Document title: HAZARDOUS MATERIALS MANAGEMENT PLAN

Document number: 1062-TGN-MNG-PLN-PJM-22-00004

Project: THE DEVELOPMENT OF THE ROMANIAN GAS TRANSMISSION

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

Revision Date Issued by Checked by Endorsed by Approved by

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

Alexandru Simionescu Sorin Keszeg

BRUA BRUA
Execution Project Project Manager
manager services

Disclaimer: The sole responsibility for this publication lies with the author. The European Union and the Innovation &
Networks Executive Agency (I.N.E.A.) are not responsible for any use that may be made of the information contained
herein.
Table of Contents
1. INTRODUCTION ......................................................................................................................................... 4
1.1. Project Overview ........................................................................................................................... 4
1.2. Environmental and Social Commitments....................................... Error! Bookmark not defined.
1.3. Document Management ................................................................ Error! Bookmark not defined.
2. DOCUMENT PURPOSE AND SCOPE ............................................................ Error! Bookmark not defined.
2.1. Purpose Of the CESMPS ................................................................. Error! Bookmark not defined.
2.2. Project hazardous materials Philosophy ........................................ Error! Bookmark not defined.
2.3. Purpose of this hazardous materials CESMP ................................................................................ 4
2.4. Scope of the hazardous materials CESMP .................................................................................... 4
3. KEY POLICIES, LEGISLATION, NORMS AND STANDARDS ........................................................................... 7
3.1. Overview ....................................................................................................................................... 7
3.2. Company Policies .......................................................................................................................... 7
3.3. National Legislation and Permits .................................................................................................. 7
3.4. International Standards and commitments .................................................................................. 7
4. LINKAGES TO OTHER BENEFICIARY ELEMENTS ......................................................................................... 9
4.1 Overview ....................................................................................................................................... 9
4.2. Linkages to Other CESMPs ............................................................................................................ 9
5. ROLES AND RESPONSIBILITIES................................................................................................................ 11
5.1. Overview ..................................................................................................................................... 11
5.2. Company Roles & Responsibilities .............................................................................................. 11
5.3 . Contractor Roles & Responsibilities ............................................................................................ 13
6. MANAGEMENT, MITIGATION, MONITORING AND VERIFICATION ......................................................... 15
6.1. Management Actions .................................................................................................................. 15
6.2. General Monitoring Activities ..................................................................................................... 15
6.3. Management System Verification Monitoring ........................................................................... 15
6.4. Key Performance Indicators ........................................................................................................ 16
6.5. Training ....................................................................................................................................... 17
Appendix 1: Mitigation Measures & Management Actions................................................................ 18
Appendix 2: Monitoring Requirements .............................................................................................. 24
Appendix 3: Relevant Legislation ........................................................................................................ 25

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Abbreviations

Abbreviations Description
BRUA Bulgarian-Romanian-Hungarian-Austrian
CESMP Construction Environmental and Social Management Plan
EIA Environmental Impact Assessment
ESMP Environmental and Social Management Plan
F-CESMP Project Framework Construction Environmental and Social Management Plan
HSE Health, Safety and Environment
HSE-MS Health, Safety and Environment Management System
HSES Health, Safety, Environment System
HSSE Health, Safety, Social and Environment
JOCE Official Journal of European Community
KPI Key Performance Indicators
PMU Project Management Unit
PR Performance Requirement

