention Emergency Preparedness

Section 6.2

Note that the last 3 audit checklists are subject to change as ChevronTexaco evolves its Operational Excellence processes (4+1 initiative).

Appendix 8-B Environmental Management Plan

Operational Controls West African Gas Pipeline

Appendix 8-B 8-1.0 WAGP HSE Policy Statement

West African Gas Pipeline

e

HHSSEE PPOOLLIICCYY SSTTAATTEEMMEENNTT

The policy of the West African Gas Pipeline Project Team is to conduct its business in a socially

responsible and ethical manner that is intended to ensure safety and protect health and the

environment. Our intent is to be a leader within the industry and in the West African sub-region,

demonstrated by Incident Free Operations. To that end, the WAGP Project Team will:

Integrate safety, health and environmental protection into every aspect of its business activities through comprehensive HSE Management systems & processes;

Comply with all safety, health and environmental laws or regulations without regard to the

degree of enforcement, subject to the harmonized regime; Encourage team members to initiate and maintain an open dialogue within the Project Team

and with all stakeholders on safety, health, and environmental matters, in addition to recognizing and responding as appropriate to stakeholder concerns;

Prudently manage emissions and discharges and eliminate unnecessary waste generation Be prepared for any emergency and mitigate incidents quickly and appropriately. The primary vehicles that the Project will use to meet these objectives are an Environmental Impact

Assessment and a Health, Safety and Environment Management System. Specific objectives

include:

Incident free operations; International recognition as an industry leader in managing health, safety, and environmental

issues associated with pipeline construction and operations, resulting in no project delays due to permitting, community or non-governmental issues;

Regional recognition for our contributions towards continuous HSE improvement through

technology transfer, capacity building and stakeholder engagement. 1

e

SSaaffeettyy GGuuiiddiinngg PPrriinncciipplleess

! Safety is a value, not just a priority. ! Improving safety results in better project cost, schedule, and quality performance and

improvement in project team building. ! Safety values, accountability and management systems must be integrated throughout all Project

Team activities including Commercial, Legal, Engineering/Construction and External Affairs, with a subsequent transition to pipeline operations.

! Effective safety implementation and improved safety performance requires a partnership

between the Project and all Stakeholders.

! The Project Team values all people working on the Project and focuses on continuous improvement of the safety culture involving the entire workforce.

! Both management and the workers have a strong commitment to, and participate in, promoting

an incident and injury-free culture and environment. Management from both the Project Team and contractor shall demonstrate this commitment to safety through leadership behaviors, working together to eliminate barriers and obstacles.

! Safety value metrics include leading indicators to evaluate gaps in the safety management

process and to foster safety awareness. ! Both the Project Teams contractor selection process & the contractors subcontractor selection

process should include: safety performance, adaptation to the site culture, management commitment, safety systems and processes, and performance data.

! All Project Team members shall commit to and implement the best safety processes and practices

in a proactive manner to eliminate injury or incident before it happens. The site conditions and culture of the area and people, as well as technology transfer opportunities are carefully considered to determine which safety processes and practices will produce the best results.

Every task is performed with a concern for the safety of ourselves, our fellow employees, contractors, visitors, customers, and the communities in which we are present.

2

Appendix 8-B 8-2.0 HES Procedures TOC

West African Gas Pipeline

R-8-2.0 Procedures TOC.doc 12/19/2003 1

WAGP HES Procedures Table of Contents

Volume 1 Emergency Response and Medical

Title Page

Table of Contents

Emergency Response Reference Emergency Response Actions Emergency Response Training

