Environmental Management Plan Operation of Quarries to...

Nimba Western Range Iron Ore Project, Liberia Environmental and Social Studies, 2008-2015

Project Phase 2: Concentrator Environmental and Social Impact Assessment

Volume 6, Part 3.3:

Environmental Management Plan: Quarry Operation March 2013

Environmental Management Plan

Operation of Quarries

to Provide

Construction Materials for Project Phase 2

VERSION DATE: 1 MARCH 2013

ArcelorMittal Liberia Limited

P.O. Box 1275 Tubman Boulevard at 15

th Street

Sinkor, Monrovia Liberia

T +231 77 018 056

www.arcelormittal.com

Nimba Western Range Iron Ore Project, Liberia

Environmental and Social Studies, 2008-2015: Project Phase 2 – Concentrator Environmental Management Plan – Operation of Quarries

Version: 1 March 2013 Page 2 of 54

Contents

List of Abbreviations ................................................................................................................................ 3

1. OPERATIONAL PRACTICES (DO’S AND DON’TS) ...................................................................... 4

2. INTRODUCTION ........................................................................................................................... 11

2.1 The Environmental Management Plan .................................................................................. 11

2.2 Approved Activities ................................................................................................................ 11

2.3 References ............................................................................................................................ 13

3. ARCELORMITTAL ENVIRONMENTAL POLICY .......................................................................... 14

4. ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS .................................................. 16

5. ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES ........................................ 18

5.1 Protection of Soils ................................................................................................................. 18

5.2 Maintenance of Water Quality ............................................................................................... 18

5.3 Protection of Ecology ............................................................................................................ 19

5.4 Maintenance of Air Quality .................................................................................................... 19

5.5 Sanitary Waste Disposal ....................................................................................................... 19

5.6 Waste Management .............................................................................................................. 19

5.7 Storage of Materials .............................................................................................................. 20

5.8 Avoidance of Community Land ............................................................................................. 20

5.9 Protection of Cultural Sites .................................................................................................... 20

5.10 Employment of Local People ................................................................................................ 20

5.11 Health and Safety of Workers ............................................................................................... 20

5.12 Worker Facilities .................................................................................................................... 20

6. MANAGEMENT OF WARNINGS AND EMERGENCIES ............................................................. 21

6.1 Early Warning Systems ......................................................................................................... 21

6.2 Emergency response plans ................................................................................................... 21

7. ENVIRONMENTAL COMPLIANCE CONTROLS ......................................................................... 26

7.1 Environmental Awareness Briefing for Site Crews ............................................................... 26

7.2 Environmental Awareness for Professional and Technical Staff .......................................... 26

7.3 Environmental Compliance Review Meetings ....................................................................... 26

7.4 Local Consultative Forums .................................................................................................... 27

7.5 Environmental Compliance Inspections and Documentation ............................................... 27

8. RESPONSIBILITIES ..................................................................................................................... 28

8.1 Organisational structure ........................................................................................................ 28

8.2 The Company ........................................................................................................................ 30

8.3 The Engineering and Procurement Management Consultant ............................................... 32

8.4 Contractors ............................................................................................................................ 32

8.5 Employment Policy ................................................................................................................ 32




9. IDENTIFIED POTENTIAL ENVIRONMENTAL IMPACTS ............................................................ 34

9.1 Impacts Relating to all Parts of the Company’s Operations ................................................. 34

9.2 Impacts Specific to this Environmental Management Plan ................................................... 35

10. ENVIRONMENTAL MANAGEMENT AND ITS MONITORING ................................................ 37

10.1 Environmental Issues Specific to Quarry Preparation .......................................................... 37

10.2 Environmental Issues Specific to Quarry Operation ............................................................. 42

10.3 Environmental Management Principles Common to All Sites ............................................... 45

List of Abbreviations AML ArcelorMittal Liberia

CEMP Contractor’s Environmental Management Plan

CLO Community Liaison Officer

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPA Environmental Protection Agency

EPML Environmental Protection and Management Law

ESIA Environmental and Social Impact Assessment

FDA Forestry Development Agency

FONSI Finding of No Significant Impact

HSE Health, Safety and Environment

MDA Mineral Development Agreement




1. OPERATIONAL PRACTICES (DO’S AND DON’TS) The Operational Practices for all Employees and Contractors are listed in the table below. These are based on the Project Briefs and the Environmental and Social Impact Assessment approved by the Environmental Protection Agency, and are therefore legal and contractual requirements. The Operational Practices are intended to be low in cost, practical and easy to apply. If an Employee or Contractor has a reason to request modification, he should raise the matter with the Environmental Superintendent: as part of the Environmental Management Plan, the Operational Practices can be modified according to site experience.

Issues Specific to this Environmental Management Plan: Quarry Preparation

Employee and Contractor compliance obligations Applicable standard

(see manual) What you MUST do What you must NOT do

Soils and earthworks

Only disturb the soil where it is necessary to do so.

Grade any newly formed slopes to the minimum angle possible.

Level surfaces to prevent erosion as soon as works have been completed.

Use existing tracks and previously disturbed areas as far as possible.

Allow small plants to grow back on the edges of roads and tracks when their use is finished.

Undertake soil erosion prevention and sediment controls as required by the Environmental Officer if this should be deemed necessary, to protect areas from slips and erosion.


Disturb any more of the ground surface than is absolutely necessary for access and working.

Allow erosion to happen without taking rapid control measures.

Make access tracks wider or other cleared areas larger than necessary.

Create earth piles close to the edge of steep slopes or close to watercourses.

Leave soil slopes steeper than 10° completely bare and unprotected.

Drive unnecessarily often or use very heavy equipment on access tracks or other earth surfaces (thereby compacting the soil excessively).

Standards 6.1 to 6.9 inclusive, as required.

Soil and water management

Phase land clearance and restoration to maximise forest cover at any one time.

Schedule activities to avoid major earthworks operations in the wet season.

Control erosion to protect slopes and watercourses.

Regulate water discharge and run off.

Monitor downstream water quality routinely.

Where it is present, top soil to a depth of 200 mm should be removed and stockpiled for later site restoration use.


Destroy vegetation cover, leaving areas prone to erosion with consequent land degradation and pollution of watercourses and catchments.

Permit water pollution on which destroys aquatic species and renders water useless for downstream community users.

Allow air pollution from dust and emissions outside the immediate site boundaries.

Allow the conditions to arise where the ground becomes unstable and liable to landslips.

Standards 2.1, 5.1, and 6.1 to 6.14 inclusive.

Water resources

Keep earthworks, tracks, roads and other cleared areas as far as possible from water courses or bodies.

Where earthworks, tracks, roads and other cleared areas are within 50 metres of water courses or bodies, take special care to ensure that fuel, oil and other hazardous substances, and any earthworks, are properly contained.

Ensure that all private and community water supplies are safeguarded. Confirm the location of local water supplies with the CLO.

Water resources

Allow leakages of fuel, oil or other hazardous materials.

Dispose of anything into a water course or standing water body.

Use any chemical without prior consent.

Extract so much water from a supply that the normal users are short.

Standards 5.1, 5.2, 5.3, 9.1.




Issues Specific to this Environmental Management Plan: Quarry Preparation



Drainage systems

Provide culverts wherever water needs to flow across a track or road.

Ensure water from culverts and other drains is discharged at low energy via drop structures and aprons.

Make temporary drains as necessary to avoid waterlogging or erosion. These must be adequate for accumulated runoff water as well as rainfall.

Discharge drains into well vegetated areas. Provide mini silt collection ponds if drains must discharge straight into water courses.

Drainage systems

Leave long gaps between culverts or turnouts, so that a lot of water flow builds up.

Allow sediment from bare eroding surfaces to be washed into water courses.

Standards 5.1, 6.1, 6.2, 6.6.

Roads and tracks

Enforce transport rules and regulations rigorously.

Avoid using public roads to the maximum extent possible.

Minimise road construction to serve purposes.

Minimise vehicle movements.

Conduct driving safety awareness campaigns.

Maximise the use of excavated material in access road construction.

Liaise with the Ministry of Public Works to carry out inventories and condition surveys of public roads, bridges and culverts to be used by the project vehicles, and contribute to their rehabilitation and maintenance, as necessary.

Include hydrological assessment and the building of effective road drainage and culverts in all road designs.

Control drainage water, and protect watercourses and wetlands from sedimentation and pollution.

Impose security and restricted access around active road construction working areas.

Roads and tracks

Allow landtake for access and haulage roads beyond the minimum required to construct the roads required.

Construct roads across or close to culturally significant sites.

Allow dust generation to affect the ambient air quality outside the site.

Spray dust suppression water at such rates that it causes erosion and washing out of the roads.

Tolerate any poor behaviour, dangerous driving or even minor traffic infringements by any Company staff or Contractors.

Standards 6.4 to 6.14 inclusive.

ArcelorMittal Liberia Transport Rules.




Issues Specific to this Environmental Management Plan: Quarry Operation



Quarry operation – general

Ensure that only the approved quarry areas are used throughout the re-opening and operation period.

Ensure quarry plans include drainage assessment and water management controls.

Maintain the quarry area in a clean, safe and efficient condition.

Rehabilitate the quarry fully to its baseline condition after work has ceased (see Project Brief).

Ensure that quarry blasting does not create excessive noise and vibration disturbance to wildlife and communities.

Ensure proper geotechnical management so that excavation and tips do not trigger slope instability.


Allow runoff to cause contamination and siltation of water bodies.

Allow emissions and dust to affect the ambient air quality outside the immediate site boundaries.

Allow excessive noise and emissions from crushers.


Stockpiles, waste dumps and sedimentation ponds

Design footprint and phasing of earthworks, stockpiles and waste dumps development to minimise impacts

Confine effects to one catchment, as far as possible.

Capture and remove waterborne sediments and regulate runoff discharge.



Change or adversely affect the hydrological regime and cause long term siltation of watercourses.

Create the potential for unstable ground and landslips.

Allow dust from the stockpiles and waste dumps to pass outside the immediate site boundaries.


Dust Ensure that rock is wetted by a constant water

stream as it enters the crusher.

Take appropriate measures to dampen dust during blasting operations.

Place speed bumps to reduce vehicle speeds on dusty haul roads.

Dust

Allow any operation to continue if it creates dust, without taking action as required to remedy the problem.

Standard 4.1.

Noise Provide all site workers with ear protection as

appropriate.

Avoid working at night and on Sundays to the maximum extent possible.

Use explosives only during daylight hours and never on Sundays.

Noise Work within 300 metres of a

dwelling outside daylight hours.

Allow any person to come close to a noisy machine without having ear protection in place.

Standard 7.1.

Explosives and blasting Obtain formal licensing from the government.

Abide by Liberian laws and regulations, and UNMIL guidelines, regarding the handling, storage and use of explosives.

Be particularly strict in enforcing safety regulations when using explosives.

Follow the detailed specifications for blasting provided in this EMP.

Explosives and blasting Allow any unauthorised person to

have access to explosives.

Allow anyone to use welding equipment, smoke, cook food or light any fire within 50 metres of an explosives store.

Deviate from strict safety standards when handling or transporting explosives, and blasting.

Standard 10.8.




Environmental Management Principles Common to All Sites


(see Standards Manual)

What you MUST do What you must NOT do

General principles

Avoid damage to any part of the environment (soil, plants, animals, human resources and settlements) as far as possible.

If damage cannot be avoided, then mitigate or compensate for the damage.

