Al Baar Al Thahabi

Spill Prevention Management Plan

 Spill Prevention and Response Plan
Page 2 of 14

CONTENTS
1.0 Objective.......................................................................................................................3
2.0 Legal and Other Requirements.....................................................................................3
3.0 Surveys.........................................................................................................................3
4.0 Management and Monitoring.........................................................................................3
5.0 Roles and Responsibilities............................................................................................9
6.0 Training, Awareness and Competency.......................................................................10
7.0 Performance Indicators...............................................................................................10
8.0 Reporting and Notification...........................................................................................10

TABLES
Table 1: Management and Monitoring.....................................................................................4
Table 2: Performance Indicators............................................................................................10

ATTACHMENTS
Attachment 1: Legal and Other Requirements..................................................................12
 Spill Prevention and Response Plan
Page 3 of 14

1.1 OBJECTIVE
Al Baar Al Thahabi (Company) has developed this Spill Prevention and Response Plan as
part of its Environmental and Social Management Plan (ESMP).
The objectives of the Spill Prevention and Response Plan are to:
1. Prevent spills
2. In the event of a spill, minimize environmental and social impact.
The Spill Prevention and Response Plan should be read in conjunction with other Company
plans:
 Waste Management Plan
 Water Management Plan
 Hazardous Material Management Plan
 Project Emergency Response Plan.
2.0 LEGAL AND OTHER REQUIREMENTS
Legal and other requirements applicable to this plan are identified in Attachment 1.
3.0 SURVEYS
Contractor shall, as part of detailed execution planning and prior to the commencement of
work, undertake a spill risk assessment to establish high risk locations and activities,
including transportation and marine activities, identify measures to reduce identified risks to
as low as reasonably practical, and develop site and activity specific response measures.
The scope of Contractor’s spill risk assessment is subject to Company approval.

4.1 MANAGEMENT AND MONITORING

Table 1 presents a summary of the potential impacts due to spills, together with mitigation
and management measures to avoid or reduce these impacts.
Contractor shall develop a Spill Prevention and Response Plan, which will as a minimum
incorporate the measures described in Table 1 but shall not be limited to these measures.
Due to differing scopes of work and work locations, not all management and mitigation
measures in the Spill Prevention and Response Plan are applicable to all Contractors.
Company’s Environmental and Social Mitigation Register defines which management and
mitigation measures are applicable to each Contract scope of work.
In Table 1, any mitigation and management commitments that were contained in Al Baar
Al Thahabi Projects Environmental Impact Statement (EIS) are identified by a code
commencing with an 'M' in the 'Mitigation Item Reference Number' column. Some
mitigation measures have been reworded to provide further clarity or more detailed
information regarding required measures. In these instances, the code is displayed in italics,
and these reworded measures supersede what is in the EIS.
Other mitigation and management commitments required by Company required by Company
are identified in Table 1 with a code commencing with an 'A'.
 Spill Prevention and Response Plan
Page 4 of 14

Table 1: Management and Monitoring

Table 1: Management and Monitoring
Potential Impact and Mitigation Monitoring
Relevant Mitigation and Management Item Monitoring
Source of Impact Responsibility
Management Plan (Design Feature/Specific Measure) Reference Frequency
†
Objective Number
Prior to the commencement of construction activities, M27, Verification Ongoing Contractor
Contractor shall undertake a spill risk assessment to M209
establish high risk locations and activities, including
transportation and marine activities, identify measures to
reduce identified risks to as low as reasonably practical,
and develop site and activity specific response measures
to be incorporated in Contractor’s Spill Prevention and
Response Plan.
Contractor’s Spill Prevention and Response Plan should
consider as a minimum:
 Description of activity type and operator information
 Identification of persons responsible for managing
Spillage of spill response efforts, including their authority, role
oil/fuel/chemical and contact details
during transport,  Notification requirements
storage, handling  Clear demarcation of spill severities, according to
or refueling the size of the spill using a clearly defined tiered
approach
 Spill response frameworks based on site specific
risk assessments including spill location, volume
and type of spill and environmental sensitivity
 Strategies and equipment for managing Tier I spills
at a minimum
 Arrangements and procedures to mobilize external
resources for responding to larger spills and
strategies for deployment
 Full list, description, location, and use of on-site
and off-site response equipment and the response
time estimates for deploying equipment
 Spill Prevention and Response Plan
Page 5 of 14

