Engineering Procedure

SAEP-32 30 June, 2003

Environmental Performance
Assessment (EPA) Program
Environmental Standards Committee Members
Al-Sharif, A.A., Chairman
Abed Hezam, M.H.
Al-Bokhedaim, Y.S.
Al-Kadhim, M.H.
Al-Said, M.M.
Arnold, L.P.
Dobinson, I.D.
Hagen, D.L.
Ngao, J.O.
Rehm, T.E.
Worrall, M.E.

Saudi Aramco DeskTop Standards

Table of Contents

1 Scope............................................................ 2
2 Applicable Documents.................................. 2
3 Program Objectives...................................... 4
4 Instructions.................................................... 5
5 Responsibilities............................................. 9

Previous Issue: 26 February, 2003 Next Planned Update: 1 March, 2008

Revised paragraphs are indicated in the right margin Page 1 of 11
Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

1 Scope

This SAEP describes the procedures for the administration and implementation of the
Environmental Performance Assessment (EPA) Program. The purpose of this program
is to conduct periodic facility surveys to determine compliance with Saudi Aramco's
environmental, environmental health, and industrial hygiene requirements, as well as
related Saudi government requirements.

2 Applicable Documents

2.1 Saudi Aramco References

Saudi Aramco Policy Statement

SAPS No. INT-5 Environmental Protection

Saudi Aramco General Instructions

GI-0002.714 Environmental Protection Policy Implementation
GI-0002.717 Procedures and Guidelines for Handling
Polychlorinated Biphenyls (PCBs)
GI-0006.021 Safety Requirements for Abrasive Blast Cleaning
GI-0150.000 Implementing Occupational Health Aspects of
Loss Prevention Policy
GI-0150.001 Asbestos Regulation
GI-0150.003 Ionizing Radiation Protection
GI-0151.006 Implementing the Saudi Aramco Sanitary Code
GI-0425.000 Refrigerant Management
GI-0430.001 Waste Management General Instruction

Saudi Aramco Engineering Standards

SAES-A-007 Hydrostatic Testing Fluids and Lay-Up
Procedures
SAES-A-102 Air Pollutant Emission Source Control
SAES-A-103 Discharges to the Marine Environment
SAES-A-104 Wastewater Treatment, Reuse and Disposal
SAES-A-105 Noise Control
SAES-B-005 Spacing and Diking for Atmospheric and Low-
Pressure Tanks

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

SAES-B-069 Emergency Eyewashes and Showers

SAES-K-001 Heating, Ventilating and Air Conditioning
(HVAC)
SAES-P-123 Lighting
SAES-S-007 Solid Waste Landfill Standard

Saudi Aramco Engineering Procedures

SAEP-302 Instructions for Obtaining a Waiver of a Saudi
Aramco Engineering Requirement
SAEP-327 Disposal of Wastewater from Cleaning, Flushing,
and Dewatering Pipelines and Vessels
SAEP-340 Air Quality Impact Analysis & Assessment

Saudi Aramco Forms and Data Sheets

Form SA 7305-ENG Equipment Noise Data Sheet
Form SA 9563-ENG Asbestos Disposal Form
Form SA 9564-ENG Waste Manifest

Saudi Aramco Supply Chain Management (SCM)

CU 22.01 Processing and Handling Gas Cylinders
CU 22.02 Control of Chlorine, Ammonia and Nitrogen
CU 22.03 Processing and Handling of Hazardous Material

2.2 Government Requirements

General Standards Environmental Protection Standards in the
Document No. 1409-01 Kingdom of Saudi Arabia -Presidency for
& Revisions Meteorology and the Environment (PME)
PME National Plan to Combat Pollution from Oil and
Other Harmful Substances in Emergency
Situations
ROPME Protocol Concerning Marine Pollution Resulting
from Exploration and Exploitation of the
Continental Shelf
Royal Commission of "Royal Commission Environmental Regulations",
Jubail Royal Commission for Jubail and Yanbu;
Directorate General for the Jubail Project,
Health Services Department, September 1999