Follow the ArcelorMittal Environmental Policy.

Respect the environment: we have only one planet!

General principles

Undertake any work beyond the agreed boundaries of the work sites.

Undertake any work before agreeing mitigation or compensation arrangements.

Hide any damage or pollution. In the event of an accident, it is better to consult the Environmental Team and agree a mitigation plan than to risk prosecution under the law.

Section 5 of this EMP.

Standards 13.1 to 13.3.

Environmental awareness

Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main environmental messages.

Ensure that all professional and technical staff respect the environment and understand why.


Allow staff and workers to neglect environmental issues. This may lead to offences under the Environment Protection and Management Law.

Ignore blatant disregard for environmental and social issues by professional and technical staff.

Standards 12.1, 12.2.

Respect for local communities

Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main messages regarding respect for the local communities.

Ensure that all professional and technical staff respect the local communities and behave well.


Ignore blatant disrespect for communities by professional and technical staff.


Provision of safety equipment

Provide all workers with safety equipment appropriate to the work that they are doing

Keep first aid kits on all work sites.

Ensure that there are two people on each work site who know what to do if there is an accident and how to use the first aid kit.

Remember that safety gear is cheaper than hospital and funeral bills!


Allow workers on to a site unless they are wearing the appropriate safety gear.

Allow first aid kits to become empty or out-of-date.

Standard 1.1.

H&S Manual and Rules.

Use of cultivated land

Avoid the use of cultivated land wherever possible. This includes fallow agricultural land, rubber and other tree plantations.

Where use of such land is required, check with the CLO at last four weeks prior to commencement of activities (ideally earlier) that mitigation measures have been agreed and implemented.


Start using cultivated land before the occupier has fully agreed the compensation strategy, all amounts have been paid and this is confirmed by the CLO.

Damage crops or land beyond agreed boundaries.

Allow any new farms to be created in the vicinity of tracks, roads or any other work sites.

Standards 3.1, 3.2, 3.3.

Local people’s livelihoods

Establish an equitable and fair employment strategy. Liaise with the CLO to ensure that it is understood in the local communities (i.e. that it is transparent).

Give priority to local people in labour crews, and those who used to earn livelihoods on land in the mining concession.


Pay local people below the usual wage rates.

Demand unpaid work by local farmers or others.

Standard 3.4.








Damage to cultural sites

Check with local people, through the CLO, as to whether any activities will affect sites of cultural or religious importance.

Avoid any works where cultural sites might be affected, as far as possible.

If damage to cultural sites cannot be avoided, agree compensation measures with the local community, through the CLO.


Damage any sites of cultural or religious importance without first agreeing compensation arrangements.

Standards 3.1, 3.2, 3.3.

Plants

Only cut vegetation that is in the way. This means plants that are in the direct area required for the access track, mining area or other purpose.

Plants

Cut more vegetation than is necessary for site access and working.

Use fire to remove vegetation.

Burn cut vegetation.

Standard 2.1.

Animals

Instruct workforce not to hunt, deal in or transport bushmeat on site.

Provide meat from domestic animals if there is no alternative.

Animals

Allow any use of fire.

Expect workers to live in places where there is no source of meat from domesticated animals.

Allow non-Project people to use the mine tracks and roads by providing gates and guards.

Standard 2.2.

Increased traffic on public roads

Maintain strict transport rules and regulations.

Undertake community safety awareness campaigns.

Undertake regular driving safety awareness campaigns to ensure safe driving.

Continue operating radar gun speed traps.

Maintain close liaison with Liberian National Police traffic control units.




Sanitation at work sites

Provide proper water closet toilet facilities at all long term (> 1 month) work sites.

Maintain all toilets in a clean and sanitary condition.

Provide proper earth pit latrines at all work sites where work will be undertaken for periods of up to one month.

Fill the latrines in once site work is complete.


Allow water to run out at toilets, or for them to be left uncleaned.

Allow latrines to become full or overflow.

Allow site workers to defecate in the open anywhere on the site or in its vicinity.

Standards 1.2, 1.3.

Pollution from site camps and stores

Ensure that all potentially hazardous materials (i.e. fuel, oil, other chemicals, sewage) are stored or disposed of in appropriate ways.

Devise on-site emergency spillage plans and train staff in their implementation.

Remove all debris and litter from site.


Allow any pollution to occur to the soil or water courses.

Standards 9.1, 9.2. 9.3, 10.1, 10.2 and others as appropriate.








Fuel and oil storage

Follow the hazardous materials management guidelines fully.

Only use the designated storage areas, with bunding of 150% volume of total capacity.

Only use facilities located down gradient of public water supply boreholes and distant from watercourses.

Ensure that there are retention systems, including walls, bunds and lined drains to contain any spillages.

Ensure that there is hard standing, with a drainage system that includes oil/water separators.

Ensure spill kits and granules are available.

Have controls in place to minimise opportunities for fuel pilferage.

Dispose of waste appropriately.

Maintain Emergency Response / Fire Fighting teams trained for a spillage event.

Maintain fire fighting equipment at each facility.

Provide training for all personnel handling fuel and oil.


Allow uncontained spills and leakages to occur, leading to soil, and ground and surface water contamination.

Allow soils to become contaminated and effectively sterilised.

Allow water courses to be affected by runoff carrying toxic substances, affecting community water supplies, aquatic biodiversity and wildlife.

Allow waste products that are not collected and stored appropriately to contaminate the surroundings.

Allow emissions of exhausts to pass outside the site.

Allow theft to occur, resulting in spillage and pollution elsewhere.

Allow any potential for explosions to occur.

Standards 9.1, 9.2. 9.3, 10.1, 10.2, and 11.1 to 11.6 inclusive.

Refuelling

Follow the hazardous materials management guidelines fully, which include procedures for refuelling vehicles and generators.

Spill kits are to be carried by all refuelling vehicles.

Keep all fuel tanks in a central location.

Refuel vehicles only on impermeable hard standings with controlled drainage (traps and interceptors).

Plant refuelling on site is to be carried out according to strict protocols for refuelling in unprotected areas.

Enforce the reporting system for spillage incidents.

Train Emergency Response / Fire Fighting teams in readiness for a spillage, fire or other accident.

Keep fire fighting equipment available at each facility.

Provide training for all personnel handling chemicals.

Refuelling

Allow spills and leakages to go uncontained leading to soil, and ground and surface water contamination.





Standards 9.1, 9.2. 9.3, 9.4, 10.1, 10.2, and 11.1 to 11.6 inclusive.








Delivery and handling of hazardous materials


Use the safest available transportation option, preferably rail.

On roads, use convoys with accompanying support.

Deliver only to prepared locations.

Maintain supplies of spill kits and granules in all vehicles and at all offloading locations.

Ensure competent drivers and close supervision.

Provide emergency training to all personnel.

Use international labelling for identifying hazardous substances.

Comply with international standards (e.g. UK COSHH).




Transport hazardous materials on public highways without having supporting vehicles in convoy to take immediate containment action in the event of an accident.

Allow any ground and water contamination from toxic materials.

Allow any potential for explosions and fires to occur.

Standards 9.1, 9.2. 9.3, 9.4 10.1, 10.2, 10.3.

Chemicals storage and use


Select chemicals with the least environmental impact where possible.

Use only chemicals that are certified for use world-wide and approved by the Liberian EPA.

Minimise the volumes of chemicals stored, and reuse them where possible.

Chemicals should be stored down gradient of any public water supply boreholes.

Ensure that all containers are clearly labelled. Labelling must include non-verbal warning signs.

Provide secondary containment for all chemicals.

Ensure that the MSDS is held for every chemical on site





Allow any loss of containment from spills or inadequate disposal.

Allow any chemicals to spill or leak to the environment with toxic effects to soil and water.

Use any chemicals that are not approved by both the Company’s HSE Manager and the EPA.

Use any chemicals known to be mutagenic or which contain substances which bio-accumulate.

Allow any use of chemicals except by fully trained workers.

Allow the use of chemicals in confined spaces if they pose any potential for explosions.

Standards 9.1, 9.2. 9.3, 9.4, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.




2. INTRODUCTION

2.1 The Environmental Management Plan This Environmental Management Plan (EMP) has been prepared as part of the overall Nimba Western Range Iron Ore Deposits concession (the project) to rehabilitate, operate and expand former iron ore mining, processing, and export infrastructure. The primary purpose of this plan is to assist in conducting all project activities in accordance with applicable environmental requirements. Under the current Phase 1 of the project, ArcelorMittal Liberia (“the Company”) and its Contractors are mining direct shipping iron ore (DSO) at sites on Mounts Tokadeh, Gangra and Yuelliton, in the Western Range Deposits of Nimba County, Liberia. The ore is being transported from the mine to a crushing and screening plant. From there it is moved by rail to the Port of Buchanan. At the port it is stockpiled and then loaded on to ships. The schedule is to export 1 million tonnes of ore in 2011 and 4 million tonnes per year from 2012 to 2015 inclusive. Under the proposed Phase 2 of the project, the Company intends to mine lower grade iron ore at the same three mountains, and to beneficiate it through a concentrator that will be constructed close to Mount Tokadeh. As with the DSO, the concentrate will be transported by rail to Buchanan, stockpiled and loaded on to ships. The schedule for this phase is to export 15 million tonnes per year from 2016 to 2026 inclusive. This document covers the operation of the following Company Quarries over a two to three-year period:

Glaton Hill near Yekepa, Nimba;

Greenhill, near Zowienta, Bong; and

Neekreen, near Buchanan, Grand Bassa. This is specifically for the production of construction materials for Project Phase 2 (the Western Range Iron Ore Concentrator Project). All of the Company’s EMPs are “live documents”. This plan will be updated as needed to reflect changing operations, areas of working and any lessons learned. The objectives of the EMP are to:

Define the specific control measures relating to the operations that it covers, to ensure compliance with the conditions of the Environmental Certificate granted by the EPA, and other applicable environmental and social documents;

List site-specific and activity-specific environmental and social requirements, in terms of the procedures to be followed, timing and standards of completion, and reporting and monitoring;

Define responsibilities between the Company and its Contractors with respect to environmental compliance and social or community issues; and,

Assign corresponding roles and responsibilities to the Company and the Contractors’ personnel.

2.2 Approved Activities Approved activities under this Environmental Management Plan are restricted to the following. Full details are given in the Project Brief, which must be referred to if there is any doubt as to the extent of the activities or the areas where they are permitted. (a) Preparation of Quarries (if necessary to improve facilities) The following activities are approved to be undertaken with respect to the re-opening of the former LAMCO quarries at Glaton Hill, Greenhill and Neekreen.

Detailed resettlement survey. A detailed survey will be undertaken to ascertain the presence of dwellings and farms within each former quarry area and within a 500-metre radius of the quarry working area.

Access track improvement. The access tracks will be regraded and provided with proper drainage turnouts and additional culverts.




Clearance of the quarry benches and other working areas. The working areas will be cleared of vegetation, soil and rock debris, to make a clean, safe and efficient working area.

Installation of magazine. A simple explosive magazine will be located in one of the safe working areas at each quarry.

(b) Operation of Quarries The activities proposed with respect to the operation of each quarry are as follows.

Blasting warning procedure. A strict procedure will be developed for warning, evacuating and compensating people who have any chance of being in the 500-metre fly rock danger zone during blasting operations.