Hazmat

Medical Treatment Phases 1 through 4

Shots and Immunization Requirements

Volume 2 Safe Work Practices

Title Page

Table of Contents

Safe Work Habits Back Safety

Ergonomics

Fall Protection

Smoking

Safety Equipment Life-Saving Equipment

Personal Protective Equipment

Safety Systems

HES Procedures and Programs Chemical Management Plan

Contractor HES

Crane and Lifting

Deviation from SOPs

Government Inspections

Hazardous Communications

HES Audit Protocol

HES Metrics

R-8-2.0 Procedures TOC.doc 12/19/2003 2

HES Procedure Review Cycle

HES Training

Incident Investigation

Incident Reporting

Industrial Hygiene Protocol and Sampling

Job Safety Analysis

Noise and Hearing Conservation

Respiratory Program

Safety and Security Orientation

Safety Communication

Work Permits Confined Space

Diving and Marine

Electrical Isolation

Electronic Devices

Excavation

Hot Bolting

Hot Work

Lockout/Tagout Electrical

Lockout/Tagout Mechanical

Maritime Transfers

Mechanical Isolation

Radiography

Safe Work

Using Scaffolding

Zero Energy

Outside Scope or Pending

Equipment Operations Electrical

Safe Work Critical Operating Practices

Security in Region

SIMOPS Construction/Commissioning

Work Permit - Depressurization

Appendix 8-B 8-2.1 WAPCo External Communications

Procedure Placeholder-To Be Included Later

West African Gas Pipeline

Appendix 8-B 8-2.2 HES Training

West African Gas Pipeline

West African Gas Pipeline HES Procedure 2 October 2003 1 Incident-Free Operations

15. HES Safety Training Guideline Contents 15. HES Safety Training Guideline .....................................................................1

Contents ...............................................................................................................1 Purpose.................................................................................................................2 Scope....................................................................................................................2 General Safety Rules............................................................................................2

Housekeeping...................................................................................................2 Drugs................................................................................................................2

Personal Protective Equipment (PPE) .................................................................3 Hard Hats .........................................................................................................3 Foot Protection.................................................................................................3 Eye Protection..................................................................................................4 Hearing Protection ...........................................................................................4 Hand Protection ...............................................................................................4 Respiratory Protection Equipment (RPE)........................................................5 Fall Protection..................................................................................................5

Back Safety ..........................................................................................................5 Proper Lifting Technique.................................................................................6 Teamwork ........................................................................................................6

Hazardous Materials/Chemicals ..........................................................................6 Lockout/Tagout....................................................................................................6 Permit System ......................................................................................................7 Emergency Response Procedures ........................................................................7 Glossary ...............................................................................................................8

2 West African Gas Pipeline HES Procedure 2 October 2003 Incident-Free Operations

Purpose This procedure provides a general guideline for conducting required safety training related to work activities in the workplace.

Scope This safety training outline applies to all personnel (employees and contractors), involved in work related to WAGP/WAPCo owned, operated, or maintained pipelines or facilities.

Employees should receive additional training on these procedures to properly carry out their routine work activities.

Although this overview does not contain all safety rules and regulations, it does contain useful information for all employees.

General Safety Rules

Housekeeping Good housekeeping is important in that it improves safety and efficiency. Employees are responsible for good housekeeping practices.

Employees must keep tools, equipment, facilities, and their work area clean and orderly.

Before waste accumulates, dispose of it in compliance with local regulations.

Tools and work equipment should be kept in good condition. Employees should check with their team leader about replacing any tools that cannot be maintained in good condition.

Keep walkways and accesses to them clear. Exits and access to fire fighting equipment should also be kept clear of clutter.

Work areas, walkways, and stairways must be kept free of slipping/tripping hazards. If you spill it, clean it up immediately. Use barricades, if necessary to secure the area.

Company vehicles should be kept free of trash, oily rags, and other debris.

Good housekeeping is everyones responsibility.

Drugs Prescription drugs brought onto company premises must be in the container in which they were originally dispensed and must be prescribed for the employee who has them in his/her possession.

The employee's team leader must be notified of the presence and use of any prescription drugs that may impair judgment or performance.

All personnel employed by WAGP/WAPCo are subject to random drug testing.