Table 1: Management and Monitoring

Potential Impact and Mitigation Monitoring
Relevant Mitigation and Management Item Monitoring
Source of Impact Responsibility
Management Plan (Design Feature/Specific Measure) Reference Frequency
†
Objective Number
 Diagrams of the surrounding layout, topography,
evacuation paths and drainage flow paths, ground
and surface water resources, sensitive ecological
and protected areas, community and cultural
sensitivities
 Identification of response priorities, with input from
potentially affected or concerned parties;
 Clean up strategies and handling instructions for
recovered oil, chemicals, fuels or other recovered
contaminated materials, including their
transportation, temporary storage, and
treatment/disposal (refer to Waste Management
Plan)
 Identification and evaluation of potential discharge
hazards and description of discharge detection
procedures and equipment
 Facility response self-inspection, training,
exercises, drills and logs
 Security measures, including fences, lighting,
guards etc.
Contractor’s spill risk assessment shall be updated as
necessary to incorporate changes in construction
operations and/or equipment and the results of updated
risk assessment, including additional mitigation and
management measures, shall be incorporated into
Contractor’s Spill Prevention and Response Plan.

Fuel and chemical storage facilities shall be purpose-built, M26, M30, Verification Ongoing Contractor
located in designated above ground areas away from M130
watercourses, and provided with secondary containment
(e.g. double-walled tanks/lined containment bunds) as
appropriate to enable containment of 110% of the storage
capacity of the largest container present.
 Spill Prevention and Response Plan
Page 6 of 14

Table 1: Management and Monitoring

Potential Impact and Mitigation Monitoring
Relevant Mitigation and Management Item Monitoring
Source of Impact
Management Plan (Design Feature/Specific Measure) Reference
† Frequency Responsibility
Objective Number

Spill kits appropriate to the spill risk are to be available at A24 Verification Ong oing Contractor
each work site and vehicles as necessary. All fuel tankers
and those tankers transporting hazardous materials shall
carry appropriate spill kits.
Operational practices for vehicle/equipment refueling, M147 Verification Ongoing Company and
which includes the prevention of spillage and the use of Contractor
spill containment and response equipment, are to be in
place. To be included is the requirement for fuel delivery
vehicles and equipment to be routinely inspected so as to
ensure the tank, pumps, pipe work and the vehicle itself
are free from leaks and fit for purpose.
Material Safety Data Sheets (MSDS) for all stored A25 Verification Ong oing Contractor
substances will be located within each storage area and at
the site office (see Hazardous Materials Management
Plan).
An appropriate number of staff will be trained in the M151 Verification Ong oing Contractor
handling of emergency response and spill scenarios.

Drivers are to be appropriately trained in spill prevention M148 Verification Ong oing Contractor
and response and have required driving licenses.
Conduct regular emergency drills to practice timely and A26 Verification Ong oing Contractor
effective spill response.
Vehicles and equipment are to be maintained and M 25 Verification Ongoing Company and
inspected to a high level of safety with respect to leaks. Contractor
All servicing operations will take appropriate measures to A27 Verification Ongoing Company and
contain spills and be undertaken in appropriate locations. Contractor
Discarded oil filters will be drained prior to disposal and A28 Verification Ong oing Contractor
stored in a contained. Refer to Waste Management Plan
for disposal of waste oil.
Prohibit the washing of equipment, vehicles or machinery M150 Verification Ongoing Company and
Spill Prevention and Response Plan
Page 7 of 14
 Spill Prevention and Response Plan
Page 8 of 14

Table 1: Management and Monitoring

Potential Impact and Mitigation Monitoring
Relevant Mitigation and Management Item Monitoring
Source of Impact Responsibility
Management Plan (Design Feature/Specific Measure) Reference Frequency
†
Objective Number
Waste Management Plan for management of wastes
arising from clean up)
 Initial assessment of environmental and social impact.
Conduct inspections to evaluate the presence and A36 Verification Ongoing Contractor
condition of spill prevention measures. Record in
inspection logs.
Conduct post-spill response investigations to evaluate the A37 Verification Per Contractor
performance of spill prevention measures. Record in occurrence
incident response logs.
Collect post-response samples of soil and/or streams, if A38 Sampling and Per Contractor
affected by spill. analysis occurrence
 Spill Prevention and Response Plan
Page 9 of 14