Quarrying of rock. The approved requirements are for the quarrying of a maximum of about 300,000 m

3 from each quarry, of aggregate, rail ballast, rip-rap, sand and mixed road-building

materials.

Actual quarrying. The face will be drilled and blasted according to the safety guidelines. Loosened rock is then to be pulled away from the base of the quarry face using bulldozers, pay loaders and excavators. From there it is loaded into tipper trucks to be hauled the short distance to the crusher.

Crushing and screening. In each case, the contractor selected as the quarry operator will be required to bring a modern mobile crusher and screening unit to the quarry. These will be set up close to the site of the former LAMCO crusher at each location.

Material washing and water use. Aggregate and sand to be used for concrete needs to be washed to remove fines and ensure that it meets the engineering specifications. Water for this process is to be taken from the ponds that were formerly used as sediment traps and reservoirs, and is to be re-used through a recycling pond system.

Generation of quarry waste. Waste generation from the quarries will be minimal, and is expected to be used for road sub-base material.

Haulage to site. From Glaton Hill, materials will be hauled to site using ordinary three-or four-axle road tippers. These will only be permitted to travel during the hours of daylight. They are obliged to follow a specified route, crossing the Dayea River at the lower of the three bridges in Yekepa. At Greenhill the materials will be loaded directly into rail wagons at the rail spur loading site beside the stockpile yard, and transported to the construction site by rail. At Neekreen the materials to be used at the Buchanan site will be transported by truck along the quarry access road, and then along the main highway, bypassing the city via the Own-Your-Own Road, to the concession area. If any materials from Neekreen are to be used along the railway or at Tokadeh, they will be hauled by truck along the route of the former LAMCO rail spur and loaded on to rail wagons at the km 12 rail spur loading site used in 2008-09.

Traffic generation. The maximum haulage permitted is five trucks per hour, or forty trucks per eight-hour day on any public road.

Hours of operation. Night-time working is to be avoided because of the proximity of settlements. The operations will not involve more than day-time operation, probably from 7am to 6 pm for the crushing.

Duration of quarrying. The duration of use of the quarries will be for the full period of construction for Project Phase 2. This is currently scheduled for the dry seasons of 2012-13 and 2013-14, but may spill over into the dry season thereafter (i.e. 2014-15). Quarrying will therefore be for a maximum of three dry seasons.

(c) Post-operational Decommissioning of the Quarries The following activities will be undertaken to decommission and restore the quarries once operations cease.

Removal of equipment. Once quarry operations are complete, the first stage of closure will be the removal of all equipment.

Making slopes safe. The quarry faces will be stabilised by the removal of any loose rocks.

Revegetation. All bare surfaces that can support vegetation (i.e. everywhere except hard rock faces) will be planted using the company’s revegetation procedures using transplanted grass slips or tree seedlings.

Greenhill Quarry may be kept open to provide ballast for operational period rail maintenance.




2.3 References The Company and Contractors must comply with or exceed the requirements of all relevant legislative statutes and regulations, specifically including but not limited to the following. (i) The Environmental Certificate granted by the EPA against the stated activities and mitigation

measures described in the Environmental and Social Impact Assessment for the Western Range DSO Iron Ore Project, 2011-15, dated September 2010.

(ii) The Environmental Protection and Management Law (2002). (iii) The Mining Licence granted by the Ministry of Lands, Mining and Energy in August 2005. (iv) The Minerals and Mining Act (2000).




3. ARCELORMITTAL ENVIRONMENTAL POLICY The Company, as an operating division of ArcelorMittal, must abide by the corporate Environmental Policy. All suppliers are also required to abide by the policy, and take responsibility for any adverse environmental impacts resulting from their actions. For ArcelorMittal Liberia, most of the practical aspects of site working in the Company’s global Environmental Policy are contained in the Policy on Caring for Nature. This is given on the next page. Key elements of the global Environmental Policy and other policies are as follows.

The implementation of environmental management systems including ISO 14001 certification for all production facilities;

Compliance with all relevant national environmental and community engagement laws and regulations, and other company commitments, to keep the company’s environmental impact to a minimum; and

Working towards a goal of zero accidents and injuries in the promotion of a healthy and safe working environment.

To ensure that these policies and plans are delivered at the local level, the company has put into place a management and monitoring framework which places the onus on national operating companies to deliver the company commitment. As part of its response, ArcelorMittal Liberia Limited has developed a Corporate Responsibility Plan, within which it pledges high standards of environmental and social safeguards.







4. ARCELORMITTAL LIBERIA ENVIRONMENTAL STANDARDS This Environmental Management Plan is to be implemented in accordance with the provisions of the latest version of the Company’s Environmental Standards Manual. Normally the Manual is issued with the EMP, but it is the Employee’s and Contractor’s responsibility to check with the Company’s environmental staff that they are still working to the latest standards. The list of standards current at the time of finalisation of this document is given below (taken from the version dated 1 March 2013).

1. WORK SITE STANDARDS

1.1 Standard for Safety Gear Provision to Site Staff and Workers

1.2 Standard for Pit Latrines

1.3 Standard for Disposal of Waste from Chemical Toilets

1.4 Standard for Burning or Burial of Rubbish at Temporary Camps

1.5 Standard for Conduct by Employees in Railway Operation

1.6 Standard for the Management of Waste

2. FOREST PROTECTION STANDARDS

2.1 Standard for Bush Clearance, Tree Felling and Use of Chainsaws

2.2 Standard for Bushmeat Hunting, Dealing, Transporting and Use

2.3 Standard for Clearance of Caves, Adits and Tunnels

3. COMMUNITY RELATIONS STANDARDS

3.1 Standard for Community Engagement

3.2 Standard for Contractor Identification of Land Access and Community Interaction

3.3 Standard for Acquiring Land and Other Assets

3.4 Standard for Employment of Temporary Construction Labour

3.5 Standard for Staff Behaviour

3.6 Standard for Handling Grievances

3.7 Standard for Unexpected Cultural Sites and Archaeological Finds

4. AIR QUALITY STANDARDS

4.1 Standard for Air Pollution Prevention and Control at Mine and Quarry Sites

4.2 Standard for Emissions Limits from Heavy Diesel Engines

5. WATER AND SOIL QUALITY STANDARDS

5.1 Standard for the Control of Water Pollution

5.2 Standard for Water Quality

5.3 Standard for Effluent Quality

5.4 Standard for Soil Contamination Screening

6. EROSION CONTROL AND REVEGETATION STANDARDS

6.1 Standard for Mine Drainage and Sediment Capture

6.2 Standard for Settlement and Attenuation Ponds

6.3 Standard for Mine Spoil Tips

6.4 Standard for Topsoil Stripping, Stockpiling and Restoration

6.5 Standard for Constructing and Maintaining Earth Tracks

6.6 Standard for Simple Drainage Systems

6.7 Standard for Slope Protection by Stone Pitching

6.8 Standard for Spillways Lined with Soil-filled Bags

6.9 Standard for Stone-filled Gabions

6.10 Standard for Check Dams

6.11 Standard for Selection of Revegetation Techniques for Erosion Prevention

6.12 Standard for Revegetation using Planted Grasses

6.13 Standard for Revegetation using Hardwood Cuttings (Brush Layers)

6.14 Standard for Revegetation using Shrub and Tree Seedlings

6.15 Standard for Drainage Systems on Major Roads

6.16 Standard for Slope Cutting Grades




7. NOISE AND RADIATION STANDARDS

7.1 Standard for the Limitation of Noise Emissions

7.2 Standard for Radio and Microwave Emissions

8. VISUAL APPEARANCE STANDARDS

8.1 Standard for the Colours of Structures

8.2 Standard for Night-time Lighting of Work Sites

9. POLLUTION PREVENTION STANDARDS

9.1 Standard for the General Prevention of Pollution at Work Sites

9.2 Standard for Avoiding and Treating Spills

9.3 Standard for Action to Clean Up Spills

9.4 Standard for Pollution Prevention from Ships

9.5 Standard for Ships’ Ballast Water Management

10. HAZARDOUS MATERIALS STANDARDS

10.1 Standard for the Storage, Dispensing and Disposal of Hazardous Materials

10.2 Standard for the Cleaning-up of Pollution by Hazardous Materials

10.3 Standard for Operation of the ArcelorMittal Liberia Medical Waste Incinerators

10.4 Standard for the Use of Wood Preservative

10.5 Standard for the Use of Herbicide

10.6 Standard for the Removal of Paint from Steel Bridges

10.7 Standard for the Disposal of Waste Containing Asbestos

10.8 Standard for the Use of Explosives in Quarries and Mines

11. FUEL HANDLING STANDARDS

11.1 Standard for Bunding Temporary Fuel Tanks

11.2 Standard for Dispensing Fuel at Temporary Site Camps

11.3 Standard for Pollution Prevention from Above Ground Oil Storage Tanks

11.4 Standard for Oil Separators in Surface Water Drainage Systems

11.5 Standard for Preventing Pollution from Refuelling Facilities

11.6 Standard for Pollution Prevention in Vehicle and Plant Workshops

11.7 Standard for the Remediation of Oil-contaminated Soil

12. ENVIRONMENTAL EDUCATION STANDARDS

12.1 Standard for Briefing Site Crews

12.2 Standard for Briefing Professional and Technical Staff

13. ENVIRONMENTAL POLICIES

13.1 ArcelorMittal Corporate Environmental Policy

13.2 Government of Liberia’s Environmental Principles

13.3 ArcelorMittal Liberia’s Policy on Caring for Nature




5. ENVIRONMENTAL REQUIREMENTS, PLANS AND PROCEDURES This section defines Project-specific environmental and social requirements.

5.1 Protection of Soils The clearing of land for quarrying involves earthworks surface disturbance which will lead to a risk of increased erosion. This will need special care to be taken to ensure that there is no unnecessary loss of soil or pollution of water resources. The following best practice measures will be adopted.

When clearing land, vegetation clearance shall be minimised to essential areas only.

Cleared areas and removed soils shall be left at as gentle a slope angle as possible, to minimise the risk of slippage and erosion, and enable rapid revegetation.

Where surfaces remain bare at the commencement of the rainy season, and hence vulnerable to erosion, temporary low cost erosion control measures shall be implemented as required by the Environmental Officer.

Temporary culverts and drainage turn-outs will be installed wherever necessary. Turn-outs will divert run-off water into well vegetated areas where it will dissipate harmlessly.

Stockpiles of soil will be planted with suitable vegetation following Company standards.

5.2 Maintenance of Water Quality (a) Protection from sediment The proposed works are relatively small but still present possible risks to the surface water environment within the project areas. There is greatest potential for impacts on water quality associated with increased sediment load due to the high erosion potential of the soils when they have been disturbed. There is also some potential for localised impacts on water quality arising from accidental spillage and discharge of potentially polluting materials such as fuel and oil, and for localised erosion or flooding due to inappropriate construction site or road drainage. The Project shall adopt the following measures to limit impacts on surface waters.

All drainage from the quarry is to be directed into the existing LAMCO-era attenuation and sedimentation ponds, to still water and remove suspended silt- and sand-sized particles before the water is released into natural drainage lines.

All bare surfaces will be protected through comprehensive drainage and flow protection devices, to ensure that runoff is collected and removed from the site safely.

Tracks and roads will be provided with suitable culverts and drains to direct water run-off away from surface water bodies or streams and into well vegetated areas where it can soak away safely.

Water courses within 150 metres of any work site will be monitored for raised levels of suspended sediment before, during and on completion of operations.