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

Royal Commission of Environmental Protection Manual and Revisions

Yanbu Manual, Directorate General for the Yanbu
Project, Madinat Yanbu Al-Sinaiyah, Royal
Commission for Jubail and Yanbu, January
1991
Royal Decree No. M/9 Regulations for Fishing, Exploitation and
Protection of Marine Life in Saudi Territorial
Waters, November 18, 1987

2.3 Other Requirements

SASO Industrial Safety & Health Regulations in the
Kingdom of Saudi Arabia, Saudi Arabian
Standards Organization (SASO)
SAS 315 Occupational Health & Environmental Control
SAS 319 Hazardous Materials
SAS 332 Personal Protective Equipment
SAS 335 Electrical
SAS 336 Welding, Cutting & Brazing
ACGIH American Conference of Governmental Industrial
Hygienists (Threshold Limit Values and
Biological Exposure Indices only)
ANSI Z9.5 Laboratory Ventilation
ASHRAE 110 Method of Testing Performance of Laboratory
Fume Hood
U.S.-OSHA Occupational Safety & Health Administration
standards (29 CFR-1910)

3 Program Objectives

The EPA Program was developed in response to Saudi Aramco's Environmental

Protection Policy (INT-5) Statement, which commits the Company to manage and
conduct its activities in an environmentally responsible manner. Implementation of this
policy is provided under GI-0002.714 and promotes protection of public health and the
environment, conservation of natural resources, and protection against liability. The
objectives of the EPA Program are to:

• Assess the environmental performance of Saudi Aramco facilities.

• Identify significant environmental compliance issues:

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

ο Environmental Engineering (air quality & emissions, wastewater discharges,

management of solid, liquid, and hazardous materials, spill prevention and
control)

ο Industrial Hygiene (noise, emergency eyewashes and showers, lighting,

respiratory protection, asbestos handling, personal protection equipment)

ο Environmental Health (food services and potable water, vector control and
public health nuisances)

• Ensure that major findings (i.e., areas of noncompliance) are appropriately resolved.

• Provide annual reports to corporate management on the status of the EPA Program.

4 Instructions
Commentary Note:

For further details, refer to the EPA Program Manual and the Team Leader's Handbook
issued by the Environmental Protection Department.

4.1 Facility Selection and Scheduling

4.1.1 The Environmental Protection Department selects facilities, or groups of

facilities, to be surveyed during the following calendar year. Selection is
primarily based on the time elapsed since the last survey, but shall also
consider potential effects on human health and the environment,
continuing compliance problems and/or complaints, available
environmental monitoring data, recommendations and feedback received
from previous Team Leaders, current or planned operational status at the
facility, and requests by Proponent Departments. Saudi Aramco
refineries, gas plants and Abqaiq Plants shall be surveyed every 3-5
years, whereas other facilities are surveyed every 5-7 years.

4.1.2 Facility selection shall be confirmed with the Proponent Departments in

September of the year preceding the surveys.

4.2 Survey Team Selection

The Environmental Protection Department (EPD) determines the number of

survey team members and the type of expertise needed for each survey, based
upon the type and complexity of the facility. The Team Leader shall be
provided by EPD from any of the divisions. Environmental Engineering
Division shall provide at least one team member and additional expertise as
deemed necessary. Environmental Compliance Division shall provide one
representative to the team from each discipline - Industrial Hygiene,

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

Environmental Health, and when applicable, Radiation Protection. A team

member shall be provided by the Proponent Department. Survey team
composition is finalized by November of the preceding year.

Other Company Departments may be requested to provide representatives

whose specialized technical knowledge will contribute to the effectiveness of the
EPA Program.

4.3 Team Preparation

The team members prepare for the survey by familiarizing themselves with the
facility organization and functions. All previous EPA reports should be
reviewed, as well as documentation regarding past environmental problems,
non-compliance incidents and formal complaints. The Team Leader may ask
the proponent to submit facility information that will help prepare the EPA team
for their visit.

