Document title: POLLUTION PREVENTION MANAGEMENT PLAN

Document number: 1062-TGN-MNG-PLN-PJM-22-00003

Project: THE DEVELOPMENT OF THE ROMANIAN GAS TRANSMISSION

SYSTEM ALONG BULGARIA-ROMANIA-HUNGARY-AUSTRIA
ROUTE, PODISOR – GMS HORIA AND 3 NEW COMPRESSOR
STATIONS (JUPA, BIBESTI AND PODISOR) (PHASE 1)
(REFERENCE NUMBER IN EU LIST: 6.24.2)

Revision Date Issued by Checked by Endorsed by Approved by

Rev 2 Popovici Maria Lucia Iulian Butnaru Paul Popescu Ion Sterian
Head Environmental BRUA BRUA Director General
Protection Service HSE Project manager / Project Manager PMU / SNTGN Transgaz SA
SNTGN Transgaz SA

Alexandru Simionescu Sorin Keszeg

BRUA BRUA
Execution Project Project Manager
manager services

Disclaimer: The sole responsibility for this publication lies with the author. The European Union and the
Innovation & Networks Executive Agency (I.N.E.A.) are not responsible for any use that may be made of
the information contained herein.
Table of Contents
Abbreviations ................................................................................................................................................. i

1 Introduction .......................................................................................................................................... 1

1.1 Overview ....................................................................................................................................... 1

1.2 Purpose of the Pollution Prevention CESMP ................................................................................ 1

1.3 Scope of the pollution prevention CESMP .................................................................................... 1

1.4 Document Management ............................................................................................................... 2

2 The BRUA Project .................................................................................................................................. 1

2.1 Project Overview ........................................................................................................................... 1

2.2 Environmental and Social Commitments...................................................................................... 2

3 Key Policies, Legislation and Standards ................................................................................................ 3

3.1 Overview ....................................................................................................................................... 3

3.2 Company Policies .......................................................................................................................... 3

3.3 National Legislation and Permits .................................................................................................. 3

3.4 International Standards and commitments .................................................................................. 3

4 Linkages to Other Elements of Transgaz HSE-MS ................................................................................. 4

4.1 Overview ....................................................................................................................................... 4

4.2 Linkages to Other CESMPs ............................................................................................................ 4

5 Key Roles and Responsibilities .............................................................................................................. 6

5.1 Overview ....................................................................................................................................... 6

5.2 Company Roles & Responsibilities ................................................................................................ 6

5.3 Contractor Roles & Responsibilities .............................................................................................. 7

6 Management, Mitigation, Monitoring and Verification ....................................................................... 8

6.1 Management Actions .................................................................................................................... 8

DOCUMENT No. 1062-TGN-MNG-PLN-PJM-22-00003 Rev 2

 6.2 General Monitoring Activities ....................................................................................................... 8

6.3 Management System Verification Monitoring ............................................................................. 9

6.4 Key Performance Indicators ........................................................................................................ 10

6.5 Training ....................................................................................................................................... 11

7 Appendices .......................................................................................................................................... 12

7.1 Appendix 1: Mitigation Measures & Management Actions........................................................ 12

7.2 Appendix 2: Monitoring Requirements ..................................................................................... 20

7.3 Appendix 3: Relevant legislation (Pollution Prevention Management Plan).............................. 22

7.4 Appendix 4: Community Notification (template) ....................................................................... 22

DOCUMENT No. 1062-TGN-MNG-PLN-PJM-22-00003 Rev 2

Abbreviations

Abbreviation Description
BRUA Bulgarian-Romanian-Hungarian-Austrian (Natural Gas Transmission Corridor
Project)
ESIA Environmental Social Impact Assessment
ESMP Environmental and Social Management Plan
CESMP Construction Environmental and Social Management Plan
F-CESMP Framework Construction Environmental and Social Management Plan
GCS Gas Compressor Stations
HSE Health, Safety and Environment
HSE-MS Health, Safety and Environmental Management System
KPI Key Performance Indicator
PMU Project Management Unit
PR Performance Requirement