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1 Introduction
1.1 Overview
The Construction Environmental and Social Management Plans (CESMP) defines the actions and measures
necessary for the overall management of environment and social impacts for both the Project beneficiary
(TRANSGAZ S.A., represented by the Bulgarian-Romanian-Hungarian-Austrian Project Management Unit
(BRUA PMU)) and contractors in line with the applicable law and other obligations. The CESMPs are
comprised of a suite of management plans.
This CESMP is the Project Hazardous Materials Management Plan, document no 1062-TGN-MNG-PLN-
PJM-22-00004.
Hazardous materials are any materials that represent a risk to human health, property or the environment
due to their physical or chemical characteristics. When a hazardous material is no longer usable for its
intended purpose and is intended for disposal, it is considered a hazardous waste (and is addressed through
the Waste Management CESMP 1062-TGN-MNG-PLN-PJM-22-00005). The Project seeks to proactively
manage the handling and storage of hazardous materials, as well as the prevention of accidents and the
control of releases of hazardous materials to ensure the protection of the workforce, the public, property and
the environment.
1.2 Purpose of this Hazardous Materials CESMP
The purpose of this Plan is to ensure an adequate management of hazardous materials throughout the
construction phase of the project to prevent any negative impacts on the people’s health, property and on
the environment. As such, this Plan:
 Outlines the key policies, legislation and standards relating to waste management;
 Defines roles and responsibilities;
 Outlines actions and measures necessary for the effective management of hazardous materials
(including handling and storage) as well as accidental release of hazardous materials;
 ;
 Details specific control measures to be implemented by the Company and its contractors (and
subcontractors);
 Incorporates the requirements of the Regulatory EIA findings, Supplemental Environmental
Assessment (June 2017), international standards, Romanian legislation, Lenders requirements and
Project-specific construction permits;
 Considers the Company’s general approach to hazardous materials management procedures and
methodologies.
The CESMP defines the actions and measures necessary for the management of hazardous materials by
both the Project beneficiary (TRANSGAZ S.A., represented by BRUA PMU), Contractors and sub-
contractors, in line with the applicable law and other obligations.
1.3 Scope of the Hazardous Materials CESMP
This CESMP covers all activities and is applicable to all Transgaz staff, Contractors and Sub-contractors.
Whilst this CESMP will act as a ‘framework’ to determine what the Contractors will be expected to produce,
Contractors are required to ensure that all the CESMP requirements are adopted within their own

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management plans. Further information on Roles and Responsibilities is provided in Section 5 of this
CESMP.
1.4 Document Management
Document will be managed and controlled by the Document Control and Archiving Compartment within BRUA
Project Management Unit. The methods for document management and improvement during the construction
phase will be described in the Document Guide to be developed by BRUA PMU.

2 The BRUA Project

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

Figure 2.1 BRUA Route

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Whilst the majority of the route is on land currently used for farming, it does pass through a number of
specifically sensitive areas, including seven Natura 2000 Sites, and the nationally important Dinosaurs Geo-
Park. It also passes close to a number of sites of archaeological value including the ancient city of Tibiscum
near Jupa. In some of these areas, as well as near major roads and railways and for the 8 major rivers, this
will involve the use of horizontal directional drilling. In mountainous areas special “hammering techniques”
may also be applied.
2.2 Environmental and Social Commitments
The Project is subject to various environmental and social requirements that are managed by the Company
through the implementation of its Health, Safety and Environmental Management System (HSE-MS)1. This
HSE-MS includes a specific Project Framework Construction Environmental and Social Management Plan
(F-CESMP) as well as associated topic/activity specific CESMPs. Operational phase Environmental and
Social Management Plans will be developed at a later stage prior to BRUA operation. The overall approach
to integration of the above documents is described in Section 4.2 of the F-CESMP document.
2.3 Project Approach to Waste Management
The Project construction activities will result in the generation of hazardous materials that require proper
planning from the outset to ensure a system of coordinated management between BRUA PMU, contractors

1
Integrated Management Manual Quality-Environment-Occupational Health and Safety, code MSMI-CMSSO Ed. 03/Rev.
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and local authorities (which have the competency to check compliance with Project provisions regarding the
storage, transportation, and final disposal of hazardous materials), and also to sanction deviations from legal
framework).