(b) Protection from spills On a large project, spills of fuel and lubricants are inevitable at some point. For this reason the Company aims to have the capacity to respond rapidly to spills of small and medium size, and to respond adequately to large spills (which would constitute a major environmental disaster). The following provisions are made.

Fuel and oil storage areas are being adapted to ensure that they comply with international standards for bunding and spill retention.

Oil spill clean-up kits are provided at all fuelling stations, on fuelling vehicles, in workshops and in the vehicles used by Health, Safety and Environment Department staff.

Oil absorption mats. The Company will maintain a large stock of absorbent materials ready in case of a spill, in the warehouse at Buchanan.

A response team will be trained and maintained ready under the direction of the SHE Manager, to respond in the event of any spill.




5.3 Protection of Ecology In order to avoid unnecessary disturbance to plants and animals near to Project work sites, the following good practice measures shall be adopted.

The hunting of protected bushmeat shall be prohibited by members of the workforce while employed by the Company or any of its Contractors.

When moving through project areas, personnel shall follow, where possible, previously used roads, tracks or disturbed areas.

Vegetation shall not be burned following clearance, but shall be used to mulch the surface or piled beside the site for later use or to rot down.

Barriers shall be provided at the entrance to the quarry site and staffed permanently, to limit vehicular access to project areas.

5.4 Maintenance of Air Quality Dry season dust generation from stockpiles, exposed earthworks and moving vehicles is a concern. This will be minimised by reducing exposed surfaces and revegetating soil (see section 5.1). If traffic-induced dust becomes a problem, water bowsers will be used to spray the roads. Air particle sensors are already installed at strategic locations to determine raised levels.

5.5 Sanitary Waste Disposal Properly engineered toilets will be provided at long term work sites. Earth pit latrines will be provided at all work sites where it is not practical to install proper toilets. They shall be backfilled when their use is finished.

5.6 Waste Management The following good practice measures shall be adopted, in conformance with the Company’s Environmental Standards Manual.

Contaminated soils resulting from any accidental spills at machine refuelling sites will be removed and transferred to a designated waste site. This shall be in a location identified in the waste management plan. The contaminated soil will be treated with a bioremediation agent.

Industrial waste will comprise items such as used lubricants, filters, tyres, batteries and personal protective equipment. These will be stockpiled until there are quantities adequate to make disposal cost effective, and will then be dealt with according to their nature and the availability of Company-checked and EPA-approved dealers or disposal sites.

Scrap iron and steel will be stockpiled until there is sufficient quantity for export. It will then be sent to an ArcelorMittal steel mill specialising in steel recycling.

Non-ferrous scrap (e.g. aluminium, copper and lead) will be stockpiled until adequate quantities are available for sale to an approved dealer.

Household waste will mainly be placed in an approved landfill site. Food waste is to be fed to domestic animals wherever possible. Recycling will be increased as facilities become available in Liberia.

Asbestos waste may be encountered in materials brought into the quarry area by farmers from former LAMCO buildings. This will be dealt with in consultation with the Environmental Protection Agency, following the Company’s Environmental Standards Manual (standard 10.7).




5.7 Storage of Materials The following good practice measures shall be adopted.

All hazardous liquids – fuel for machines, lubricants, solvents, other chemicals, cement, etc – shall be stored and handled in a manner so as to minimise the risk of a release to the environment, and in accordance with the Company’s Environmental Standards Manual.

The Company has a hazardous material spill clean-up plan (following the Company’s Environmental Standards Manual) and the contractor is required to provide all necessary equipment at the project work site in support of the plan. It will also ensure that field personnel are appropriately trained in its implementation under emergency conditions.

5.8 Avoidance of Community Land No private or community land will be affected by this component of the project. Some shifting agricultural land will be affected: this will be assessed and the households compensated following the procedures given in the Company’s Resettlement Manual.

5.9 Protection of Cultural Sites No works are anticipated in the vicinity of any cultural sites. These have been comprehensively assessed through the community liaison and resettlement programmes, and none has been identified.

5.10 Employment of Local People The Company and its Contractors will make their best efforts to employ local Liberian labour where practicable. To this end, a fair and transparent employment scheme has been established in consultation with the County Labour Commissioners. Once a works Supervisor or Contractor has identified his unskilled labour needs, he shall pass this information to the Community Liaison Officer. The CLO will then make an initial approach for local labour through the community Chiefs and Elders at a public meeting. When recruiting unskilled day wage labourers, the Company and Contractors will take into account the population distribution across the communities surrounding the particular area of operations, with priority given to those from communities most likely to be affected by the development.

5.11 Health and Safety of Workers Supervisors and Contractors are responsible for maintaining the health of all employees and labourers during the period of employment. Contractors shall make available, free of charge, all necessary personal protective equipment as required for the site of working. Prior to mobilisation, Contractors shall provide the Company with evidence of employee accident and liability insurance to cover all workers regardless of employment status.

5.12 Worker Facilities The workforce shall be provided with the following:

1. Supplies of clean water; 2. Suitable first-aid facilities; 3. Personal protective equipment as necessary and as per the Company’s Environmental

Standards Manual, and Health and Safety Policy.




6. MANAGEMENT OF WARNINGS AND EMERGENCIES

6.1 Early Warning Systems The following early warning system is to be in place for this component of the project. Quarry site clearance (a) The quarrying works covered by this EMP will all be in areas that are guarded against encroachment by unauthorised personnel. The main danger is therefore to workers from one part of the site moving to other areas where they are unfamiliar with the hazards. (b) Well in advance of the commencement of operations, the Company shall demarcate the outer perimeter of the exclusion zone and mark it on the ground. (c) Within the exclusion zone, a survey shall be undertaken to identify all hazards. This will be used as the basis for a complete removal of safety hazards from the affected area. (d) The Company will deploy security personnel to patrol and enforce the exclusion zone, and ensure that workers are kept aware of safety issues in different parts of the site. Warning of blasting operations (a) Blasting operations will be announced at least one week in advance and the timing agreed with the Company’s Community Liaison Officer. (b) Notices of blasting will be posted at prominent locations at the quarry access road and other approaches to the area. (c) The day before any blasting, the quarry operator and the Community Liaison Officer will visit all households judged to be close enough to the 500-metre fly rock exclusion zone as to require warning of evacuation. (d) On the day of any blasting, additional security will be deployed around the quarry and patrols made to enforce the exclusion of people from the 500-metre safety zone. (e) The operator will sound a loud siren 15 minutes and 5 minutes before the blasting shots are fired. The operator will separately ensure that all quarry workers and security guards are warned and removed to an approved safe location before the blast.

6.2 Emergency response plans An emergency response plan is in place to cover:

Accidental spills of hazardous materials;

A major spill arising from a train derailment;

Other accidents involving personnel on the work sites; and

Major failures, such as earthquakes, landslides, tsunamis, mine failures, structural collapse, etc.

The environmental emergency response plan is linked to the Company’s overall Emergency Response Plan. This is a restricted document since it covers a number of security and other sensitive issues, but the environmental aspects are described here in some detail. The overall Emergency Response Plan (ERP) provides the Company with the framework and guidance to respond effectively to emergencies or serious incidents, reducing their impact on the project, its people, property and operations. The ERP and its attendant Incident Response Procedures should enable the Company to respond effectively to a wide range of adverse events,




thus reducing any subsequent impact on the Company, its staff and the surrounding environment. As well as environmental emergencies, the ERP covers explosion, fire, bomb threat, threats to personnel, suspect mail, missing persons, kidnap and ransom, extortion, medical emergency, fatality, disease outbreak, civil unrest, natural disaster, armed attack and robbery. The priority in resolving any emergency incident and for business continuity management will always be:

The safety and security of people;

The protection of assets;

Protection of the environment;

Adherence to the law; and

The timely re-activation of business functions. Emergency Response Team In the event of an emergency of any kind, a Company Emergency Response Team is detailed to assemble at an Emergency Control Centre in the Buchanan concession. This takes overall responsibility for all emergency incidents affecting all or significant elements of the Company’s operations. Once the nature of the emergency is understood, the ERT determines the appropriate composition of an Incident Response Team (IRT) to deal with the problem. The IRT would be based at the appropriate concession location (Yekepa or Buchanan) and would typically be led by the Company’s Security Manager, who is required to be trained in a wide range of emergency response procedures. Any environmental disaster would automatically have the HSE Manager co-opted into the IRT as a key adviser. The IRT would then operate under the overall direction of the ERT, which would typically be led by either the Chief Operations Officer (COO), or the appropriate Manager (Mine, Rail or Port) to ensure that adequate resources and authority for actions are immediately available. The ERT would provide management guidance for the IRT in addressing the emergency. Some of the procedural guidelines for use by the ERT and IRT are discussed below, but these are only a small part of the comprehensive guidelines and checklists in the restricted Emergency Response Plan. Emergency Reporting Checklist This is one of the emergency management tools used by the Incident Response Team. It has a number of different categories to cover different possible incidents. The following is the section that covers environmental issues.

MINOR Report – Same Day

SIGNIFICANT Report – 1 HOUR

MAJOR Report – Immediately

ENVIRONMENTAL ENVIRONMENTAL ENVIRONMENTAL

• Hydrocarbon spill < 25 litres • Recovered & cleaned immediately • No off site impact potential

• Hydrocarbon Spill 25-200 litres • Recovered & cleaned immediately • Fire in railway corridor • Put out immediately • Off site impact possible

• Any spillage into a waterway or any other contamination of ground close to waterways or villages • Any spillage of material (liquid or solid) outside Company industrial sites • Any spillage of liquid > 200 litres irrespective of location

Other emergency incident management tools are as follows.

Incident Notification Form

Major Incident Post Incident Report Form




Whereabouts Board

Telephone and Communications Log (for serious incidents)

Persons On Board List Immediate Response Guidelines for an Environmental Disaster These set out the recommended guidelines for the IRT’s response to the more common emergency incidents. They are designed to assist Company staff to consider appropriate responses and make the best possible decisions during emergency situations. It is important to note that detailed prescriptive planning for every scenario is both impractical and unwise, as there is a danger that flexibility could be lost. However, these guidelines serve as a useful prompt at each stage of incident resolution. The tables below show the guidelines for environmental disaster response. The Incident Response Team Leader (IRTL) would typically be the Company Security Manager. PHASE 1: Notification & Escalation – Immediate Actions

# Action Responsible

1 Immediately advise the IRTL, using the Incident Notification Form as a guide for what information needs to be passed.

Observer

2 Establish the nature of the disaster (e.g. solid or liquid material spill) and the nature of the environment affected (e.g. water course, urban area, empty bush land).

IRTL

3 Establish the need for immediate evacuation of casualties or people in danger.

IRTL

4 Notify the site manager immediately if there is any likelihood that the disaster may have an impact on AML’s facilities.

IRTL

5 Notify the Environmental Protection Agency immediately if there is any likelihood that the disaster may have an impact on any land or water resource outside of AML’s facilities.

HSE Manager

6 Record all events, actions and decisions in an Incident Management Log.

IRTL

PHASE 2: Event Containment – Follow Up Actions


7 Determine the events surrounding the environmental disaster:

What type of disaster is it?

Has the immediate risk passed, or does it still exist?

In the case of an impending disaster, what is the expected scale and what areas are likely to be affected?

Is the problem basically soil- or water- or urban-based, or a combination of these?