West African Gas Pipeline HES Procedure 2 October 2003 3 Incident-Free Operations

Personal Protective Equipment (PPE) Personal protective equipment (PPE) plays an essential role in protecting employees from on-the-job injuries. All PPE must meet standards established by WAGP/WAPCo. It is an employees responsibility to maintain PPE that has been issued to him/her in a safe and sanitary condition.

As a minimum, all employees, contractors, and visitors must wear the following PPE when working in areas other than offices:

! Hard hats

! Steel-toed footwear (with a defined heel) ! Safety glasses (with side shields)

Additional equipment may be required, depending on the hazard. This equipment includes, but is not limited to, the following:

! Respirators ! Goggles (for grinding, chemicals, and welding hazards) ! Face shields (for splash and welding hazards) ! Gloves

! Welder's jacket, pants, and arm protectors

Hard Hats Hard hats shall be worn by all personnel, including contractors and visitors, at all work locations and along the right of ways. When working in offices or when riding in the enclosed cab of a vehicle, however, employees are exempt from wearing a hard hat. Hair long enough to be potentially hazardous while working around moving machinery or rotating tools and equipment must be secured. Hairstyles that cannot be worn with a hard hat are not permitted.

Hard hats must be non-metallic (non-conductive or dielectric). Reference the WAGP/WAPCo Procedure on PPE for additional information on hard hats.

Foot Protection Field personnel are required to wear steel-toed footwear when working in areas outside of the office setting.

Acceptable footwear must comply with the following:

! Steel toes ! Adequate ankle coverage

! Clearly defined heel ! Oil-resistant soles

Reference the WAGP/WAPCo Procedure on PPE for additional information on foot protection.

4 West African Gas Pipeline HES Procedure 2 October 2003 Incident-Free Operations

Eye Protection WAGP/WAPCo requires eye protection with side shields at all work locations. Do not depend on safety glasses alone to protect you against all eye hazards. They must sometimes be worn in combination with other forms of eye protection.

Goggles must be worn at all times when there is a possibility of foreign objects and hazardous chemicals entering the eyes. There are two types of goggles: impact and chemical. Goggles will be furnished by the company, where required.

Face shields should never be worn alone as eye protection. Use them in addition to eye protection.

Reference the WAGP/WAPCo Procedure on PPE for additional information on safety glasses and other forms eye protection.

Hearing Protection Although we gradually lose some hearing as part of the aging process, wearing hearing protection in known areas of high noise plays an important role in the prevention of hearing loss. To prevent hearing loss that is not associated with aging, hearing protection must be worn in high noise areas and when working with tools and equipment that produce high noise levels. WAGP/WAPCo shall post signs identifying these high noise areas to alert employees of the need for hearing protection equipment.

Noise-induced hearing loss can be temporary or permanent. Temporary hearing loss results from short-term exposures to noise. Normal hearing may return after a period of rest from noise.

Prolonged exposure to high noise levels over a period of time, without hearing protection, can cause a permanent hearing loss.

The most common forms of hearing protection are earplugs and earmuffs. These may be worn alone or in combination.

Hand Protection Employees must wear hand protection appropriate for the activity and conditions when performing operations that expose the fingers and hands to cuts, scrapes, bruises, burns, and chemicals.

Some examples of appropriate hand protection and their uses include the following:

! Insulated or heat resistant gloves, to be worn when handling steam hoses ! Leather gloves, to be worn when working with wire rope

! Cloth gloves, to be worn when working with pipe ! Chemical resistant gloves, to be worn when working with caustics, acids, and other

chemicals ! Rubber gloves, to be worn when performing electrical work ! Hydrocarbon resistant gloves, to be worn when working with hydrocarbon-based

solvents, cleaning agents, or other such chemicals

When working around moving machinery, extra caution must be taken while wearing gloves. Rings and loose-fitting jewelry worn around the wrists should be removed.

West African Gas Pipeline HES Procedure 2 October 2003 5 Incident-Free Operations

Respiratory Protection Equipment (RPE) Employees must wear respiratory protection equipment (RPE) whenever they are working in an oxygen-deficient atmosphere or in an area that contains hazar