3 Key Policies, Legislation and Standards

3.1 Overview
The Project is subject to a range of policies, legal and regulatory requirements and other applicable standards
of relevance to this CESMP. Where two or more of the identified standards are inconsistent or contradictory,
unless otherwise justified, the Project will adopt the most stringent.
3.2 Company Policies
Transgaz’ Health Safety and Environment (HSE) policy (as outlined in the Integrated Management Manual
Quality-Environment-Occupational Health and Safety, code MSMI-CMSSO Ed. 03/Rev.) and Corporate
Social Responsibility policy apply to all activities carried out by, or on behalf of, the Company as part of this
Project. Details of these policies are provided in Section 7.3 of the F-CESMP.
3.3 National Legislation and Permits
All contractors are also required to comply with all relevant national regulatory requirements. Whilst
contractors are required to verify the latest regulatory requirements themselves, an indicative list of Romanian
national legislation is provided in Appendix 3.
Contractors must also ensure that relevant requirements of the various construction-related permits for the
Project issued by national (and local) regulators are addressed. Any requirements arising from the
revision/amendment of those permits will also be applied. Key permits are summarized in Section 3.2 of the
F-CESMP.
3.4 International Standards and commitments
A range of international standards and commitments are applicable to this CESMP as described in Section
3.3 of the F-CESMP Document. These include the European Bank of Reconstruction and Development
(EBRD) Environmental and Social Performance Requirements (PRs), with PR3 being especially relevant to
this document. All contractors are required to comply with all such requirements as they apply to their
activities.
The following European Union Regulations are relevant to this CESMP and have been taken into account:
 Waste Framework Directive 2008/98/EC
 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008
on classification, labelling and packaging of substances and mixtures, amending and repealing
Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006
 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006
concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH),
establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council
Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council
Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and
2000/21/EC

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Page 8 of 25 DOCUMENT No. 1062-TGN-MGN-PLN-PJM-22-00004Rev 2
4 Linkages to other Elements of the Transgaz HSE-MS
4.1 Overview
This CESMPs forms part of the Project HSE-MS as described in the F-CESMP. Where relevant the CESMP
should be read in conjunction with other HSE-MS elements including the ESMP source documentation,
control documentation and the key HSE-MS documentation. These are illustrated in Figure 4.1 below and
further described in Section 4.1 of the F-CESMP.
Figure 4.1 Links to other HSE-MS Documentation

4.2 Linkages to Other CESMPs

A listing of the CESMPs and their document numbers is presented in Section 4.2 of the F-CESMP
Document. The other CESMPs considered to be of particular relevance to the Hazardous Materials
CESMP are as follows:
 Roads and Traffic CESMP – Document No. 1062-TGN-MNG-PLN-PJM-22-00012 (in relation to the
transport of hazardous materials)

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 Waste Management CESMP - Document No. 1062-TGN-MNG-PLN-PJM-22-00005 (in relation to
the management of hazardous waste)
 Pollution Prevention CESMP, Document No. 1062-TGN-MNG-PLN-PJM-22-00003
 Community Health, Safety and Security CESMP, Document No. 1062-TGN-MNG-PLN-PJM-22-
00011
 Labour and Working Conditions CESMP, Document No. 1062-TGN-MNG-PLN-PJM-22-00010
 Water CESMP, Document No. 1062-TGN-MNG-PLN-PJM-22-00007
 Emergency Response Plan, Document No. 1062-TGN-MNG-PLN-PJM-22-00015

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

Activities Beneficiary Contractors External providers

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

The operational cooperation procedures in the construction site will be set in the Statement of Works that will
be an Appendix to the Commercial Contract to be signed between the Beneficiary and the Contractor. The
Contact Point Unit for each construction site, as defined in the Contractor Management Plan, is the structure
responsible for the implementation and monitoring of the provisions in the Statement of Works.
5.2 Company Roles & Responsibilities
Transgaz HSE management roles and responsibilities during the Project construction phase are detailed in
the BRUA PMU - Regulation of organization and functioning. Further information is also provided in other
documents listed in the F-CESMP document.
With regards to this CESMP, Transgaz S.A. is responsible for key management activities including:
• Development of bidding conditions regarding hazardous materials management;
• Professional training of a Transgaz Hazardous Materials representative on site;
• Monitoring Contractor performance, supervision and control of Contractors;

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• Management cooperation in case of an ecologic accident2 (including registration and communication
of events).