If water-based, what is the scale of downstream catchment affected?

IRTL

8 Determine the exact nature of the environmental fall-out, both immediate, impending and long term.

HSE Manager





9 Determine whether the Company or its Contractors have the capacity to deal with the incident, or whether specialist support is required.

HSE Manager supported by IRTL

10 Determine what people or assets are threatened in proximity to the event.

IRTL

11 Notify the Environmental Protection Agency if this has not already been done in Phase 1.

HSE Manager

12 Outline the action that needs to be taken to contain and rectify the problem:

What resources are needed?

Who should be assigned to what tasks?

What is the sequence of actions?

What authority is needed to implement the response?

IRTL supported by HSE Manager

13 Verify what action has been taken to date through the observers IRTL

14 Verify the actions and resources needed for containment or rectification, obtain necessary authority and commence implementation.

IRTL

15 Contact all principle staff clusters and advise them of the situation. HR

16 Notify the Environmental Protection Agency of the actions being taken and resources mobilised.

HSE Manager

17 Issue an information bulletin via public radio. IRTL

18 Monitor the containment or rectification process and modify as necessary.

HSE Manager

PHASE 3: Event Recovery – Not Time Critical


19 Ensure that the containment process is completed fully and effectively.

HSE Manager

20 Ensure that the rectification process is completed fully and effectively.

HSE Manager

21 Verify the impact on people, assets and the environment. Identify any further actions that may be necessary.

IRTL supported by HSE Manager

22 Issue information bulletin updates as appropriate via public radio. IRTL

23 Monitor local media and be prepared to issue media releases to quash rumours, should they develop.

IRTL

24 Request Environmental Protection Agency to review action taken and ascertain further needs.

HSE Manager

25 Conduct a post-incident review of incident management procedures.

IRTL

26 Conduct a post-incident impact assessment. IRTL





27 Ensure lessons learnt are ploughed back into Company and Contractor procedures to avoid a repeat.

COO

28 If the incident had security-related implications, consider the need for an increased physical security presence and preventative security measures.

IRTL

29 Consider the requirement to conduct an additional environmental audit.

HSE Manager

Incident Response Team: HSE Manager’s responsibilities The Health, Safety and Environment Manager is a member of the Incident Response Team. His or her responsibilities can be summarised as:

Identify HSE impact of the situation;

Ensure sufficient resources available for consequential management;

Initiate Flash Report; and

Co-ordinate incident investigation. The detailed roles and responsibilities for the HSE Manager are as given below.

# IRT Responsibilities – HSE Manager

1 Join the Incident Response Team as soon as informed by the Emergency Response Team or the IRTL. Until further notice the incidence response takes precedence over all other work or leave. It may require immediate travel to and residence at a different site.

2 Develop as full an understanding as possible of the nature of the incident and the possible immediate and long term impacts on all aspects of the environment.

3 Advise the IRTL on immediate actions that are required to counteract the initial impacts on the environment.

4 Determine what other resources are required to provide detailed specialist technical support, and request the IRTL to arrange these.

5 Decide whether to notify the Environmental Protection Agency in either Phase 1 or Phase 2 of the incident response (see Incident Response Guidelines). Once the EPA has been notified, establish a liaison point within the Agency and arrange to keep them updated as events develop.

6 Work closely with the field teams mobilised by the Company to deal with the incident.

7 Advise the IRTL on the longer term actions and resources that are required to contain and rectify the incident. Emphasis must be given first to minimising and then to rectifying impacts on the environment.

8 Monitor the incident response and ascertain whether it is proving effective. Advise the IRTL of any modifications or additions that are necessary to the response.

9 Once the response is substantially complete, check all of the work done and ascertain that it has been fully undertaken to a satisfactory and effective degree.

10 Work with the Environmental Protection Agency to review the actions taken, the lessons learnt and any further work that is required.

11 Produce a formal environmental audit report covering the entire incident and response, on behalf of the Company.




7. ENVIRONMENTAL COMPLIANCE CONTROLS The following primary management controls shall be implemented with the aim of ensuring that all activities are conducted in accordance with applicable environmental requirements and best practices:

1. Environmental and Social Awareness Briefing for Site Crews; 2. Environmental and Social Awareness Briefing for Professional and Technical Staff; 3. Environmental Compliance Reviews and Co-ordination Meetings; 4. Community Consultative Meetings; and 5. Environmental Compliance Inspections and Documentation.

7.1 Environmental Awareness Briefing for Site Crews All site crews of the Company or its Contractors shall be briefed on key environmental issues before starting work in the field. This shall be done at the start of each package of work and at the beginning of each working week. It is expected to take only about ten minutes. The environmental awareness messages shall also be displayed in notices on the site, which shall be painted or laminated, and maintained for the duration of site works. As a minimum, the following issues shall be raised:

1. Environmental matters: awareness of the special natural environment of the project sites and Liberia’s environment in general; essential behaviour;

2. Safety issues: the use and check of personal protective equipment, site cleanliness and “housekeeping”;

3. Pollution issues: accident procedures, hazardous materials being used, and handling details. The recommended environmental briefing messages are given in the Environmental Standards Manual (standard 12.1).

7.2 Environmental Awareness for Professional and Technical Staff All professional and technical staff should be aware of the sensitivities of the biophysical and socio-economic environment in which they are working. Managers should remind them of this from time to time, not just to ensure compliance with this Environmental Management Plan, but also to help generate respect for this planet that we all share. The “Safeguarding the Environment” briefing is given in the Environmental Standards Manual (standard 12.2).

7.3 Environmental Compliance Review Meetings Where works are undertaken in-house by the Company, meetings to co-ordinate and review environmental compliance shall be held once per month between the Company’s Manager (Mine, Rail or Port, as appropriate) and the site teams. The teams will normally be represented by the Superintendent, Foreman and Supervisor, as appropriate (see section 8). These individuals will hold the responsibility for environmental compliance by their respective teams. Where works are contracted, meetings to co-ordinate and review environmental compliance shall be held once per month between the Company’s Manager (Mine, Rail or Port, as appropriate) and the Contractors’ Field Managers. The purpose of the meetings shall be to discuss current and future activities as they relate to ensuring environmental compliance. The agenda for each meeting shall be set by the Environmental Officer. It is envisaged that the Environmental Compliance Review Meetings will be held at the same time as other regular site co-ordination meetings between Company management and site teams, or between the Company and its Contractors.




7.4 Local Consultative Forums There are many distinct household groups who are primary stakeholders in the project area as a whole (i.e. people directly affected by some part of the project, either as beneficiaries or adversely affected, such as by loss of property), within the settlements in and around the mine and port sites and the railway. Each group needs to be involved in the project process. These include neighbouring communities, fishermen, owner-farmers, absentee land owners, sharecroppers, landless households, agricultural wage labourers, market sellers, hunters, and their dependent households. Within these groups are important sub-groupings, comprising women working at home, children, the disabled and the elderly. Factors such as ethnicity, and relative wealth and resources, may further divide communities. These factors can result in the exclusion of low status groups from community information systems and participation in decision-making. The Company’s Community Liaison Officers (CLO) have set up Local Consultative Forums (LCF) to keep stakeholders informed, consulted and involved in the project. There is to be one LCF per affected part of a Clan, meeting up to four times a year, but with additional meetings during resettlement activities. As the project progresses, these LCFs will deal in turn with issues relating to design, then resettlement and compensation, and then implementation. Written instructions for the formation, conduct and recording of the LCF meetings are given in the Company’s Resettlement Manual. It is the responsibility of each site Manager and CLO to implement these, beginning with a discussion in a workshop at the start of resettlement activities. The CLO will use the LCF mechanism to meet each Town Leader and representatives of the affected persons (stakeholders who are significantly adversely affected by the project) at intervals throughout the project, and if appropriate a Contractor’s representative will also attend. These meetings are called to consult communities over the works, to disclose the Resettlement Plan formally, discuss compensation difficulties and anomalies, and resolve grievances and outstanding issues. Records are to be kept of these meetings and the decisions agreed.

7.5 Environmental Compliance Inspections and Documentation Company staff and, if appropriate, Contractors shall participate in both regular and non-regular inspections of work sites to verify that the environmental requirements specified in this EMP are being implemented. The Environmental Officer and the Community Liaison Officer will make an inspection together a few days before each Environmental Compliance Review Meeting, sometimes accompanying the site Manager or Superintendent for this purpose. The findings of these inspections shall be documented. Other non-regular inspections may be made, possibly without warning, by other members of the environmental and community teams, and by the Government of Liberia’s Environmental Protection Agency. Inspections shall use the monitoring tables for the Employees’ and Contractors’ Operational Practices, as given in Section 10 of this plan. Key aspects of the environmental compliance inspections are as follows.

The scope of each inspection shall be based on current and completed activities, and shall be adapted as site conditions change.

Immediate changes shall be implemented where the potential for an adverse environmental impact or non-compliance is observed.

“Stop work” orders shall be issued if activities are not in accordance with the applicable environmental requirements and are likely to result in a significant adverse impact to the environment. Activities shall not be resumed until corrective actions have been agreed upon and implemented. “Stop work” orders may be made by the Company’s site Manager or Superintendent on the recommendation of the Environmental Officer, the Community Liaison Officer or any other member of the environmental or community teams.

On completion of activities on each part of every site, a final inspection will be made to ensure compliance with all environmental safeguards, and this fact will then be documented. No inspection shall be deemed “final” until all compliance has been fulfilled.




8. RESPONSIBILITIES

8.1 Organisational structure The Company is responsible for conducting all work in accordance with applicable laws and regulations, and ensuring that its workers and Contractors comply. As far as it relates to environmental and social safeguards, the general organisation of ArcelorMittal Liberia is shown on the next page, with the detailed approximate breakdown of responsibilities given on the following two pages. Specific responsibilities of Company personnel are summarised in section 8.2, and those of contractors are given in section 8.3. Detailed terms of reference for individuals are provided in the sector-specific and topic-specific Environmental Management Plans, but have been omitted from this Overall EMP for the sake of simplicity. Although ArcelorMittal employs a standard top-down pyramidal organisation structure, it is important to appreciate two main features.

Within the Company, there is a formal bottom-up reporting and responsibility system.

Nevertheless, there is widespread cross-over within and between departments, giving a fully three-dimensional structure.

All Company activities in Liberia are the responsibility of the Chief Executive Officer of ArcelorMittal Liberia. The CEO (AML) reports to the Vice President (Mining Operations) in ArcelorMittal Mining, the Company’s global mining division based in London. The ArcelorMittal Mining team provide a number of strategic and technical support functions, including environmental management. These are further strengthened by additional support functions provided from ArcelorMittal Corporate, the global Company overview teams based in London, Luxembourg and elsewhere. Within ArcelorMittal Liberia, activities are handled by a series of specialist teams. These vary between what might be termed “professional” teams (e.g. finance, legal and environmental), and “technical” teams (e.g. port operations, transport and workshops). Both types have a similar structure, as shown below. This arrangement allows delegation and responsibility to run up and down the hierarchy, but for activities to be shared between departments.

Manager (1 per department)Shared services

(ArcelorMittal Liberia or

ArcelorMittal Mining)

Formal reporting line Regular line of liaison

Professional departments Technical departments

Chief Executive Officer

Chief Operations Officer

Superintendent (1 per unit)

Foreman (varies)

Supervisors (varies)

Operators (teams)

Chief Executive Officer

Chief Operations Officer

Superintendent (1 per unit)

Officer (varies)

Assistants (varies)

Manager (1 per department)

Underlying the organisation of the Company are the universal principles of environmental management:

Everyone must take responsibility to ensure that their actions do not damage the environment beyond permitted levels; and

Everyone must undertake the agreed mitigation and rehabilitation measures for the impacts that they cause on the environment.