The level of spill response is dependent upon the potential impact of the spill.
Company proposes the following spill categorisation:
 Tier I: Within capability of Contractor’s on-site resources.
 Tier II: Exceeds Contractor’s on-site resources
 Tier III: Exceeds available resources in PNG and requires additional resources to be
mobilized internationally.
Generally, Contractor shall respond to Tier I spills using on site resources. Contractor shall
have in place response arrangements with specialist third parties for Tier II and Tier III spills.
Such arrangements are subject to Company approval.
Contractor shall work closely with Company to define the spill categorisation and include it in
Contractor’s Spill Prevention and Response Plan.
Contractor shall develop spill response frameworks based on site specific risk assessments
including spill location, volume and type of spill and environmental sensitivity and include this
information in Contractor’s Spill Prevention and Response Plan.
Contractor’s spill categorisation and response framework are subject to Company approval.
Subsequent to a Tier II or Tier III spill release where site contamination has occurred, action
shall be taken to remediate the site and prevent (further) impacts to human health or the
environment. A site specific risk assessment shall be undertaken to identify human health
and environmental risks associated with the contaminated site.
The risk assessment shall be based on a site assessment which generally follows the
process established in the Australian National Environment Protection Council’s
(Assessment of Site Contamination) Measure 1999 Schedule A (Recommended General
Process for Assessment of Site Contamination) and considers, as a point of reference, the
Health Investigation Levels (HIL) and Environmental Investigation Levels (EIL) established in
its Schedule B1 (Guideline on the Investigation Levels for Soil and Groundwater).
The purpose of the risk assessment and site assessment shall be to determine whether site
contamination poses an actual or potential risk to human health and the environment, either
on or off the site, of sufficient magnitude to warrant remediation appropriate to the current or
proposed land use.
Based on the results of the risk assessment and site assessment, a remediation plan shall
be developed for the site as necessary. The remediation plan shall include target levels for
contaminants of relevance and shall provide for post remediation site assessment in order to
verify successful remediation and, if necessary, ongoing monitoring requirements.
Contaminated materials arising from the remediation shall be dealt with pursuant to the
requirements of the Waste Management Plan (PGGP-EH-SPENV-000018-006).
In the case of a spill by Contractor and/or its subcontractor, Contractor shall be responsible
for the implementation of the above requirements. Contractor’s risk assessment, site
assessment and remediation plan are subject to Company approval.

5.0 ROLES AND RESPONSIBILITIES

Contractor shall ensure sufficient resources are allocated on an ongoing basis to achieve
effective implementation of the Spill Prevention and Response Plan.
Contractor’s Spill Prevention and Response Plan shall describe the resources allocated to
and responsible for the execution of each task and requirement contained therein, and shall
describe how roles and responsibilities are communicated to relevant personnel.
 Spill Prevention and Response Plan
Page 10 of 14

Company shall ensure sufficient resources are allocated on an ongoing basis to achieve
effective implementation of Company’s responsibilities in the Spill Prevention and Response
Plan.

6.0 TRAINING, AWARENESS AND COMPETENCY

Contractor shall ensure that all personnel responsible for the execution of the tasks and
requirements contained within the Spill Prevention and Response Plan are competent on the
basis of education, training and experience.
Contractor’s Spill Prevention and Response Plan shall describe the training and awareness
requirements necessary for its effective implementation.
Contractor’s training activity associated with the Spill Prevention and Response Plan shall be
appropriately documented by means of a training needs assessment, training matrix/plan
and records of training undertaken.
Company shall ensure that all Company personnel responsible for the execution of
Company’s tasks and requirements in the Spill Prevention and Response Plan are
competent on the basis of education, training and experience.
Company’s training activity associated with the Spill Prevention and Response Plan shall be
appropriately documented by means of a training needs assessment, training matrix/plan
and records of training undertaken.

7.0 PERFORMANCE INDICATORS

Table 2 outlines the indicators for measuring and verifying performance in relation to spill
prevention and response.

† See Section 1.