DOCUMENT No. 1062-TGN-MNG-PLN-PJM-22-00007 Rev 2

1 Introduction
1.1 Overview
The Construction Environmental and Social Management Plans (CESMP) defines the actions and measures
necessary for the overall management of environment and social impacts for both the Project beneficiary
(TRANSGAZ S.A., represented by the Bulgarian-Romanian-Hungarian-Austrian Project Management Unit
(BRUA PMU)) and contractors in line with the applicable law and other obligations. The CESMPs are
comprised of a suite of management plans.
This is document is the Project Pollution Prevention Management Plan, document no 1062-TGN-MNG-PLN-
PJM-22-00003.
Project construction activities have the potential to generate a range of pollution sources that require proper
planning from the outset to avoid resulting in impacts to human, biological or other environmental receptors.
These includes accidental emissions to air, water and soil, amongst others. The Project seeks to proactively
manage such potential pollution sources and to this effect has included specific obligations regarding
pollution prevention in the bidding document drawn by TRANSGAZ S.A.
This CESMP defines the actions and measures necessary for the overall management of pollution for both
the Project beneficiary (TRANSGAZ S.A., represented by UMP – BRUA) and contractors in line with the
applicable law and other obligations.
1.2 Purpose of the Pollution Prevention CESMP
The potential pollutants that could arise from the Project requires careful management to avoid negative
impacts on human health, and environmental factors such as groundwater, soils, surface water and ecology.
This CESMP therefore:
This CESMP therefore:
 Outlines the key policies, legislation and standards relating to waste management;
 Defines roles and responsibilities;
 Outlines actions and measures necessary for the effective prevention of pollution;
 Covers both accidental and intended emissions to air, noise, water and soils;
 Details specific control measures to be implemented by Transgaz and its contractors (and
subcontractors), to achieve this.
 Incorporates the requirements of the EIA findings, Supplemental Environmental Assessment,
international standards, Romanian legislation, Lenders requirements and Project-specific
construction permits.
 Considers Transgaz’s general approach on pollution prevention procedures and methodologies.
.

1.3 Scope of the pollution prevention CESMP

This CESMP covers all construction activities and is applicable to all Transgaz staff, Contractors and Sub-
contractors. Whilst this CESMP will act as a ‘framework’ to determine what the Contractors will be expected

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to produce, Contractors are required to ensure that all the CESMP requirements are adopted within their own
management plans. Further information on Roles and Responsibilities is provided in Section 5 of this CESMP.
The construction phase of the Project also includes the reinstatement of land that is temporarily occupied or
affected by the works to its original state when the construction works are completed, including the locations
for the construction site organizations and pipe storage yards.
1.4 Document Management
Document will be managed and controlled by the Document Control and Archiving Compartment within BRUA
PMU. The methods for document management and improvement during the construction phase will be
described in the Document Guide to be developed by BRUA PMU.

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2 The BRUA Project
2.1 Project Overview
SNTGN Transgaz SA Medias (“Transgaz”, “the Company” or “the Beneficiary”), the licensed operator of the
Romanian National Gas Transmission System, is developing a 529km natural gas pipeline between Podisor
in southern Romania and Horia in the west of the country (the “Project”). The pipeline, which for much of the
route will be buried and will upgrade or run alongside existing pipelines, represents the Romanian section of
the Bulgaria-Romania-Hungary-Austria Natural Gas Transmission Corridor. In addition to the pipeline itself,
the Project will also require construction of three new Gas Compressor Stations (GCS) at Podisor, Bibesti
and Jupa, as well as a range of supporting infrastructure including block valve stations, construction camps,
pipe storage areas, watercourses and infrastructure crossings and access roads.

Figure 2.1 BRUA Route

Whilst the majority of the route is on land currently used for farming, it does pass through a number of
specifically sensitive areas, including seven Natura 2000 Sites, and the nationally important Dinosaurs Geo-
Park. It also passes close to a number of sites of archaeological value including the ancient city of Tibiscum
near Jupa. In some of these areas, as well as near major roads and railways and for the eight major rivers,
this will require the use of horizontal directional drilling. In other mountainous areas, special “hammering
techniques” may also be applied.

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2.2 Environmental and Social Commitments
The Project is subject to various environmental and social requirements that are managed by the Company
through the implementation of its Health, Safety and Environmental Management System (HSE-MS)1. This
HSE-MS includes a Project specific Framework Construction Environmental and Social Management Plan
(F-CESMP) as well as associated topic/activity specific CESMPs. Operational phase Environmental and
Social Management Plans (ESMP) will be developed at a later stage prior to BRUA operation. The overall
approach to integration of the above documents is described in Section 4.2 of the F-CESMP document itself.

1
Integrated Management Manual Quality-Environment-Occupational Health and Safety, code MSMI-CMSSO Ed. 03/Rev.

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3 Key Policies, Legislation and Standards
3.1 Overview
The Project is subject to a range of policies, legal & regulatory requirements and other applicable standards
of relevance to this CESMP. Where two or more of the identified standards are inconsistent or
contradictory, unless otherwise justified, the Project will adopt the more stringent.
3.2 Company Policies
Transgaz’s HSE policy (as outlined in the Integrated Management Manual Quality-Environment-
Occupational Health and Safety, code MSMI-CMSSO Ed. 03/Rev.) and Corporate Social Responsibility
policy apply to all activities carried out by, or on behalf of, the Company as part of this Project. Details of
these policies are provided in the F-CESMP Document (Section 7.3).
3.3 National Legislation and Permits
All contractors are also required to comply with all relevant national regulatory requirements. Whilst
contractors are required to verify the latest regulatory requirements themselves an indicative list of
Romanian national legislation is provided in Appendix 3 to this CESMP. Contactors must also ensure that
relevant requirements of the various construction-related permits for the Project issued by national (and
local) regulators are addressed. Key permits are summarised in Section 3.2 of the F-CESMP.
3.4 International Standards and commitments
A range of international standards and commitments are applicable to this CESMP as described in the F-
CESMP Document (Section 3.3). These include the European Bank of Reconstruction and Development
Environmental and Social Performance Requirements (PRs), with PR1 and PR3 being especially relevant to
this document. All contractors are required to comply with all such requirements as they apply to their
activities. At European level, the Directive for Integrated Pollution Control reformed by Directive Industrial
Emissions and the Integrated Product Policy have a significant contribution to preventing pollution.