Hence the Environmental Department is principally responsible for advisory and monitoring services, and the implementing technical departments are responsible for the resolution of their own pollution and waste management, under Environmental Department guidelines and support.




Summary of the organisational structure of ArcelorMittal Liberia

Min

e

Rail

Port

Roads a

nd Q

uarrie

s

Pro

cure

ment

Tow

nship

s

Tra

nsport a

nd W

ork

shops

Enviro

nm

ent

Com

munitie

s

Health

and S

afe

ty

Hospita

ls

Schools

Security

Fin

ance

Legal

Inte

rnal A

udito

r

Com

munic

atio

ns

Govern

ment R

ela

tions

Hum

an R

esourc

es

Info

rmatio

n T

echnolo

gy

Genera

l Adm

inis

tratio

n

Pro

ject M

anagers

EP

CM

Pro

cure

ment

Operations Shared Services: Corporate Responsibility Shared Services: Administrative and Support Projects

ArcelorMittal Liberia: Chief Executive Officer's Responsibilities

Summary of the organisational linkages for environmental safeguards in ArcelorMittal Liberia

Hydro-

meteorological

Monitoring

Environmental

Officer

Environmental

Assistant

Environmental Manager Environmental Adviser

Mainly working on Operations Mainly working on Projects

Chief Operations Officer Project Director

Chief Executive Officer, ArcelorMittal LiberiaVice President HSESS,

ArcelorMittal Mining

Formal reporting line Regular line of liaison

Buchanan Site

Environmental

Superintendent

Environmental

Officer

Yekepa Site

Environmental

Superintendent

Biodiversity Officer

Environmental

Team of

Engineering

Procurement and

Contract

Management

Consultant

(EPCM)

Biodiversity

Conservation

("Offset")

Programme

Programme

Co-ordinator

Assistant

Co-ordinator

HSSE Site Manager

Environmental

Co-ordinators (2)

Environmental

Officers (2)




8.2 The Company The Company is the owner of the project and takes the ultimate responsibility for all actions in its implementation. The Chief Executive Officer of ArcelorMittal Liberia Limited holds the ultimate responsibility for all Company activities in Liberia. The CEO is supported by a number of head office staff. In particular, the Vice President for Health, Safety, Environment, Security and Sustainability in ArcelorMittal Mining provides guidance on those issues. At the site and contract level, the Company is represented by the Project Director, who has responsibility for delivering the Project Phase 2 construction in a safe and environmentally sound manner. The Project Director is supported by a number of Project Managers, to whom responsibility is delegated at the site level. The Company is represented by the Chief Operations Officer with respect to responsibility for operational actions and effects. A number of shared services support both Projects and Operations, and help to integrate the Company’s safeguards across the sites. The Environmental Manager is one of these, with responsibility for all matters relating to the protection of the environment. The Environmental Superintendent and the Environmental Officers support the Environmental Manager in all matters. The Environmental Manager also has an Environmental Adviser who takes particular responsibility for ensuring compliance by the Project Operations. The Health and Safety Manager reports to the CEO, and has the responsibility of ensuring that all health and safety provisions are in place and properly administered. The Communities Manager and the Community Liaison Officers support the CEO and other Company staff in all matters of relations with, and the welfare and support of, local communities. The Project Director is the Company’s principal representative regarding this component of the Project. He is responsible for ensuring that the Project, as implemented by the Company through its Contractors, complies with all environmental requirements. The Project Director has the following responsibilities with respect to environmental management:

Ensuring that sufficient resources are provided to meet the requirements of this EMP;

Ensuring that relevant elements of the EMP are incorporated into the contracts held with individual Contractors;

Preparing permit submissions where relevant, and where these cannot be done by Contractors;

Monitoring the standard of environmental compliance as reported by the Environmental Officer.

Direction of the Contractors regarding environmental compliance requirements and other matters of environmental importance;

Communication of site environmental issues with regulators and other interested parties;

Liaison with Company management on overall issues relating to health, safety, environment and communities, environmental performance data, incident reports, etc;

Co-ordination, via nominated agents, of compensation schemes for land clearance in cultivated areas, etc;

Approval of valid Contractors’ plans for emergencies;

Participation in Environmental Compliance Reviews;

Review of conditions following completion of site works;

Enforcement of all mitigation measures;

Enforcing the implementation of the control measures in this plan, and any other corrective measures;

Monitoring and reporting all issues of environmental compliance and community relations.




The Environmental Superintendent is a member of the Company’s staff. He or she supports the Projects Director in all environmental matters. The Environmental Superintendent has the following duties which may be delegated to other staff in the Environmental Department:

Communication with Company staff and Contractors regarding environmental compliance requirements and other matters of environmental importance;

Keeping Company management informed on overall issues relating to the Project’s environmental standards and compliance;

With the Community Liaison staff, supporting Company staff and Contractors in planning for action to be taken in the event of accidents and other emergencies threatening human welfare;

Supporting Company staff and Contractors in planning for action to be taken in the event of spills or leakages of hazardous materials, and other environmental emergencies;

With the Community Liaison staff, supporting Company staff and Contractors in the provision of environmental awareness and community interaction training;

Leading of Environmental Compliance Reviews;

With the Community Liaison staff, review of conditions following completion of works on site;

Liaison with Company staff and Contractors for the implementation of all environmental mitigation measures;

Identification of additional environmental mitigation or corrective measures that are deemed to be necessary in the course of operations;

Implementation of the control measures in this plan and any other corrective measures;

Preparation for the Port Manager of reports on all aspects of environmental compliance. The Community Liaison Officer is a member of the Company’s staff. He or she supports the Projects Director and other Company staff in all matters of relations with, and the welfare and support of, local communities. The Community Liaison Officer has the following duties:

Community liaison, particularly in relation to engagement with communities, enabling participation, implementation of grievance mechanisms, implementation of employment policy, and participation in determining and ensuring resettlement requirements;

Communication with Company staff and Contractors regarding liaison with communities and other matters of importance to local inhabitants;

Keeping Company management informed on relevant community issues, disputes, incident reports, etc;

Supporting of compensation and resettlement for land clearance in all areas;

With the Environmental staff, supporting Company staff and Contractors in planning for action to be taken in the event of accidents and other emergencies threatening human welfare;

With the Environmental staff, supporting Company staff and Contractors in the provision of environmental awareness and community interaction training;


Active involvement in Community Consultative Meetings;

With the Environmental staff, review of conditions following completion of works on site;

Liaison with Company staff and Contractors for the implementation of all community support measures;

Identification of additional community mitigation or corrective measures that are deemed to be necessary in the course of operations;

Implementation of the community support measures in this plan and any other corrective measures;

Preparation for the Port Manager of reports on all aspects of community relations.




8.3 The Engineering and Procurement Management Consultant Many of the responsibilities listed in section 8.2 for the Company and its staff may be designated to the Engineering and Procurement Management Consultant (EPCM). In this event, the EPCM shall accept the responsibility for assigned tasks as described for the company.

8.4 Contractors Where they are engaged, Contractors are responsible for complying with environmental requirements for all field activities covered by this EMP. Contractors to the Company are also responsible for the actions of any Sub-contractors they may engage. Each Contractor’s Field Manager is responsible for:

Direct overview of field personnel at the Project work sites;

Ensuring that all operations comply with the environmental standards that may be set from time to time by the Environmental Protection Agency under the provisions of the Environmental Protection and Management Law (2002);

Ensuring that the control measures provided for in the various documents of the Project’s health, safety, environmental and community safeguards systems are both understood and implemented by site personnel;

Training staff in appropriate environmental awareness issues, and ensuring that the key messages are passed on to the labourers in the work crews;

Setting up plans for action to be taken in the event of accidents and other emergencies threatening human welfare;

Setting up plans for action to be taken in the event of spills or leakages of hazardous materials, and other environmental emergencies;

Taking reasonable measures to employ local people in the work crews, particularly those whose livelihoods have been adversely affected by the Project;

Taking reasonable measures to avoid or mitigate impacts to the environment which may arise from the project’s activities (mitigation measures shall include awareness raising and training of all staff with respect to the possible environmental impacts during site works, and emergency incidents, such as accidents and pollution from fuel spills);

Monitoring of EMP implementation, by maintaining appropriate records and communications on site environmental issues and the status of compliance, and making these available to representatives of the Company as required;


Participation in Community Consultative Meetings;

Identification of significant matters pertaining to environmental compliance;

Liaise with the Company on the need for corrective action in the event of unexpected environmental or community problems emerging during the course of operations.

The Environmental staff and Community Liaison Officer are to support the Contractor in achieving many of these responsibilities, where it falls within their duties to do so.

8.5 Employment Policy Although the activities will generate a limited amount of local labour, an equitable and transparent employment strategy must be implemented that takes account of the individuals on whom the Project will have an impact. This is particularly important as the strategy applied to this initial phase will set precedents and expectations for all future activities. Responsibility for this activity will be with the Company’s Community Liaison Officers. As outlined in other sections of this EMP, a targeted employment policy should be extended to all potentially affected communities.




A labour allotment strategy should be developed and implemented on the following basis.

Skilled staff who worked for LAMCO and are still living in the vicinity of the mines or railway should be employed if they are not too old and their skills are still relevant.

All unskilled labourers employed on Project works should be recruited from settlements within 5 km of the sites.

The stages for the ArcelorMittal Community Liaison Officer to implement this are as follows.

1. Collect information from the Contractors’ staff as to the numbers and locations of labourer requirements.

2. Contact the Head and Elders of the main communities to identify areas where communities are interested.

3. Organise public meetings in each community to explain the opportunities for employment and the selection procedures, and for anyone who feels excluded to voice their grievances.

4. The County Labour Commissioner should be consulted as to the hiring terms and work conditions.

Detailed guidelines for these procedures are given in the Company’s Human Resources Plan. For short term works, guidelines are given in standard 3.4 of the Company’s Environmental Standards Manual.




9. IDENTIFIED POTENTIAL ENVIRONMENTAL IMPACTS This section of the Environmental Management Plan lists the potential environmental impacts, both good and bad, that were identified in the Environmental and Social Impact Assessment. These form the basis of the practical management and monitoring requirements given in sections 1 and 10.

9.1 Impacts Relating to all Parts of the Company’s Operations Issue Potential impacts (positive & negative) Prevention, control and mitigation measures


Uncontained spills and leakages leading to soil, and ground and surface water contamination. Affected soils are contaminated and effectively sterilised, leading to loss of vegetation and subsequent erosion. Water courses are affected by the resulting toxic substances, affecting community water supplies, aquatic biodiversity and wildlife. Waste products not collected and stored appropriately leading to widespread contamination. Fugitive emissions. Theft, resulting in spillage and pollution elsewhere. Potential for explosions.

AML to develop and implement Hazardous Materials Management Plan. Designated area, with appropriate bunding (150% volume of total capacity). The facility should be located down gradient of any public water supply boreholes wherever possible. Where this is not possible, a separate site specific hydrogeological and environmental impact assessment will be required. Retention systems, including walls, bunds and lined drains to contain any spillages. The facility should be on hard standing, distant from watercourses, with drainage system including oil/water separators. Spill kits and granules available. On-going controls to be put in place to minimise opportunities for fuel pilferage. Appropriate waste disposal. Emergency Response /Fire Fighting teams trained for a spillage event. Fire fighting equipment available at each facility. On site training for all personnel handling fuel and oil.