8.0 REPORTING AND NOTIFICATION

Contractor shall report to Company the results of the risk assessment described in Section
3.1 and integrate the results, including additional mitigation and management measures as
agreed with Company, into the Spill Prevention and Response Plan.
Contractor shall immediately notify Company of all contained and uncontained spills detailing
material released, volume, location, cause and proposed corrective measures, where
appropriate.
For all uncontained releases, Contractor shall provide the following additional information:
 response time
 clean up requirements
 outcome and initial assessment of environmental and social impact.
 Spill Prevention and Response Plan
Page 11 of 14

Contractor’s monthly report to Company shall include:

 Number and results of verification inspections prescribed in Table 1
 Summary of all contained and uncontained spills/releases and follow-up
action/outcome
 Results of sampling undertaken to demonstrate successful remedial and
decontamination of receiving environment in the event of an uncontrolled release
 Performance Indicators as applicable in the reporting period.
Refer to the Environmental and Social Management Plan (main document) for details of
additional reporting and notification requirements relating to spills.
 Spill Prevention and Response Plan
Page 12 of 14

Attachment 1: Legal and Other Requirements

LEGAL AND OTHER REQUIREMENTS

Contractor shall comply with applicable Papua New Guinea Laws and Regulations,
applicable International Finance Institution (IFI) requirements and International Treaties and
Conventions (where applicable).
Papua New Guinea Laws and Regulations
PNG has no specific legislation or guidelines relating to spill prevention and response
although it is party to several relevant international conventions. Also, the Environment Act
2000 contains numerous provisions that promote environmental protection, regulate
environmental impacts associated with development activities, and safeguard the life
supporting capacity of air, water land and ecosystems. It also contains Duty of Care
provisions, as well as provisions relating to incidents threatening or causing environmental
harm.
International Financial Institution Requirements
The following International Finance Corporation (IFC) Performance Standards are applicable
to Spill Prevention and Response:

 IFC Performance Standard 1: Social and Environmental Assessment and

Management System, which establishes requirements for assessment, management,
organizational capability, training, community engagement, monitoring, and reporting.

 IFC Performance Standard 3: Pollution Prevention and Abatement, which refers to

the need for the client to be prepared to respond to process upset, accidental, and
emergency situations in a manner appropriate to the operational risks and the need
to prevent their potential negative consequences. This preparation will include a plan
that addresses the training, resources, responsibilities, communication, procedures,
and other aspects required to effectively respond to emergencies associated with
project hazards.

 IFC Performance Standard and Guidance Note 4 on Community Health, Safety and
Security refers to the following:

“Where the project poses risks to or adverse impacts on the health and safety of
affected communities, the client will disclose the Action Plan and any other relevant
project-related information to enable the affected communities and relevant
government agencies to understand these risks and impacts, and will engage the
affected communities and agencies on an ongoing basis consistent with the
requirements of Performance Standard 1.”

“Where the consequences of emergency events are likely to extend beyond the
project property boundary or originate outside of the project property boundary (e.g.
hazardous material spill during transportation in public roadways), the client is
required to design emergency response plans based on the risks to community
health and safety identified during the process of Social and Environmental
Assessment. When projects need to develop such plans, the proposed actions and
measures should be included in the client’s Action Plan. Emergency plans should be
developed in close collaboration and consultation with potentially affected
communities and should include detailed preparation to safeguard the health and
safety of workers and the communities in the event of an emergency.”
 Spill Prevention and Response Plan
Page 13 of 14

“The client should provide relevant local authorities, emergency services, and the
affected community with information on the nature and extent of environmental and
human health effects that may result from routine operations or unplanned
emergencies at the project facility. Information campaigns should describe
appropriate behaviour and safety measures in the event of an accident involving
project facilities, as well as actively seek community views concerning risk
management and associated community preparedness. In addition, clients should
consider including the community in regular training exercises (e.g. simulations, drills,
and debriefs of exercises and actual events) to familiarize them with proper
procedures in the event of an emergency. Emergency plans should address the
following aspects of emergency response and preparedness:
 Specific emergency response procedures
 Trained emergency response teams
 Emergency contacts and communication systems / protocols
 Procedures for interaction with local and regional emergency & health
authorities
 Permanently stationed emergency equipment & facilities (e.g. first aid
stations, fire extinguishers/hoses, sprinkler systems)
 Protocols for fire truck, ambulance and other emergency vehicle
services
 Evacuation routes and meeting points
 Drills (annual or more frequently as necessary)

The following IFC Guidelines are applicable to Spill Prevention and Response. Contractor
shall meet the intent of these guidelines:
 IFC EHS General Guidelines (April 2007), Section 3.7 which, in brief, advocates the
Emergency Preparedness and Response Plan that is commensurate with the risks of
the facility or activity and that includes the following elements:
o Administration (policy, purpose, distribution, definitions, etc)
o Organization of emergency areas (command centers, medical stations,
etc)
o Roles and responsibilities
o Communication systems
o Emergency response procedures
o Emergency resources
o Training and updating
o Checklists (role and action list and equipment checklist)
o Business Continuity and Contingency.