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4 Linkages to Other Elements of Transgaz HSE-MS
4.1 Overview
This CESMPs forms part of the Project HSE-MS as described in the F-CESMP (Section 4.2). Where
relevant, the CESMP should be read in conjunction with other HSE-MS elements including the ESMP
source documentation, control documentation and the key HSE-MS documentation. These are described
further in Section 4.1 of the F-CESMP and illustrated in Figure 4.1 below:
Figure 4.1 HSE-MS Linkages

4.2 Linkages to Other CESMPs

A listing of the CESMPs and their document numbers is presented in Section 4.2 of the F-CESMP
Document (Section 4.2). The other CESMPs considered to be of particular relevance to the Pollution
Prevention CESMP are as follows:

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Table 4.2 Other CESMPs considered to be of particular relevance to the Pollution Prevention CESMP

Plan Name Document Reference

Road and Traffic Management Plan 1062-TGN-MNG-PLN-PJM-22-00012
Waste Management Plan 1062-TGN-MNG-PLN-PJM-22-00005
Hazardous Materials Management Plan 1062-TGN-MNG-PLN-PJM-22-00004
Water Resources Management Plan 1062-TGN-MNG-PLN-PJM-22-00007
Contractor Management Plan 1062-TGN-MNG-PLN-PJM-22-00002
Emergency Response Management Plan 1062-TGN-MNG-PLN-PJM-22-00015
Water Crossing Management Plan 1062-TGN-MNG-PLN-PJM-22-00008

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5 Key Roles and Responsibilities
5.1 Overview
An integrated approach to pollution prevention involves a range of stakeholders, including the Company, the
Contractors (and subcontractors), local authorities, regulatory agencies and the general public. Such a
system therefore requires robust processes regarding information dissemination, training, and designation of
responsibility, management actions, monitoring, control, and remedial actions.
Generic roles and responsibilities for the Company and Contractors are detailed below. An initial split of
activities between key stakeholders is shown in Table 5.1 below with further information on specific
responsibilities for CESMP actions outlined in Appendices 1 and 2 to this CESMP.
Table 5.1 Initial Split of Activities

Activities Beneficiary Contractors External providers

Planning x x
Dissemination of x x
information
Management of pollution x x x
Spill response & x x
treatment
Professional training x x x
Surveillance and control x x
Monitoring and audit x x
Corrective actions x x
Management of x x
cooperation

The operational cooperation procedures in the construction site will be set in the Statement of Works that will
be Appendix to the Commercial Contract to be signed between the Beneficiary and the Contractor. The
Contact Point Unit for each construction site, as defined in the Contractor Management Plan, is the structure
responsible for the implementation and monitoring of the provisions in the Statement of Works.
5.2 Company Roles & Responsibilities
Transgaz HSE management roles and responsibilities during Project construction are detailed in the BRUA
PMU “Regulation of organization and functioning”. Further information is also provided in other documents
listed in the F-CESMP document.
With regards to this CESMP, Transgaz S.A. is responsible for key management activities including:
• Development of bidding conditions regarding pollution management;
• Professional training of its representative on site;
• Surveillance and control;
• Sanctioning;
• Management cooperation in case of medium incident; and
• Management of pollution from its own operations.

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Specifically, within the Company the following roles and responsibilities will apply:
Table 5.2 Company Roles and Responsibilities

Role Responsibilities
Director general - Approves the Pollution Prevention CESMP
SNTGN TRANSGAZ SA
HSSE Coordinator: - Ensures the compliance of the Project with the
requirements set out in this Plan.
- Has the general responsibility for the implementation of
this Pollution Prevention Management Plan, including by
the main contractors
- Develops, monitors and revises this plan according to
changes in the legislation or other requirements emerging
- Ensures the necessary training for BRUA PMU staff on
pollution prevention is delivered.
- Centralizes the information regarding pollution prevention
management by the Contractors,
- Provides necessary support to the Contractors to enable
them to comply with the Pollution Prevention Plan
- Ensures this Pollution Prevention Plan is available to all
BRUA PMU staff and Contractor staff.
- Performs regular audits of the main Contractors’
performance against the requirements of this Plan.
- Reports all risks, non-compliances with this Plan and
incidentsPrepares an annual environmental report that
includes details on the measures to be applied for pollution
prevention, including the results of the quarterly monitoring
results for air, water and noise.
Environmental responsible on Will verify the implementation of contractors’ obligations, including
site of Transgaz from PMU regular audits of:
BRUA - visual inspections of soil and water in the work area;
- Whether Contractors have appropriate Intervention Plans
in case of accidents;
- Monitoring of noise emissions