Refuelling Uncontained spills and leakages leading to soil, and ground and surface water contamination. Affected soils are contaminated and effectively sterilised, leading to loss of vegetation and subsequent erosion. Water courses are affected by the resulting toxic substances, affecting community water supplies, aquatic biodiversity and wildlife. Fugitive emissions. Potential for explosions.

AML to develop and implement Hazardous Materials Management Plan, which will include procedures for refuelling vehicles and generators. Spill kits to be carried by all refuelling vehicles. Central location for fuel tanks, vehicle refuelling to take place only on impermeable hard standings with controlled drainage (traps and interceptors). Plant refuelling on site to be carried out according to strict protocol for refuelling in unprotected areas. Reporting system for incidents enforced. Emergency Response / Fire Fighting teams to train for such an event. Fire fighting equipment available at each facility. On site Training for all personnel handling chemicals.


Hazardous materials on public highways with the potential for spills and leakages to the wider environment with little chance of containment. Ground and water contamination from toxic materials, leading to significant effects on community water supplies and wildlife mortality. Danger to road users. Potential for explosion and fire effecting wider environment.

AML to develop and implement Hazardous Materials Management Plan. Assessment of available transportation options, eg rail transport is safer than road. Use of convoys with accompanying support. Delivery to a prepared location. Supply of spill kits and granules in all vehicles and at offloading locations. Competent drivers and supervision. Emergency training to all personnel. Use of international labelling for identifying hazardous substance. Compliance with international standards (e.g. UK COSHH). Emergency Response / Fire Fighting teams to train for such an event. On site training for all personnel handling chemicals.




Issue Potential impacts (positive & negative) Prevention, control and mitigation measures

Chemicals (including herbicides) storage and use

Loss of containment from spills or inadequate disposal.Chemicals spill or leak to the environment with toxic effects to soil and water, resulting in polluted water supplies, or habitat degradation and wildlife mortality and/or reduced reproductive success. Some chemicals may be mutagenic. Some chemicals are, or contain, substances which bio-accumulate.Improper use by poorly trained workers leads to damaging health effects.Some chemicals pose a potential for explosion in confined spaces.

AML to develop and implement Hazardous Materials Management Plan. Minimise chemicals stored, reuse where possible.Select chemicals with least environmental impact where possible.Use only chemicals that are certified for use world-wide and approved by the Liberian EPA.Chemicals should be stored down gradient of any public water supply boreholes.All containers must be clearly labelled. Labelling must include non-verbal warning signs.Secondary containment for all chemicals.MSDS held for every chemical on site. Emergency Response / Fire Fighting teams to train for such an event. Fire fighting equipment available at each facility. On site training for all personnel handling chemicals.

Roads between Buchanan, Monrovia and Yekepa - increased traffic

Safety hazard to community and wildlife. Runoff to watercourses. Air pollution. Noise pollution. Houses may be affected by the vibration of heavy traffic on the roads. Increased accidents.

AML to update and expand its current transport rules and regulations. Community safety awareness campaigns. Driving safety awareness policies and ongoing campaigns to ensure safe driving. AML to continue operating radar gun speed traps. AML to maintain close liaison with Liberian National Police traffic control units. Road run off (erosion, sedimentation and pollution control)

9.2 Impacts Specific to this Environmental Management Plan Issue Potential impacts (positive & negative) Prevention, control and mitigation measures

Quarries for construction materials

Landtake and disturbance to habitats and species. Construction of temporary roads to borrow pits and quarries. Run off to water bodies. Contamination and siltation of water bodies. Emissions and dust affecting ambient air quality. Quarry crushers - noise and emissions. Quarry blasting, creates noise and vibration disturbance and stress to wildlife and nearby communities. Houses may be affected by the vibration and outfall of blasting operations.

AML to identify borrow/ quarry areas and conduct specific impact assessment and mitigation on these areas. Ensure design includes drainage assessment and water management controls. All road construction related activities are to be covered by detailed, site specific and project specific environmental management plans.

Earthworks Landtake and disturbance to habitats and species. Alteration of land surfaces and slopes.. Run off to water bodies. Contamination and siltation of water bodies. Emissions and dust affecting ambient air quality. Earth moving machines - noise and emissions. Excavation or surcharging triggers slope instability.

AML to identify and delimit the maximum areas for project earthworks. Ensure design includes drainage assessment and water management controls. All earthworks and related activities are to be covered by detailed, site specific and project specific environmental management plans.




Issue Potential impacts (positive & negative) Prevention, control and mitigation measures

Access roads to and within the quarry site

Landtake for access and haulage has detrimental effect on wider environment: forest destruction, noise and dust disturbance to wildlife, road kills, opening up access for more extensive hunting, run off from roads which can pollute watercourses with sediment and leaked hydrocarbons. Houses may be affected by the vibration of heavy traffic on the roads. Potential for increased road accidents, especially with non-AML road users. Dust generation effecting ambient air quality. Wash out from dust suppression water. Potential for destruction/ disturbance of culturally significant sites. Better roads will facilitate trading through easier access to resources and markets for local communities in longer term.

AML to update and expand its current transport rules and regulations. AML to avoid using public roads to a maximum extent. Minimise road construction to serve purpose; minimise vehicle movements; consult local communities, if public roads are used in relation to traffic safety. Community safety awareness campaigns. Driving safety awareness policies and ongoing campaigns to ensure safe driving. AML to continue operating radar gun speed traps. AML to maintain close liaison with Liberian National Police traffic control units. Maximise the use of excavated material in access road construction. Liaise with the Ministry of Public Works to carry out inventories and condition surveys of all public roads, bridges and culverts to be used by the project vehicles, and contribute to their rehabilitation and maintenance, as necessary. Road designs to include hydrological assessment and building of effective road drainage and culverts. Drained water to be controlled and watercourses/wetlands protected from sedimentation and pollution. Security and restricted access around active road construction working areas.


Landtake for long term and permanent mine use, with consequent destruction of landscape, fragmentation of habitats and species of high biodiversity and nature conservation importance. Potential to change or adversely affect hydrological regime and to cause long term siltation of watercourses. Potential for creation of unstable ground and landslips. Permanent removal or disturbance of culturally significant sites Permanently removes land from agricultural and silvicultural production, and collection of non-timber forest products (NTFP), including medicinal plants, fruits, local handicraft materials, etc with consequent effect on community livelihood. Dust from the stockpiles and waste dumps. Top soil where it is present, and up to 200 mm depth should be removed and stockpiles for later site restoration use.

Design footprint and phasing of stockpiles and waste dumps development to minimise impacts; including confining effects to one catchment, where possible. Utilise constraints map to carefully plan development activities. AML to develop and implement Resettlement Action Plan, which includes land acquisition and compensation. Ensure that resettlement activities are implemented with appropriate disclosure of information, consultation and the informed and meaningful participation of those affected. Comprehensive consultation programme, identifying groups of greater risk and more vulnerable groups. Capture and removal of waterborne sediments, regulation of runoff discharge. Regular monitoring to ensure no sedimentation to watercourses, and contingency measures. Avoid wetlands, where possible.




10. ENVIRONMENTAL MANAGEMENT AND ITS MONITORING The tables in this section list the obligations of the Company, its staff, workers and Contractors, for environmental management and compliance, and how these will be monitored. They are the basis of the Operational Practices in section 1 of this EMP.

10.1 Environmental Issues Specific to Quarry Preparation

Quarry Preparation


(see manual)

Monitoring

What you MUST do What you must NOT do Check timing Responsibility for

checking

Assessment of condition and performance

Action required


Only disturb the soil where it is necessary to do so.

Grade any newly formed slopes to the minimum angle possible.

Level surfaces to prevent erosion as soon as works have been completed.

Use existing tracks and previously disturbed areas as far as possible.

Allow small plants to grow back on the edges of roads and tracks when their use is finished.

Undertake soil erosion prevention and sediment controls as required by the Environmental Officer if this should be deemed necessary, to protect areas from slips and erosion.


Disturb any more of the ground surface than is absolutely necessary for access and working.

Allow erosion to happen without taking rapid control measures.

Make access tracks wider or other cleared areas larger than necessary.

Create earth piles close to the edge of steep slopes or close to watercourses.

Leave soil slopes steeper than 10° completely bare and unprotected.

Drive unnecessarily often or use very heavy equipment on access tracks or other earth surfaces (thereby compacting the soil excessively).

Standards 6.1 to 6.9 inclusive, as required.

Before starting work.

Monthly during site operations.

After completion of site operations.

Environmental Officer.

To be completed at each check.

Only to be completed at check if compliance is not satisfactory. State who is responsible for action.




Quarry Preparation


(see manual)

Monitoring


checking


Action required


Phase land clearance and restoration to maximise forest cover at any one time.

Schedule activities to avoid major earthworks operations in the wet season.

Control erosion to protect slopes and watercourses.

Regulate water discharge and run off.

Monitor downstream water quality routinely.



Destroy vegetation cover, leaving areas prone to erosion with consequent land degradation and pollution of watercourses and catchments.

Permit water pollution on which destroys aquatic species and renders water useless for downstream community users.

Allow air pollution from dust and emissions outside the immediate site boundaries.

Allow the conditions to arise where the ground becomes unstable and liable to landslips.

Standards 2.1, 5.1, and 6.1 to 6.14 inclusive.

Before start of work.








Quarry Preparation


(see manual)

Monitoring


checking


Action required

Water resources

Keep earthworks, tracks, roads and other cleared areas as far as possible from water courses or bodies.

Where earthworks, tracks, roads and other cleared areas are within 50 metres of water courses or bodies, take special care to ensure that fuel, oil and other hazardous substances, and any earthworks, are properly contained.

Ensure that all private and community water supplies are safeguarded. Confirm the location of local water supplies with the CLO.

Water resources

Allow leakages of fuel, oil or other hazardous materials.

Dispose of anything into a water course or standing water body.

Use any chemical without prior consent.

Extract so much water from a supply that the normal users are short.

Standards 5.1, 5.2, 5.3, 9.1.




Environmental Officer and Community Liaison Officer together.






Quarry Preparation


(see manual)

Monitoring


checking


Action required

Drainage systems

Provide culverts wherever water needs to flow across a track or road.

Ensure water from culverts and other drains is discharged at low energy via drop structures and aprons.

Make temporary drains as necessary to avoid waterlogging or erosion. These must be adequate for accumulated runoff water as well as rainfall.

Discharge drains into well vegetated areas. Provide mini silt collection ponds if drains must discharge straight into water courses.

Drainage systems

Leave long gaps between culverts or turnouts, so that a lot of water flow builds up.

Allow sediment from bare eroding surfaces to be washed into water courses.

Standards 5.1, 6.1, 6.2, 6.6.










Quarry Preparation


(see manual)

Monitoring


checking


Action required

Roads and tracks

Enforce transport rules and regulations rigorously.

Avoid using public roads to the maximum extent possible.

Minimise road construction to serve purposes.

Minimise vehicle movements.

Conduct driving safety awareness campaigns.

Maximise the use of excavated material in access road construction.