Specific roles and responsibilities within the Company presented in Table 5.2 will apply.
Table 5.2 Company Roles and Responsibilities

Role Responsibility
Director general - Approves the Hazardous Materials Management Plan
SNTGN TRANSGAZ SA
HSSE Coordinator the - Ensures the compliance of the Project with the requirements
environmental expert established in this Plan;
- Has the general responsibility for the implementation of this Plan,
including by the main Contractors;
- Develops, monitors and revises this plan;
- Ensures the necessary training for BRUA PMU staff on hazardous
materials is delivered;
- Centralizes the information regarding the generated hazardous
materials and hazardous materials management by the Contractors;
- Provides necessary support to the Contractors to enable them to
comply with the Hazardous Materials Management Plan;
- Ensures this Hazardous Materials Management Plan is available to all
BRUA PMU staff and Contractor staff;
- Performs regular audits of the main Contractors’ performance against
the requirements of this Plan;
- Reports all the risks, non-compliances with this Plan and incidents;
and
- Prepares an annual environmental report that includes details
regarding the management of hazardous materials
Will verify the implementation of contractors’ obligations, including regular
A nominated audits of:
environmental - the hazardous materials storage areas;
responsible of - visual inspections of soil and water in the work area;
TRANSGAZ from PMU- - whether safety data sheets exist for hazardous materials;
BRUA - whether hazardous substances are managed according to the safety
data sheets;
- whether Contractors’ have appropriate Intervention Plans in case of
accidental pollution.

2
Ecologic accident – an event resulting from an unforeseen and accidental spillage or emission of a hazardous or polluting
substance (whether liquid, solid, gasseous or vapour) that could result in detrimental impacts to the environment and/or local
communities (G.E.O. 195/2005 on environment protection, as further amended and supplemented)
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5.3 Contractor Roles & Responsibilities
Overarching Contractor HSSE requirements are defined in the relevant articles of their contracts and
associated mandatory Annexes. Each contractor must also implement all relevant requirements of the
CESMPs, including this Hazardous Materials CESMP. Contactors are also responsible for ensuring that any
subcontracted work meets these requirements. In addition, within the Project, responsibility for hazardous
materials management lies with the Contractors according to the principle "polluter pays".

Contractors will be required to present to the Beneficiary, represented in the Project by PMU BRUA, in
accordance with the requirements, their proposed approaches to:
• Management of hazardous materials on site, including handling and storage;
• Spill recovery and emergency response;
• Any other conditions outlined in this CESMP or its appendices.

In addition, Contractors will present the Beneficiary with details of:

- A nominated environmental responsible on hazardous materials
- Records of any impacts associated with hazardous materials.

Further specific responsibilities of the Contractor/sub-contractors are outlined in the Appendices to this
CESMP and in Table 5.3 below.

Table 5.3 Contractor Roles and Responsibilities

Role Responsibility
- Manager - Ensures that all construction activities are performed in compliance
responsible for with the requirements of this Plan.
environmental - Produces a Hazardous Materials Management Plan in line with this
matters Plan.
- Ensures the proper handling, labelling, storage and management of
hazardous materials.
- Ensures the proper disposal of hazardous materials in line with
national / EU legislation.
- Identifies registered and appropriately managed disposal facilities for
hazardous materials; and undertakes a review of facilities as part of
Project supplier management processes.
- Ensures all staff receive the necessary training in relation to
hazardous materials management.
- Performs regular audits of the working sites to ensure all activities are
being undertaken according to the requirements of the Hazardous
Materials Management Plan.
- Ensures that all information regarding hazardous materials is properly
recorded and reported. Ensures the transport of hazardous materials
is undertaken by an authorized firm(s), according to the required legal
provisions.