5.3 Contractor Roles & Responsibilities

Overarching Contractor HSSE requirements are defined in the relevant articles of their contracts and
associated mandatory Annexes. Each contractor must also implement all relevant requirements of the
CESMPs, including this Pollution Prevention CESMP. Contactors are also responsible for ensuring that any
subcontracted work also meets these requirements. In addition, within the project, responsibility for pollution
prevention lies with the Contractors according to the principle "polluter pays".
Specifically, within the Contractors’ Organization, the following roles and responsibilities will apply:
Table 5.3 Contractor Roles and Responsibilities

Role Responsibilities

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 - Manager responsible for - Makes sure all activities are performed according to the
environmental matters requirements within this Pollution Prevention CESMP
- Develops their own pollution prevention plans according to
the principles herein and to the principles within the
Environmental Agreement
- Assures notification of local communities on the start of
activities (see Appendix 3)
- Assures the necessary staff training on pollution prevention
- Monitors noise, air and water according to the provisions in
the Environmental Agreement through accredited
laboratories and sends copies of the assessment bulletins to
the beneficiary
- Makes regular inspections at work sites to make sure all
activities are undertaken according to the pollution prevention
plans
- Prepares annual and quarterly environmental reports that will
include details on the implementation of the pollution
prevention measures and sends it to the beneficiary
- Reports on all risks, non-conformities and incidents
- Takes the necessary measures to remedy non-conformities
- Within the project the responsibility for pollution prevention
rests with the Contractors, according to the principle “polluter
pays”

Contractors will therefore be required to present to the Beneficiary, represented in the project by BRUA PMU
in accordance with the requirements, their proposed approaches to:
• Prevention and management of pollution on site.
Spill recovery and emergency response to an event
• Any other conditions outlined in this CESMP or its appendices.
In addition contractors will present the Beneficiary with details of:
- A nominated representative on pollution prevention; (see Appendix 1)
- Records of any pollution incidents (air, noise, water, soils)
Further specific responsibilities of both the operator and the contractors/sub-contractors are outlined in the
Appendices to this CESMP.

6 Management, Mitigation, Monitoring and Verification

6.1 Management Actions
A range of management actions (and other mitigation measures) are required to be implemented in respect
of pollution prevention. The specific management actions and measures required of Transgaz staff and its
Contractors (and sub-contractors) are described in Appendix 1 to this CESMP.
6.2 General Monitoring Activities
Monitoring provisions for this Pollution Prevention CESMP have been developed through the process
outlined in Table 6.1.

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Table 6.1 Approaches to Monitoring

Objective Approach
1: Risk Based Monitoring programmes to address material issues base on the use of the ‘source-
pathway-receptor’ approach in the ESIA. These are commensurate with:
 The scale and nature of the activity;
 The assessed potential level of impact (and uncertainty thereof); and
 The sensitivity of the local environment within the activity area of influence.
2: Compliance Addition monitoring programmes to meet specific regulatory needs.
Based

Following this approach, the proposed monitoring plans should meet both Transgaz’s requirement to
understand and manage the Project’s potential impacts for each construction activity/ location and any
specific requirements of the Romanian authorities. The specific monitoring requirements for this Pollution
Prevention CESMP are presented in Appendix 2.
The relevant Romanian legislation and standards that identify the limits/thresholds for pollution prevention
(air emissions, water quality and noise limits) are provided in Appendix 3.
The permanent representatives on sites of TRANSGAZ from BRUA PMU will check the accomplish of
contractors’ obligations. This will include:
• Periodic testing of soil and water in the work area;
• Periodic checking of the Contractors’ Intervention Plans in case of medium incidents; and
• Annually audit.

If the monitoring results reflect any non-conformity with the requirements of the Management Plan, such lack
of conformity will be assessed, corrective actions will be taken, and such corrective actions will mandatorily
be implemented in the shortest time possible.
6.3 Management System Verification Monitoring
Management system verification monitoring requirements, as detailed in Section 6.3 of the F-CESMP, are
divided into three levels as shown in Table 6.2 below.
Table 6.2 Auditing Management System

Tier Objective Responsible Description

Tier 1: Transgaz Transgaz These audits are aimed at assessing the Transgaz HSSE
management management system elements and assessing their continued
system suitability throughout the project life cycle.
audits.
Tier 2: Transgaz Transgaz These audits are undertaken by the Transgaz BRUA team to
CESMP confirm compliance by the Company and its contractors with
audits. the CESMPs.
Tier 3: Contractor Contractor These audits are to be undertaken by contractors to confirm
self audits. compliance by themselves and their sub-contractors with the

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 CESMPs and their own HSE management systems. The
managing contractors shall ensure that audit reports are
provided to Transgaz

In addition to the above, there are also expected to be regulatory audits and lender compliance monitoring
visits. The nature and structure of these will be confirmed with regulators and lenders.
6.4 Key Performance Indicators
Both the General Monitoring and the Management System Verification Processes require robust Key
Performance Indicators (KPI) to be developed. These are quantitative or qualitative measurements used to
gauge performance over time and can be used to assess the effectiveness of control measures. The KPIs
considered relevant to this Pollution Prevention CESMP are shown in Table 6.3 below.