Liaise with the Ministry of Public Works to carry out inventories and condition surveys of public roads, bridges and culverts to be used by the project vehicles, and contribute to their rehabilitation and maintenance, as necessary.

Include hydrological assessment and the building of effective road drainage and culverts in all road designs.

Control drainage water, and protect watercourses and wetlands from sedimentation and pollution.

Impose security and restricted access around active road construction working areas.

Roads and tracks

Allow landtake for access and haulage roads beyond the minimum required to construct the roads required.

Construct roads across or close to culturally significant sites.

Allow dust generation to affect the ambient air quality outside the site.

Spray dust suppression water at such rates that it causes erosion and washing out of the roads.







Transport Manager.






10.2 Environmental Issues Specific to Quarry Operation

Quarry Operation


(see manual)

Monitoring


checking


Action required


Ensure that only the approved quarry areas are used throughout the re-opening and operation period.

Ensure quarry plans include drainage assessment and water management controls.

Maintain the quarry area in a clean, safe and efficient condition.

Rehabilitate the quarry fully to its baseline condition after work has ceased (see Project Brief).

Ensure that quarry blasting does not create excessive noise and vibration disturbance to wildlife and communities.

Ensure proper geotechnical management so that excavation and tips do not trigger slope instability.


Allow runoff to cause contamination and siltation of water bodies.

Allow emissions and dust to affect the ambient air quality outside the immediate site boundaries.

Allow excessive noise and emissions from crushers.










Quarry Operation


(see manual)

Monitoring


checking


Action required


Design footprint and phasing of earthworks, stockpiles and waste dumps development to minimise impacts

Confine effects to one catchment, as far as possible.

Capture and remove waterborne sediments and regulate runoff discharge.



Change or adversely affect the hydrological regime and cause long term siltation of watercourses.

Create the potential for unstable ground and landslips.

Allow dust from the stockpiles and waste dumps to pass outside the immediate site boundaries.







Dust Ensure that rock is wetted by a

constant water stream as it enters the crusher.

Take appropriate measures to dampen dust during blasting operations.

Place speed bumps to reduce vehicle speeds on dusty haul roads.

Dust

Allow any operation to continue if it creates dust, without taking action as required to remedy the problem.

Standard 4.1.





Noise Provide all site workers with ear

protection as appropriate.

Avoid working at night and on Sundays to the maximum extent possible.

Use explosives only during daylight hours and never on Sundays.

Noise Work within 300 metres

of a dwelling outside daylight hours.

Allow any person to come close to a noisy machine without having ear protection in place.

Standard 7.1.








Quarry Operation


(see manual)

Monitoring


checking


Action required

Explosives and blasting Obtain formal licensing from

the government.

Abide by Liberian laws and regulations, and UNMIL guidelines, regarding the handling, storage and use of explosives.

Be particularly strict in enforcing safety regulations when using explosives.

Follow the detailed specifications for blasting provided in this EMP.

Explosives and blasting Allow any unauthorised

person to have access to explosives.

Allow anyone to use welding equipment, smoke, cook food or light any fire within 50 metres of an explosives store.

Deviate from strict safety standards when handling or transporting explosives, and blasting.

Standard 10.8.









10.3 Environmental Management Principles Common to All Sites

General Environmental Management



Monitoring


checking


Action required

General principles

Avoid damage to any part of the environment (soil, plants, animals, human resources and settlements) as far as possible.

If damage cannot be avoided, then mitigate or compensate for the damage.

Follow the ArcelorMittal Environmental Policy.

Respect the environment: we have only one planet!

General principles

Undertake any work beyond the agreed boundaries of the work sites.

Undertake any work before agreeing mitigation or compensation arrangements.

Hide any damage or pollution. In the event of an accident, it is better to consult the Environmental Team and agree a mitigation plan than to risk prosecution under the law.

Section 5 of this EMP.



Monthly during operations.

After completion of operations.

Environmental Officer for bio-physical matters.

Community Liaison Officer for socio-economic matters.




Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main environmental messages.

Ensure that all professional and technical staff respect the environment and understand why.


Allow staff and workers to neglect environmental issues. This may lead to offences under the Environment Protection and Management Law.

Ignore blatant disregard for environmental and social issues by professional and technical staff.

Standards 12.1, 12.2.











Monitoring


checking


Action required


Ensure that the site supervisors brief all workers at the start of every job, and at the beginning of each week, on the main messages regarding respect for the local communities.

Ensure that all professional and technical staff respect the local communities and behave well.


Ignore blatant disrespect for communities by professional and technical staff.



Community Liaison Officer.




Provide all workers with safety equipment appropriate to the work that they are doing

Keep first aid kits on all work sites.

Ensure that there are two people on each work site who know what to do if there is an accident and how to use the first aid kit.

Remember that safety gear is cheaper than hospital and funeral bills!


Allow workers on to a site unless they are wearing the appropriate safety gear.

Allow first aid kits to become empty or out-of-date.

Standard 1.1.

H&S Manual and Rules.

Weekly during site operations.

Health and Safety Manager.









Monitoring


checking


Action required


Avoid the use of cultivated land wherever possible. This includes fallow agricultural land, rubber and other tree plantations.

Where use of such land is required, check with the CLO at last four weeks prior to commencement of activities (ideally earlier) that mitigation measures have been agreed and implemented.


Start using cultivated land before the occupier has fully agreed the compensation strategy, all amounts have been paid and this is confirmed by the CLO.

Damage crops or land beyond agreed boundaries.

Allow any new farms to be created in the vicinity of tracks, roads or any other work sites.

Standards 3.1, 3.2, 3.3.



Environmental Officer and Community Liaison Officer together.




Establish an equitable and fair employment strategy. Liaise with the CLO to ensure that it is understood in the local communities (i.e. that it is transparent).

Give priority to local people in labour crews, and those who used to earn livelihoods on land in the mining concession.


Pay local people below the usual wage rates.

Demand unpaid work by local farmers or others.

Standard 3.4.











Monitoring


checking


Action required


Check with local people, through the CLO, as to whether any activities will affect sites of cultural or religious importance.

Avoid any works where cultural sites might be affected, as far as possible.

If damage to cultural sites cannot be avoided, agree compensation measures with the local community, through the CLO.


Damage any sites of cultural or religious importance without first agreeing compensation arrangements.

Standards 3.1, 3.2, 3.3.


As required thereafter.




Plants

Only cut vegetation that is in the way. This means plants that are in the direct area required for the access track, mining area or other purpose.

Plants

Cut more vegetation than is necessary for site access and working.

Use fire to remove vegetation.

Burn cut vegetation.

Standard 2.1.







Animals

Instruct workforce not to hunt, deal in or transport bushmeat on site.

Provide meat from domestic animals if there is no alternative.

Animals

Allow any use of fire.

Expect workers to live in places where there is no source of meat from domesticated animals.

Allow non-Project people to use the mine tracks and roads by providing gates and guards.

Standard 2.2.


Environmental Officer, supported by Community Liaison Officer.









Monitoring


checking


Action required


Maintain strict transport rules and regulations.

Undertake community safety awareness campaigns.

Undertake regular driving safety awareness campaigns to ensure safe driving.

Continue operating radar gun speed traps.

Maintain close liaison with Liberian National Police traffic control units.




Not applicable.

Transport Manager.

Not applicable.

Not applicable.


Provide proper water closet toilet facilities at all long term (> 1 month) work sites.

Maintain all toilets in a clean and sanitary condition.

Provide proper earth pit latrines at all work sites where work will be undertaken for periods of up to one month.

Fill the latrines in once site work is complete.


Allow water to run out at toilets, or for them to be left uncleaned.

Allow latrines to become full or overflow.

Allow site workers to defecate in the open anywhere on the site or in its vicinity.

Standards 1.2, 1.3.











Monitoring


checking


Action required


Ensure that all potentially hazardous materials (i.e. fuel, oil, other chemicals, sewage) are stored or disposed of in appropriate ways.

Devise on-site emergency spillage plans and train staff in their implementation.

Remove all debris and litter from site.


Allow any pollution to occur to the soil or water courses.

Standards 9.1, 9.2. 9.3, 10.1, 10.2 and others as appropriate.













Monitoring


checking


Action required



Only use the designated storage areas, with bunding of 150% volume of total capacity.

Only use facilities located down gradient of public water supply boreholes and distant from watercourses.

Ensure that there are retention systems, including walls, bunds and lined drains to contain any spillages.

Ensure that there is hard standing, with a drainage system that includes oil/water separators.

Ensure spill kits and granules are available.

Have controls in place to minimise opportunities for fuel pilferage.

Dispose of waste appropriately.

Maintain Emergency Response / Fire Fighting teams trained for a spillage event.

Maintain fire fighting equipment at each facility.

Provide training for all personnel handling fuel and oil.


Allow uncontained spills and leakages to occur, leading to soil, and ground and surface water contamination.



Allow waste products that are not collected and stored appropriately to contaminate the surroundings.


Allow theft to occur, resulting in spillage and pollution elsewhere.


Standards 9.1, 9.2. 9.3, 10.1, 10.2, and 11.1 to 11.6 inclusive.












Monitoring


checking


Action required

Refuelling

Follow the hazardous materials management guidelines fully, which include procedures for refuelling vehicles and generators.

Spill kits are to be carried by all refuelling vehicles.

Keep all fuel tanks in a central location.

Refuel vehicles only on impermeable hard standings with controlled drainage (traps and interceptors).

Plant refuelling on site is to be carried out according to strict protocols for refuelling in unprotected areas.

Enforce the reporting system for spillage incidents.




Refuelling

Allow spills and leakages to go uncontained leading to soil, and ground and surface water contamination.





Standards 9.1, 9.2. 9.3, 9.4, 10.1, 10.2, and 11.1 to 11.6 inclusive.












Monitoring


checking


Action required



Use the safest available transportation option, preferably rail.

On roads, use convoys with accompanying support.

Deliver only to prepared locations.

Maintain supplies of spill kits and granules in all vehicles and at all offloading locations.

Ensure competent drivers and close supervision.

Provide emergency training to all personnel.

Use international labelling for identifying hazardous substances.

Comply with international standards (e.g. UK COSHH).




Transport hazardous materials on public highways without having supporting vehicles in convoy to take immediate containment action in the event of an accident.

Allow any ground and water contamination from toxic materials.

Allow any potential for explosions and fires to occur.

Standards 9.1, 9.2. 9.3, 9.4 10.1, 10.2, 10.3.












Monitoring


checking


Action required



Select chemicals with the least environmental impact where possible.

Use only chemicals that are certified for use world-wide and approved by the Liberian EPA.

Minimise the volumes of chemicals stored, and reuse them where possible.

Chemicals should be stored down gradient of any public water supply boreholes.

Ensure that all containers are clearly labelled. Labelling must include non-verbal warning signs.

Provide secondary containment for all chemicals.

Ensure that the MSDS is held for every chemical on site





Allow any loss of containment from spills or inadequate disposal.

Allow any chemicals to spill or leak to the environment with toxic effects to soil and water.

Use any chemicals that are not approved by both the Company’s HSE Manager and the EPA.

Use any chemicals known to be mutagenic or which contain substances which bio-accumulate.

Allow any use of chemicals except by fully trained workers.

Allow the use of chemicals in confined spaces if they pose any potential for explosions.

Standards 9.1, 9.2. 9.3, 9.4, 10.1, 10.2, 10.4, 10.5, 10.6, 10.7.






Date post:	24-Mar-2018
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