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 - Produces monthly and annual environmental reports that include
details on the management of hazardous materials.
- Ensures that all the hazardous materials have associated safety data
sheets.
- Ensures that all the hazardous materials are managed according to
the safety data sheets.
- Reports on all risks, non-compliances with this Plan and incidents
- Ensures all necessary measures are taken to remedy any non-
compliances.
- Investigates accidents and incidents and ensures the implementation
of measures to prevent further accidents/incidents.

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6 Management, Mitigation, Monitoring and Verification
6.1 Management Actions
A range of management actions (and other mitigation measures) are required to be implemented in respect
of hazardous materials management. The specific management actions and measures required of Transgaz
staff and its Contractors (and sub-contractors) are described in Appendix 1 to this CESMP.
6.2 General Monitoring Activities
Monitoring provisions for this Hazardous Materials Management CESMP have been developed through the
process outlined in Table 6.2.
Table 6.2 Approaches to Monitoring

Objective Approach
1: Risk Based Monitoring programs to address material issues based on the use of the ‘source-
pathway-receptor’ approach in the EIA. These are commensurate with:
 the scale and nature of the activity,
 the assessed potential level of impact (and uncertainty thereof), and
 the sensitivity of the local environment within the activity area of influence
2: Compliance Additional monitoring programs to meet specific regulatory needs.
Based
By adopting the above approach, the monitoring plans should meet both Transgaz’s requirement to
understand and manage the Project’s potential impacts for each construction activity/ location and any
specific requirements of the Romanian authorities. The specific monitoring requirements for this Hazardous
Materials CESMP are presented in Appendix 2.
6.3 Management System Verification Monitoring
Management System verification monitoring requirements, as detailed in the F-CESMP Document, are
divided into three levels as shown in Table 6.3 below.
Table 6.3 Auditing Management System

Tier Objective Responsible Description

Tier 1: Transgaz Transgaz These audits are aimed at assessing the Transgaz HSE-MS
management elements and assessing their continued suitability throughout
system audits the project life cycle.
Tier 2: Transgaz Transgaz These audits are undertaken by the Transgaz BRUA team to
CESMP confirm compliance by the Company and its contractors with
audits the CESMPs.
Tier 3: Contractor Contractor These audits are to be undertaken by contractors to confirm
self-audits compliance by themselves and their sub-contractors with the
CESMPs and their own HSE-MS. The managing contractors
shall ensure that audit reports are provided to Transgaz.

In addition to the above, there are also expected to be regulatory audits and lender compliance monitoring
visits. The nature and structure of these will be confirmed with regulators and lenders.

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6.4 Key Performance Indicators
Both the General Monitoring and the Management System Verification Processes require robust Key
Performance Indicators (KPI) to be developed. These are quantitative or qualitative measurements used to
gauge performance over time and can be used to assess the effectiveness of control measures. The KPIs
considered relevant to this Hazardous Materials CESMP are shown in Table 6.4 below.

Table 6.4 Key Performance Indicators for Project Hazardous Materials Management

ID KPI Target Monitoring Measure Associated

management
actions
KPI-001 Number of reported non- Zero per year N/A All measures
compliances with the identified in
requirements of this Appendix 1
CESMP
KPI-002 Number of non-conformities 100% of all non- N/A All measures
closed due to corrective conformities remedied identified in
actions being taken within within the defined Appendix 1
the defined timeframe (set timeframe.
on a case by case basis)
KPI-003 Number of reported Zero per year HM2 All measures
instances of uncontrolled Minimise and continued identified in
releases of hazardous improvement in number Appendix 1
materials, resulting in actual of reported non-
or potential harm to compliances
humans, property or the
environment.
KPI-004 Number of reports of near 100% of near miss N/A N/A
misses reviewed for root reports reviewed and
cause and a corrective shared
action identified and shared
across all spreads within 48
hours to prevent future
occurrence
KPI-005 Number of complaints Zero per year N/A N/A
received from the Minimise and continued
community in relation to the improvement in number
management of hazardous of reported complaints.
materials
KPI-006 % of all staff who have 100% compliance with HM1 N/A
received relevant and training requirements.
adequate training

The specific auditing and monitoring requirements for the verification of each of the management measures
described within this Hazardous Materials CESMP (Appendix 1) are identified in Appendices 1 and 2. This
includes identification of the relevant audit tier level (1 to 3) to be undertaken.