4.4 Opening Meeting

The EPA Opening Meeting is held before the site visit commences and is
presided by the EPA Survey Team Leader. In attendance are the survey team,
the Proponent Manager, and appropriate facility supervision (as invited by the
manager). The purpose of the Opening Meeting is to introduce the EPA survey
team and facility management, give an overview of the EPA process, clarify any
areas of uncertainty, discuss site details and logistics, and set a time and location
for the Closing Meeting.

4.5 Onsite Survey

4.5.1 The survey team will assess the facility's environmental performance by
evaluating compliance with the Company documents listed in Sections
2.1 through 2.3. These can be obtained from the Environmental
Protection Department.

4.5.2 The EPA survey will cover the following items, as a minimum:
• Air pollutant emissions and air quality problems
• Wastewater discharges and management
• Solid and hazardous waste disposal and management
• Hazardous, toxic and regulated materials management
• Environmental monitoring, testing & sampling program data
• Spill containment and contingency planning

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

• Occupational health hazards (chemical, physical, biological, and

radioactive)
• Noise, emergency eyewashes and showers, lighting, respiratory
protection, asbestos handling, personal protection equipment
• Food services and potable water
• Vector control and public health nuisances

4.5.3 To assess the items listed in Section 4.5.2, the survey team should walk
through and inspect the facility, interview personnel, review pertinent
files, and investigate facility procedures. Checklists are required to be
used by the team members as a reminder of things to look for and to
document findings.

4.5.4 The survey team shall ensure that major findings from previous EPA
surveys have been appropriately resolved. Unresolved major findings
will be carried over to the new survey.

The survey team will check the status of the minor findings from
previous EPA survey. Unresolved minor findings may be elevated to
major status in the current EPA survey.

4.6 Summary Report and Closing Meeting

4.6.1 After completion of the onsite survey and initial data evaluation, the
team shall prepare a Summary Report that contains the major and minor
findings. This report will be presented in a closing meeting. In
attendance are the survey team, the proponent manager, and appropriate
facility supervision (as invited by the manager).

• Major findings are items that conflict with a Saudi Arabian

government or Saudi Aramco environmental requirement, and/or
represent significant cost to the Company if left unresolved, and/or
could have a significant adverse effect on human health or the
environment if unresolved. The findings should be supported by
reference to a specific mandatory requirement. They usually
represent issues that will take major funding to resolve.

• Minor findings are issues that should be brought to the attention of

facility management. These are generally findings that can be
resolved within 6 months and may require some local funding. The
facility should seek to permanently resolve these findings as soon as
possible.

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

4.6.2 The Summary Report is presented to facility management at the Closing

Meeting, which is normally held the last day of the site visit. The team
gives an overall assessment of environmental performance and discusses
each of the findings, highlighting items that need immediate attention
and those that require significant capital expenditure.

4.6.3 A copy of the Summary Report is left with facility management so that
they can correct and permanently resolve the minor findings and develop
an action plan for the major findings.

4.6.4 The Summary Report will be included as an attachment to the EPA Final
Report.

4.7 EPA Final Report

4.7.1 Only major findings will be highlighted for action in the EPA Final
Report.

4.7.2 The Survey Team Leader is responsible for circulating a draft report to
the team members and EPA Program Coordinator within four (4) weeks
of the site visit. The Final Report shall be completed within six (6)
weeks of the site visit and is sent to the Proponent Manager from the
Manager, Environmental Protection Department, with copies to
managers of other participating organizations and survey team members.

4.8 Facility Action Plan and Resolution of Findings

4.8.1 After receiving and reviewing the Final Report, the Proponent shall
complete the action plan attached to the report, which addresses
resolution of the major findings. This plan, with estimated dates of
completion, shall be submitted to the Environmental Protection
Department within four weeks of receipt of the Final EPA Survey
Report.

4.8.2 The proponent shall resolve the major findings expeditiously, using
appropriate Company resources as needed.

4.8.3 Proponents should provide pertinent and verifiable documentation to

support closure of major findings. Relevant documentation should be
sent to EPD in support of closure. Field verification of implementation
may be conducted by the Environmental Protection Department.