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Table 6.3 Key Performance Indicators

ID KPI Target Monitoring Measure Associated

mitigation
controls
KPI-PP001 Number of non-compliance Zero non-conformances See verification column All measures
with the requirements of this of Appendix 1 identified in
CESMP. Appendix 1
KPI- Number of non-compliance Zero non-conformances See Appendix 2 N/A
PP002 with project standards
identified during monitoring
KPI- Number of noise monitoring Observe monitoring See Appendix 2 N/A
PP003 reports periodicity for noise
KPI- Number of non-conformities to Observance of admissible See Appendix 2 N/A
PP004 noise admissible limit limits through the
Environmental Agreement
KPI- Number of air monitoring Observance of noise See Appendix 2 N/A
PP005 reports monitoring periodicity
KPI- Number of non-conformities to Observance of admissible See Appendix 2 N/A
PP006 air admissible limit limits through the
Environmental Agreement
KPI-PP007 Number of water monitoring Observance of water See Appendix 2 N/A
reports and monitored monitoring periodicity and of
indicators monitoring indicators
required for emissions into
water
KPI-PP008 Number of non-conformities to Observance of admissible See Appendix 2 N/A
water admissible limit limits through the
Environmental Agreement
KPI-PP009 Number of non-compliances 100% of all non-conformities N/A All actions
closed due to corrective remedied within the defined identified in
actions being taken within the timeframe Appendix 1
defined timeframe (set on a
case by case basis)
KPI-PP010 % of all staff who have 100% compliance with ?? N/A
received relevant and training requirements.
adequate training
KPI-PP011 Number of reports of near 100% of near miss reports N/A N/A
misses reviewed for root reviewed and shared
cause and a corrective action
identified and shared across
all spreads within 48 hours to
prevent future occurrence

The specific auditing requirements for the verification of each management and mitigation controls measure
described within this Pollution Prevention CESMP are identified in Appendix 1 and Appendix 2. This
includes identification of the relevant audit tier level (1 to 3) to be undertaken.
6.5 Training
Training needs for all TRANSGAZ and Contractor staff shall be identified at the outset, before construction
works commence, and a training plan developed.

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7 Appendices
7.1 Appendix 1: Mitigation Measures & Management Actions
Ref. Topic Location Requirement Responsibility Verification
Process

PP01 General pollution All The equipment shall be brought to the site in perfect state of Contractor Internal audit
prevention operation, the technical revisions and oil exchange being already program
made
PP02 General pollution All All plant, vehicles and equipment to be maintained to Contractor Internal audit
prevention manufacturers standards and maintained in accordance with the program
provisions of the Government Decision no. 332/2007. This
includes regular inspections of plant and equipment to prevent
leakage/emissions and technical periodical checks of emissions
(carbon monoxide and exhaust gases). A plan for this to be created
including processes to remedy potential defects.
PP03 General air All All installations to be well maintained with appropriate valves, Contractor Internal audit
emissions control fittings and flanges. program;
Periodic
inspections

PP04 General air All Idling of vehicles or equipment to be restricted to minimize Contractor Internal audit
emissions control emissions. program
PP05 General air All Use and maintain effective filters in vehicle cabs to keep air free of Contractor Internal audit
emissions control dusts and fumes program, Visual
inspections
PP06 General air All The vehicles transporting materials issuing fine particles in the air Contractor Periodic
emissions control shall be covered with tarpaulin inspections
PP07 General air All areas, but especially All powdery/dusty materials to be stored in enclosed containers or Contractor Periodic
emissions control areas with large covered to avoid wind dispersal. Dust producing activities to be inspections
mammals reduced during strong winds or to be controlled by dust
suppression techniques e.g. water sprinkling, use speed controls,
all-weather surfaces

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Ref. Topic Location Requirement Responsibility Verification
Process

PP08 General air Residential area An Air quality monitoring program shall be implemented, especially Transgaz/Contractor Analysis reports
emissions control close to the residential areas that determined the impact
significance to be "high", in the surroundings of the GCS and site
organizations areas
PP09 General noise All All plant and machinery to be fitted with appropriate noise baffles / Contractor Internal audit
control silencers to keep noise emissions within normal program, Visual
operating/regulatory limits. inspections
PP10 General noise All Provision of noise barriers for static equipment where appropriate Contractor Internal audit
control especially when noisy work (eg. hammering) is being conducted. program,
Periodic
inspections