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6.5 Training
Training needs for all Transgaz and Contractor staff shall be identified at the outset, before construction
works commence, and a training plan developed.

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7 Appendices
7.1 Appendix 1: Mitigation Measures & Management Actions

Ref. Topic Location Requirement Responsibility Verification

Process
HM Hazardous All sites All requirements in the Environmental Agreement in Contractor
001 Materials relation to Hazardous Materials must be met.
Management
HM Hazardous All sites Any relevant requirements in the Pollution Contractor
002 Materials Prevention CESMP associated with Hazardous
Management Materials management should be put in place.
HM Material All sites All hazardous materials will be evaluated in Contractor Audit of chemical
003 assessment accordance with relevant regulatory requirements. and hazardous
and selection Such assessments will be undertaken by a suitably materials register
qualified and experienced individual and approved and records
by the H&S and Training Manager.

HM Hazardous All sites All chemical substances and compounds purchased Contractor Audit of Technical
004 materials from suppliers used on the site will be accompanied Safety Data Sheets.
inventory by their Technical Safety Data Sheets that meet the Visual confirmation
requirements of Regulation 1907/2006 (REACH) as of TSDSs at storage
regards their content. The purchase of chemicals for areas and points of
which the supplier can provide proof of their pre- use.
registration to the European Chemicals Agency shall
be performed in compliance with the same
provision. These will be available in the storage
locations and principle points of use.
Ref. Topic Location Requirement Responsibility Verification
Process
HM Storage All sites Storage of fuel will be in tanks equipped with locking Contractor
005 procedures devices and which have secondary containment Visual inspections
(with 110% capacity) that are located on a platform
in a designated area located away from any
watercourse or drain

HM Storage All sites *The metal containers for the deposit of used oils Contractor Visual inspections
006 procedures shall be adequately marked (with the code of the Audit of records of
type of used oil) and they shall be located on inspections and
concreted surrounded areas. any repairs.
Waste oils will not be stored in underground tanks.
Storage tanks will be emptied and inspected
regularly for any signs of cracks or holes. The
findings of the inspection will be recorded; any
cracks or holes will be repaired, and any repairs
conducted will be recorded.
HM Spill Response All sites Spill kits, protective equipment, and other necessary Contractor Visual inspections
007 equipment will be available where hazardous
materials are handled, to enable any spills to be
cleaned up.

HM First Aid All sites Appropriate first aid will be located close to Contractor Visual inspections
008 hazardous material storage areas such as eye-wash,
showers, and first aid kits.

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Ref. Topic Location Requirement Responsibility Verification
Process
HM Transport During Hazardous materials will only be transported in Contractor Visual inspections
009 transport vehicles authorized for the transport of hazardous Audit of relevant
substances according to the requirements of paperwork for the
Government Decision No. 1175/2007 and which hold transport of
a transport license for hazardous substances and an hazardous
ADR certificate. materials.
HM Transfer All sites Dedicated fittings, pipes, and hoses specific to the Contractor Visual inspections.
010 procedures hazardous materials being stored must be used, and Audit of Hazardous
procedures followed to prevent the addition of Materials
hazardous materials to the incorrect tank. Management
procedures
HM Transfer All sites Equipment that is compatible and suitable for the Contractor Visual inspections
011 procedures characteristics of the hazardous material being
transferred must be used to ensure safe transfer.

HM Transfer All sites The transfer of hazardous materials from vehicles to Contractor Visual inspections
012 procedures storage tanks must be conducted on impervious
hard standing, which is sloped to a collection or a
containment structure, not connected to municipal
wastewater/storm water collection system.