4.8.4 Minor findings should be resolved expeditiously. These findings will be

re-evaluated at the next scheduled survey and, if unresolved, may be
elevated to "major" status.

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

4.9 Status Reports

4.9.1 The Environmental Protection Department will request the Proponent

Department to submit a status report on the major findings every six (6)
months, until the findings are resolved to the satisfaction of EPD.

4.9.2 A finding involving project action is not considered 'closed' until the
project has been completed and commissioned. Copy of the
commissioning certificate should be filed with EPD.

4.9.3 Where a regulatory agency is involved, a letter indicating the solution

has been accepted or approved by that agency is required. Copy of the
approval letter should be filed with EPD.

4.9.4 The Environmental Protection Department shall have final concurrence

on the resolution and authorize closure of all major findings.

4.10 Annual Report

A year-end report is submitted to Corporate and Executive Management by the

Vice President, Engineering Services, summarizing all of the EPA surveys
completed to date and the progress made by facilities in resolving major findings
as per the facility action plans.

5 Responsibilities

5.1 Environmental Protection Department (EPD)

5.1.1 EPD is responsible for the administration, coordination, and execution of

the EPA Program. The EPA Program Coordinator will carry out the
day-to-day tasks.

5.1.2 EPD shall finalize facility selection by September, and the survey team
composition by November of the preceding year.

5.1.3 EPD shall circulate the draft EPA Final Report within four (4) weeks of
the site survey to the team members and EPA Program Coordinator for
comments, and shall distribute the Final EPA Survey Report within six
(6) weeks of the site survey.

5.1.4 If requested, EPD shall provide consultation on the development of a

corrective action plan for the facility.

5.1.5 EPD shall request the Proponent Department to submit a status report on
their action towards resolving the major findings every six (6) months,

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

until the findings are resolved. EPD shall track the findings and work
with the Proponent Department to ensure resolution.

5.1.6 EPD shall prepare an Annual Report for submission to Corporate and
Executive Management that summarizes all of the EPA surveys
conducted to date and the progress made by facilities in resolving major
findings.

5.2 Proponent Department

5.2.1 The Proponent Department shall provide a survey team member with the
qualifications and experience recommended by the Environmental
Protection Department.

5.2.2 Prior to the site survey, the Proponent Department shall provide any
information requested by the EPA Team Leader in sufficient time for the
team to evaluate the information and plan its visit.

5.2.3 The Proponent Department shall provide access and logistical support to
the survey team to inspect its facilities, interview its employees, and
review its documents.

5.2.4 The Proponent Department shall submit a facility action plan for the
resolution of major findings (if any) within four (4) weeks of receipt of
the EPA Final Report. Both major and minor findings shall be corrected
as soon as possible.

5.2.5 The Proponent Department shall track the resolution of all findings and
provide status reports as outlined in Section 4.9. Proper documentation
will be provided to EPD to support closure of resolved findings.

5.3 Support Departments

If requested to participate, support departments shall provide specialized

technical representatives that will contribute to the thoroughness of the EPA
program.

5.4 EPA Survey Team

5.4.1 The EPA Team Leader shall direct the course of the survey. This may
include assigning tasks to team members in order to efficiently utilize
their expertise.

5.4.2 The EPA team members shall participate full-time during the onsite
survey.

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Document Responsibility: Environmental SAEP-32
Issue Date: 30 June, 2003 Environmental Performance
Next Planned Update: 1 March, 2008 Assessment (EPA) Program

5.4.3 The team members shall finalize their findings by the end of the survey
period and present them in a Summary Report at the Closing Meeting.
They shall assist the Team Leader in preparing the EPA Final Report.

Revision Summary
26 February, 2003 Minor changes that provide clarification to existing directives and statements.
Revised the Next Planned Update.
30 June, 2003 Editorial revision to change the title of SAEP-327 referred to in this document.

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