PP11 General noise All Generators and water pumps required for 24-hour operation will be Contractor Internal audit
control super-silenced or screened/located as appropriate to reduce noise; program,
Crane spindles, pulley wheels, telescopic sections and moving Periodic
parts of working platforms will be adequately lubricated in order to inspections
prevent undue screeching and squealing; and, where possible
mains electricity will be used rather than generators.
PP12 General noise All Personnel will be instructed on best practice measures to reduce Contractor Internal audit
control noise and vibration as part of their site induction training; program,
Shouting and raised voices will be kept to a minimum e.g. in cases Periodic
where warnings of danger must be given. inspections
Use of audio radios in the open environment will be prohibited
except where two-way radios are required for reasons of safety and
communication;
Control of noise introduced into site induction to ensure that all
operators on site, including contractors, are working in such a way
to minimize noise;
PP13 General noise All Compliance monitoring of noise to ensure limits are being met. Contractor Analysis reports
control

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Ref. Topic Location Requirement Responsibility Verification
Process

PP14 General noise All All materials will be handled, stored and used in a manner that Contractor Internal audit
control minimizes noise, this include the preclusion of dropping material program,
which would be placed in all instances; Periodic
Routes and programming for the transportation associated with the inspections
works will be carefully considered in order to minimize the overall
noise impact generated by these movements and will conform to
the operational hours of the works
Provision of temporary acoustic barriers (or other means) for use
when operations are exposed or are identified as problem activities;
Appropriate complaint procedure to ensure complaints are logged,
investigated and resolved; and,
Control of noise introduced into site induction to ensure that all
operators on site, including contractors, are working in such a way
to minimize noise.
PP15 General noise Site establishment Piling and ground stabilization would be suitably controlled on site if Contractor Internal audit
control platform wash water necessary (However, due to the large separation distances to the program,
nearest receptors this is not considered an issue); Periodic
Isolation of pumps and generators when positioned in close inspections
proximity to sensitive receptors to prevent direct vibration transfer;
Selection of appropriate equipment for the task required;
Appropriate training with regard to plant operational techniques so
as to minimize vibration generation;
Appropriate complaint procedure to ensure complaints are logged,
investigated and resolved.
PP16 General spill All Standard industry refueling protocols should be followed. Vehicles Contractor Internal audit
prevention maintenance to be undertaken on a purposely provided drip tray. programme,
Secondary spill containment to be provided wherever refueling or Periodic
storage occurs. All materials to be properly contained for decanting inspections
with fill areas to contain any spillage during transfer.

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Ref. Topic Location Requirement Responsibility Verification
Process

PP17 General spill All The exchange of oils shall be done in specialized workshops Contractor Internal audit
prevention programme,
Periodic
inspections

PP18 General spill All Spill kits should be continually available and all site assemblies will Contractor Internal audit
prevention be equipped with specific materials necessary for the intervention program,
in case of accidents (hydrocarbon leaking), so that any possibility Periodic
for extension of pollution may be avoided inspections

PP19 General Spill All The measures required for the prevention of soil pollution with Contractor Internal audit
prevention drilling fluid shall be taken program,
Periodic
inspections

PP20 General Spill All Perform simulations regarding emergency situations in case that an Transgaz/Contractor Internal audit
prevention accidental pollution is caused, having impact on the water program
resources
PP21 General Spill All Fuel handling, especially bulk storage, will take place in secure Contractor Periodic
prevention bounded areas. Similar conditions will apply to lubricant oils, inspections
chemicals and liquid wastes. Should a spill occur, polluted soils will
be cleaned up or removed for appropriate disposal. All wastes will
be handled, stored and disposed of as per local regulations. Diesel
and other potentially polluting liquids will be stored in appropriate
containers, fitted with secondary containment. Fuel equipment shall
be supplied by oil pump, and tanks with automatic alarms and shut
off systems to be installed in all refueling areas. All areas to be
checked prior to delivery to prevent overfill and spillage.
PP22 General Water Activities of record All working areas to have appropriate ecological toilets to be Contractor Periodic
resource keeping, emptied by authorized operators inspections
protection correspondence,
supervision and site
inspector.

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Ref. Topic Location Requirement Responsibility Verification
Process

PP23 General Water Domestic waste from Domestic wastewater to be separated from hazardous, oily water Contractor Periodic
resource construction camps, pipe discharges at all sites inspections
protection deposits and work fronts

PP24 General Water From activities Contractors will develop and implement an appropriate plan to Contractor Internal audit
resource concerning: - prevent accidental water pollution based on the BRUA program
protection Maintenance of commitments requirements.
equipment,- Building
demolition- Pipelining

PP25 General Water Support activities to the Standard pollution control measures will be implemented i.e. to Contractor Periodic
resource shore, packaging, prevent silt contamination by keeping water out of the works area inspections
protection casings, various using appropriate isolation techniques, such as coffer dams and by-
carpentry works. pass channels.
PP26 General Water Pipe trench excavation, Sewage treatment plant at GCS will be carefully maintained strictly TRANSGAZ Wastewater
resource foundations, building respecting the timing of maintenance and emptying plant
protection access roads, land maintenance
systematization. manual

PP27 General Water Pipe cleaning Demarcation and offsets for camp and storage locations and field Contractor Periodic
resource activities of at least 50 m from watercourses where possible. inspections
protection

PP28 General Water Pipeline preparation Monitoring the meteorological bulletins meant to take the Contractor Internal audit
resource equipment outside the areas which could be flooded, in case of programme,
protection high waters Periodic
inspections

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Ref. Topic Location Requirement Responsibility Verification
Process

PP29 General Water All Implement measures against sedimentation. Use of settling ponds, Contractor Periodic
resource silt fences and screens to prevent sediment transport inspections
protection

PP30 General Water All Wastewater should be prevented from entering surface water Contractor Periodic
resource bodies without prior assessment and treatment if necessary inspections
protection

PP31 General Water Watercourse The placing of concrete in, or near to, any watercourse must be Contractor Periodic
resource controlled to minimize the risk of pollution inspections
protection
PP32 General Water Site organizations The adequate collection and treatment of all the used waters which Contractor Periodic
resource will result from the site organizations so that no impact is caused on inspections
protection the waters
PP33 General Water All Ensure contaminated water from dewatering or cement washing Contractor Periodic
resource operations is treated prior to discharge, depending on the nature of inspections
protection the contaminants
PP34 General Water Access ways Accomplish polders of small dimensions having a sediment Contractor Periodic
resource exclusion role, respectively for stilling the leaking force of pluvial inspections
protection waters, to be accomplished along the access ways at distances of
approximately 30- 50m. The development of polders shall be
accomplished on surfaces of up to 10m2 and at a maximum depth
of 30cm, being provided with diffuse leaking areas, in steps
oriented upstream, in order to avoid the occurrence of erosive
phenomena, at distances of 2-3m to the access ways, being used
as accumulation areas (aggregation) of the species of amphibians
and not only, outside the areas having a potential for negative
impact (access ways).
PP35 Traffic All Vehicle tyres should be cleaned at the exit from the working areas, Contractor Periodic
in case of use of public roads inspections

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Ref. Topic Location Requirement Responsibility Verification
Process

PP36 General Works site Works sites will be subject to legally binding documents that will Contractor/TRANSGAZ
principles ensure the transfer of ownership.
Based on these documents, environmental responsibilities are
specifically defined to be transferred to the entrepreneurs and
subsequently to the beneficiary, following the responsibilities for
each stage to be clearly defined and assumed.
PP37 General All Works organizations will be established by accurate legal Contractor/TRANSGAZ
principles documents that will determine the distinct responsibilities of
entrepreneurs, assumed compensation, but also the breach to
restore them to the initial state.
Based on these documents, environmental liabilities will be clearly
defined in the protocols of pre-defining environmental tasks
undertaken. Thus, the principles underlying the specific legislation
in force (especially the principle: the polluter pays), the contractor
will undertake to remedy any fault of its negative effects.
PP38 General All The workforce will be provided with environmental awareness Contractor Trainning
principles training. records
PP39 On-site Traffic Dust emissions due to road travel shall be minimized by regulating Contractor Periodic
Traffic inspections
Management vehicle speed and watering roads (where required).
PP40 On-site Traffic Contractor Records
Traffic Prepare necessary reports, inspection logs and incident records.
Management
PP41 General pollution All Vehicles will be maintained in accordance with manufacturer Transgaz/Contractor Internal audit
prevention guidelines and Romanian licensing requirements and periodic programme
verification inspections will be undertaken.
PP42 General All Contractor Internal audit
principles Reducing exposure times for people working near noisy machinery programme

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Ref. Topic Location Requirement Responsibility Verification
Process

PP43 General All For the pre-construction stage when work sites will be in place for TRANSGAZ Records
each sector there will be a protocol that will establish as accurately
as possible the environmental load, based on standardized forms
(standard-forms), with aerial photographs or photographic images
taken from the ground, which will act as control elements. For each
site during the growing season (May-September the ecological
structure and functions of the site will be accurately determined.
PP44 General All Comply with all mitigation measures included in the Environmental Contractor Internal audit
principles Agreement program

PP45 General All Investigate all incidents and identify any necessary corrective Contractor Internal audit
principles actions program
Records

PP46 General All Noise and vibration from plant and machinery will be controlled by Contractor Internal audit
ensuring that: program
1) Engine compartments are closed when equipment is in use
2) Resonance of body panels and cover plates is reduced by the
addition of suitable dampening materials
3) Any "rattling noise" is addressed by the tightening of loose parts
or the addition of resilient materials if appropriate;
4) Siting of semi-static equipment will be orientated as far as is
reasonably practicable from noise-sensitive receptors with localised
screening if deemed necessary.
PP47 Water resource Water Courses All pumps, motors and combustion engines to be operated with drip Contractor Periodic
protection trays underneath and set back from watercourses (minimum of inspections
20m).

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7.2 Appendix 2: Monitoring Requirements
Table 7.1

ID Activity Description Parameters Location Standards

PP General (project Monitoring of compliance Number of non-compliance with All Project standards
002 lifecycle) with project standards project standards identified
during monitoring

PP General Noise Noise monitoring Number of elaborated According to the Observance of monitoring
003 control reports/number of reports noise monitoring periodicity according to the
required through the program to be Environmental Agreement
Environmental Agreement elaborated

PP General Noise Assessment of conformity Number of non-conformities N/A Observance of admissible

004 control against admissible limits found to noise admissible limits limits according to the
Environmental Agreement

PP General Air Air quality monitoring Number of elaborated According to the air Observance of monitoring
005 Emissions reports/number of reports monitoring program to periodicity according to the
control required through the be elaborated Environmental Agreement
Environmental Agreement

Page 20 of 26 DOCUMENT No. 1062-TGN-MNG-PLN-PJM-22-00002 Rev 2

ID Activity Description Parameters Location Standards
PP General Air Assessment of conformity Number of non-conformities N/A Observance of monitoring
006 Emissions against admissible limits found to air admissible limits periodicity according to the
control Environmental Agreement

PP General Water Wastewater quality Number of elaborated According to the Observance of monitoring
007 Control monitoring reports/number of reports water monitoring periodicity according to the
required through the program to be Environmental Agreement
Environmental Agreement. elaborated
Number of monitored
indicators/number of indicators
required through the
Environmental Agreement

PP General Water Assessment of conformity Number of non-conformities N/A Observance of admissible

008 Emissions against admissible limits found to water admissible limits limits according to the
control Environmental Agreement

Page 21 of 26 DOCUMENT No. 1062-TGN-MNG-PLN-PJM-22-00002 Rev 2

7.3 Appendix 3: Relevant legislation (Pollution Prevention Management Plan)

The indicative list of Romanian national legislation Correspondence with EU Directives/Regulations

GEO no. 195/2005 on environment protection approved
by Law no. 265 / 29.06.2006, as further amended and
supplemented.
Law no. 104/2011 on quality of environmental air as Transposes in the national legislation the provisions of
further amended and supplemented. Directive 2008/50/CE of the European Parliament and
Council of May 21st, 2008 quality of environmental air and
cleaner air for Europe and the provisions of Directive
2004/107/CE of the European Parliament and Council of
December 15th, 2004 on arsenic, cadmium, mercury,
aromatic hydrocarbon polycyclic aromatic hydrocarbons in
ambient air.
Ministry Order no. 462/1993 on the approval of the
technical conditions for atmospheric protection and of the
methodological norms on the determination of emissions
and atmosphere pollutants caused by stationary sources.

STAS 12574/1987 on the quality condition of air in

protected areas.

Water Law no. 107/1996, as further amended and Transposes Directive 2000/60/CE of the European
supplemented. Parliament and Council of October 23rd, 2000 on the setting
of a community policy framework on water, as published in
the Official Journal of European Community (JOCE) series
L no. 327 of December 22nd, 2000 and Directive
2007/60/CE of the European Parliament and Council of
October 23rd, 2007 on the assessment and management of
flood risks, published in the Official Journal of European
Community (JOUE) series L no. 288 of November 6th, 2007.
GD no. 188/2002 on the approval of some norms Transposes Council Directive no. 91/271/CEE on treatment
regarding the conditions for discharge of wastewaters in of urban wastewaters, modified by Commission Directive
in aquatic environment, as further amended and no. 98/15/CE on some requirements set in Annex to Council
supplemented. Directive no. 91/271/CEE and in the Regulation of
European Parliament and Council no. 1882/2003/CE on
harmonization of Council Directive no. 199/468/CE of the
provisions regarding the committees assisting the European
Commission in their exercising of competences to execute
the deeds under the procedure mentioned at art. 251 in CE
Treaty, published in the Official Journal of European
Communities (JOCE) no. L 284/2003.
Ministry Order no. 756/1997 on the approval of the
Regulation regarding the assessment of environment
protection.
SR 10009:2017 Acoustics. Admissible noise levels in
ambient environment.

7.4 Appendix 4: Community Notification (template)

During ..................................., will execute construction works in the area of natural gas mains ...... ..

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We inform you that between the hours ............................., we will perform works by producing noise
machinery, dust and vibration.
Please do not throw in the works perimeter waste (paper, glass, household waste, etc.) because they can
pollute the soil and create obstacles.

MANAGEMENT S.C. ......... SRL

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