HM Transfer All sites Written procedures for transfer operations must be Contractor Audit of written
013 procedures prepared that include a checklist of measures to procedures.
follow during filling operations for storage tanks.

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Ref. Topic Location Requirement Responsibility Verification
Process
HM Storage All sites Incompatible materials (acids, bases, flammables, Contractor Visual inspections
014 procedures oxidizers, reactive chemicals) must be stored in
separate areas, and with containment facilities
separating material storage areas. The storage and
use of hazardous substances will be done under
conditions of maximum security.

HM Storage All sites Material-specific storage for extremely hazardous or Contractor Visual inspections
015 procedures reactive materials will be provided.

HM Health & All sites All sources of ignition near to flammable storage Contractor Visual inspections
016 Safety tanks are prohibited.

HM Storage All sites Drummed hazardous materials will be stored in Contractor Visual inspections
017 procedures areas with impervious surfaces that are sloped, or
bunded to retain any spills/leaks

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Ref. Topic Location Requirement Responsibility Verification
Process
HM Fuelling All sites Fuelling of vehicles will only be undertaken in Contractor Visual inspections
018 procedures specially designated areas inside the site
organization and for machines from off site, the
supply shall be done only in compliance with all
environmental protection norms.

HM Storage All sites Containers holding flammable and/or toxic materials Contractor Visual inspections
019 procedures will be kept permanently closed and covered. They
shall be kept in their original packaging and they
shall be handled and transported under maximum
security.

HM Emergency All sites There will be strict compliance with all relevant Contractor Internal audit
020 response guidelines for health and safety at work and with the
provisions of the Emergency Response Plan
HM Accidental All sites Any accidental leaks of fuel or oil will be immediately Contractor Audit of incident
021 leaks cleaned up with absorbent material and collected in reports.
closed and labelled containers - temporarily stored
in specially designed spaces until delivery to an
operator authorized for the collection / disposal of
oil waste.
HM Accidental All sites All equipment and machinery involved in the Contractor Visual inspections
022 leaks construction of the trench will be well maintained
and periodically inspected to avoid the accidental
loss of fuels and oils.

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 Ref. Topic Location Requirement Responsibility Verification
Process
HM Storage All sites Chemicals with different hazard symbols should not Contractor Visual inspections
23 procedures be stored together

HM General All Sites All relevant mitigation measures in relation to the Contractor
24 Principles management of hazardous materials included in the
Environmental Agreement will be complied with.
HM Disposal All Sites All Hazardous Materials must be disposed of Contractor Audit of relevant
25 according to the requirements of relevant national / paperwork for the
EU legislation disposal of
hazardous
materials
HM Recording All Sites Maintenance of a hazardous materials register which Contractor Audit of the
26 is updated monthly register

* Commitment from the Environmental Permit.

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7.2 Appendix 2: Monitoring Requirements
ID Activity Description Parameters Location Standards Frequency Tier (1/2/3)
HM1 Training Audit of records to Evidence of training provided. All Level of training Tier 2 – bi-annual 2&3
demonstrate all construction required Tier 3 - quarterly
contractor/sub-contractor sites and
staff have received storage
relevant training depots
HM2 Storage Audit of any storage  Incidents of water pollution All Incident reports Tier 2 – bi-annual 2&3
failures  Incidents of soil contamination construction Tier 3 - quarterly
 Health & Safety incidents sites and
relating to incorrect storage of storage
hazardous materials depots
HM3 Recording Audit of the hazardous Evidence of accurate recording of All Register Tier 3 – quarterly 3
materials register hazardous materials construction completed
sites and accurately
storage
depots

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7.3 Appendix 3: Relevant Legislation

The indicative list of Romanian national legislation regarding hazardous materials - general framework

Law 360 of September 2nd, 2003 (*republished*) on the regime of hazardous chemical substances and
preparations, as further amended and supplemented

European Union Regulations (directly applicable)

Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on
classification, labelling and packaging of substances and mixtures, amending and repealing Directives
67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006
Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006
concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), establishing
a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No
793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and
Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC