Pollution Prevention Procedure

Document Title: Pollution Prevention Procedure

Document No.: CAL00-TAP-QHSE-Y-TPA-0001 Rev. 1

Classification: INTERNAL

Copyright Reserved: This document may not be copied, shown to or placed at the disposal of third parties of 43

without prior consent of TAP AG. The latest version of the document is registered in the TAP Project’s Database.

Table of Contents

1. Introduction ......................................................................................................................................... 4

1.1 Scope ............................................................................................................................................ 4

1.2 Purpose ......................................................................................................................................... 4

1.3 Abbreviations and Definitions ....................................................................................................... 5

1.4 Roles and Responsibilities ............................................................................................................ 6

1.4.1 Operations and Maintenance Country Manager .................................................................... 6

1.4.2 TAP QHSE Officer(s) ............................................................................................................. 6

1.4.3 O&M Contractor(s) ................................................................................................................. 7

1.4.4 All TAP AG and O&M Contractor personnel .......................................................................... 7

2. References .......................................................................................................................................... 8

3. Pollution Prevention Procedure .......................................................................................................... 9

3.1 Noise Management ..................................................................................................................... 10

3.2 Dust Management ....................................................................................................................... 10

3.3 Light Management ...................................................................................................................... 11

3.3.1 TAP Facility Surveys ............................................................................................................ 11

3.3.2 Community Surveys ............................................................................................................. 11

3.4 Groundwater Monitoring.............................................................................................................. 11

3.5 Discharge Management .............................................................................................................. 12

3.5.1 Stormwater ........................................................................................................................... 12

3.5.2 Sanitary Wastewater ............................................................................................................ 18

3.5.3 Process Wastewater (condensate) ...................................................................................... 22

3.6 Pollution Prevention and Control ................................................................................................ 24

3.6.1 Hazardous Material Storage and Handling .......................................................................... 24

3.6.2 Maintenance of Process Equipment, Facilities and Vehicles .............................................. 26

3.6.3 Refuelling ............................................................................................................................. 26

3.6.4 Spill Preparedness and Response ....................................................................................... 26

Spill Clean Up................................................................................................................................ 27

3.7 Compliance Monitoring and Reporting ........................................................................................ 27

3.7.1 Community Engagement...................................................................................................... 30

3.7.2 Training and Awareness ...................................................................................................... 30

4. Records ............................................................................................................................................. 31

5. Changes Since Last Revision ........................................................................................................... 32

6. List of Appendices ............................................................................................................................. 33






6.1 Appendix 1 TAP Operations Activities, Products and Services List ........................................... 34

6.2 Appendix 2 Hazardous Material Inventory .................................................................................. 38

6.3 Appendix 3: Environmental Inspection Checklist ........................................................................ 39






1. Introduction

This Pollution Prevention Procedure describes the requirements and best practices for prevention of pollution and management of nuisances and discharges during TAP operations phase.

This procedure is subordinate to and shall be read in conjunction with TAP AG Environmental and Social Management Manual (Ref. 1) which provides an overview of all TAP environmental, socio-economic and cultural heritage aspects and how impacts are identified, avoided, mitigated or managed in accordance with TAP AG commitments and TAP Operations Environmental Standards (Ref. 2).

This document contains requirements in addition to any legal requirements applicable to TAP AG

(arising from national and/or EU legislation and the ESIA approvals in place), and therefore no such

provision has any effect whatsoever on the fulfilment of these legal obligations by TAP AG. This

document includes additional requirements formulated by, and incumbent on, TAP AG and, therefore,

does not give any right to third parties and are not enforceable by any third party beyond any legal rights

they may have in accordance with applicable laws.

1.1 Scope

This procedure is applicable to the following TAP AG owned and operated facilities in Greece, Albania

and Italy:

– Pipeline right of way (550 km) from the border between Greece and Turkey in Kipoi up to

the border between Greece and Albania, including the compressor station at Kipoi and 23

block valve stations

– Pipeline right of way (215 km) from Qendër, Bilisht in Korçë to 17 km north-west of Fier,

approximately 400 m inland from the shoreline, the compressor station near Fier, the

metering station near Bilisht and 9 block valve stations

– Pipeline right of way (105 km) pipeline traversing the Adriatic Sea to the Italian coast, the

micro-tunnel site near the town of San Foca, the pipeline right of way (8.2 km), Pipeline

Receiving Terminal and back-up control centre in Brindisi.

This procedure applies to TAP AG and Operations and Maintenance (O&M) contractors undertaking work within TAP AG operational facilities listed above. The list of activities products and services applicable to TAP AG operations are provided in Appendix 1.

This document shall take effect from the commencement of commercial operations and shall supersede

the previous construction phase Pollution Prevention Contractor Control Plans (Ref. 3-7).

The scope of this procedure includes noise, dust, light, groundwater monitoring and management of discharges (stormwater, sanitary wastewater, oil separator and process condensate discharges) from TAP AG facilities listed above. The framework for management of air quality and emission monitoring are detailed within separate documents (see Section 2).

1.2 Purpose

The purpose of this procedure is to:

– present a clear framework of the tools and processes in place to manage pollution

prevention, nuisance and discharge during TAP operations phase

– to meet TAP AG obligations under the commitments of the approved TAP Environmental

and Social Impact Assessments (ESIA) for Greece, Albania and Italy (Ref. 8-10) including

subsequent approved amendments.






Where necessary, this document refers to other parts of the TAP AG QHSE Management System, which provides supplementary technical details relevant to prevention of pollution and nuisance and discharge management.

1.3 Abbreviations and Definitions

Abbreviation Definition

ACS02 Metering Station in Albania

ACS03 Compressor Station in Albania

BCMA Billion Cubic Metres per Annum

BVS Block Valve Stations

CCP Contractor Control Plan

dB Decibel

dB(A) A-weighted decibels

E&S Environmental and Social

ESCH Environmental, Social and Cultural Heritage

EHS Environment, Health and Safety

ESIA Environmental Social Impact Assessment

ESMS Environmental and Social Management System

EU European Union

FCU Filter coalescer unit

GCS00 Compressor Station in Greece (10 BCMA case)

GCS01 Compressor Station in Greece (20 BCMA case)

IPR01 Pipeline Receiving Terminal in Italy

LAeq Sound level in decibels equivalent to the total A-weighted sound energy measured over a stated period of time.

MSDS Material Safety Data Sheet

O&M Operations and Maintenance

PD Presidential Decree

PM10 Particles of 10 micrometres or less in aerodynamic diameter

PRT Pipeline Receiving Terminal

TAP Trans Adriatic Pipeline

TAP AG Trans Adriatic Pipeline AG

Term Definition

Competent authority

any person or organization that has the legally delegated or invested authority, capacity, or power to perform a designated function, such as national ministry, a regional authority, a local council, or another public or private body that has been nominated and approved by the national government

Hazardous waste

Any industrial by-product that is destructive to the environment, flora, or fauna or dangerous to public health as defined by applicable legislation and displays one or more of the hazardous properties listed in Annex III of EU Directive 2008/98

http://www.acoustic-glossary.co.uk/sound-level-and-sound-level-meters.htm

http://www.acoustic-glossary.co.uk/definitions-d.htm#decibel

http://www.acoustic-glossary.co.uk/frequency-weighting.htm






Term Definition

Receptor An ecosystem or part of an ecosystem of interest that may potentially be impacted by pollutant concentrations or atmospheric deposition (e.g. organisms, plant communities, terrestrial ecosystems, groundwater, surface waters, etc.)

Spill Accidental discharge of a solid product or liquid that by its nature, quantity and location, is considered a potential risk

Wastewater Liquid effluent generated in a facility, either as a result of an operational process, by the personnel, or by the combination of both

1.4 Roles and Responsibilities

TAP AG organization, with its headquarters in Switzerland, includes roles such as the Operations Director, who shall support the roles and responsibilities presented below.

1.4.1 Operations and Maintenance Country Manager

Environmental Management of hot commissioning, introduction of hydrocarbons, operations and maintenance of TAP pipeline systems in each host country has been delegated to Operations and Maintenance Country Manager(s) in the three countries respectively, who shall be responsible for:

– Ensuring compliance with and implementation of TAP AG standards and QHSE

Management system, including applicable environmental and urban and land planning

legislation, Lenders and ESIA requirements, implementation of practices for prevention of

pollution and management of waste, operation of facility flood protection, drainage and runoff

systems

– Ensuring implementation of pollution prevention controls outlined in Section 3 of this

procedure.

1.4.2 TAP QHSE Officer(s)

The QHSE Officer(s) based in each country of operation and assigned to the respective country facilities shall be responsible for:

– Preparation, implementation and update of this procedure

– Implementing monitoring requirements outlined within Section 3.6 of this procedure

– Undertaking compliance monitoring and reporting results to the TAP AG management

– Identification and verification of closure of actions

– Recording and reporting pollution, nuisance and discharge related incidents

– Providing training, guidance and awareness to TAP AG personnel on pollution prevention

requirements

– Compiling annual statistics on pollution prevention, nuisance and discharge management

– External reporting to competent authority as required under national legislation and

approved TAP Environmental and Social Impact Assessments (ESIA) for Greece, Albania

and Italy (Ref. 8-10) including subsequent approved amendments

– Carrying out analysis of performance data and making necessary recommendations for

improvement

– Monthly review and revision of the hazardous material inventory






– Maintaining a database of material safety data sheets (MSDS) for all

chemicals/lubricants/fuels used and stored at TAP operations facilities.

– Support TAP AG procurement process in selection of all contractors engaged in pollution

prevention monitoring and reporting to ensure they achieve a minimum standard for quality

(e.g. accreditation to ISO 17025), QHSE management as well as ability to comply with a

detailed method statements when undertaking sampling and analysis.

1.4.3 O&M Contractor(s)

TAP O&M Contractors shall be responsible for:

– Acting in accordance with the relevant Maintenance contract and this procedure

– Ensuring full compliance with the provisions of this procedure and applicable national legal

requirements by its personnel and its subcontractor personnel

– Reporting of incidents, including incidents related to pollution

– Maintaining TAP operational facilities and associated equipment as per manufacturer

recommendations

– Implementing preventive maintenance programme for TAP operational facilities and

associated equipment falling within their scope.

1.4.4 All TAP AG and O&M Contractor personnel

Personnel shall have a responsibility to:

– Follow pollution prevention, nuisance and discharge management requirements outlined

within this procedure

– Promptly report all faulty / defective TAP owned equipment to the QHSE Function

– Contact TAP QHSE Inspector or designated O&M Contractor person (as the case may be)

in the event of encountering unidentified waste, source of pollution or when unclear on

requirements of this procedure

– Following health and safety precautions specified within MSDS when handling hazardous

substances.






2. References

No Document Title Document Number

1 Environmental and Social Management Manual CAL00-TAP-QHSE-Y-TMT-0001

2 Operations Environmental Standards Manual CAL00-TAP-QHSE-Y-TMT-0002

3 TAP Albania Onshore Pollution Prevention CCP AAL00-RSK-601-Y-TTM-0002

4 TAP Albania Offshore Pollution Prevention CCP AAL00-RSK-601-Y-TTM-0024

5 TAP Greece Onshore Pollution Prevention CCP GAL00-ENT-601-Y-TTM-0002

6 TAP Italy Onshore Pollution Prevention CCP IAL00-RSK-601-Y-TTM-0002

7 TAP Italy Offshore Pollution Prevention CCP IAL00-RSK-601-Y-TTM-0015

8 Environmental and Social Impact Assessment (ESIA) for Greece

GAL00-ENT-642-Y-TAE-0001

9 Environmental and Social Impact Assessment (ESIA) for Albania

AAL00-ENT-641-Y-TAE-0001

10 Environmental and Social Impact Assessment (ESIA) for Italy

IAL00-ERM-643-Y-TAE-1011

11 Method Statement Noise Monitoring CAL00-TAP-QHSE-Y-TAG-0004

12 Environmental Monitoring Project Italy IAL00-ERM-643-Y-TAE-1028

13 Method Statement Light Monitoring CAL00-TAP-QHSE-Y-TAG-0003

14 Method Statement Groundwater Sampling CAL00-TAP-QHSE-Y-TAG-0002

15 Method Statement Wastewater Sampling CAL00-TAP-QHSE-Y-TAG-0001

16 Waste Control Procedure CAL00-TAP-QHSE-Y-TPA-0007

17 Environmental Engineering Verification Register CAL00-PMT-601-Y-TAT-0001

18 HSE Hazard – Impact and Risk Assessment Procedure

CAL00-TAP-QHSE-X-TPA-0016

19 Crisis and Emergency Response Plan CAL00-TAP-QHSE-X-TTA-0001

20 Scenario Specific Response Guidelines - Fuel Oil Condensate Spill During Transfer

CAL00-TAP-QHSE-S-TVN-0005

21 QHSE Incident Reporting and Investigation Procedure

CAL00-TAP-QHSE-X-TPA-0008

22 Non-Conformity Management Procedure CAL00-TAP-QHSE-X-TPA-0002

23 Stakeholder Engagement Procedure CAL00-TAP-SKE-X-TPA-0001

24 Grievance Management Procedure CAL00-TAP-QHSE-Y-TPA-0002

25 QHSE Training Procedure CAL00-TAP-QHSE-X-TPA-0006

26 Records Retention Guidelines CAL00-TAP-LEG-X-TPA-0001






3. Pollution Prevention Procedure

The process of TAP AG pollution prevention is presented in Figure 1 below. Further detail on the process is provided in Section 3.1 – 3.7 of this procedure.

QHSE OfficerTAP Operations QHSE Officer

Start

3.1 Noise Management

3.2 Dust Management

3.3 Light Management

Finish

Ok?

Measurement Record Sheets

Environmental Inspection Checklist

3.4 Groundwater Monitoring

3.5 Discharge Management

3.6 Pollution Prevention and

Control

YES

3.7 Compliance Monitoring and

Reporting

Figure 1 Pollution Prevention Process






3.1 Noise Management

Noise has the potential to create discomfort and or disturbance to humans and fauna species. The main routine noise sources present at the TAP operational facilities include filters, compressors, gas turbines, generators, stacks, air ventilation systems, pressure control valves and piping. All equipment shall be compliant with the applicable limit values and, where necessary, noise attenuation packages shall be provided.

Applicable noise standards are detailed in Table 1 and Table 2 and were taken from the TAP Operations Environmental Standards (Ref. 2).

Table 1 - Noise Standard During Operations for Greece, Italy and Albania

Parameter Value, dB(A) Basis / Source Directive

Maximum noise level attributed to TAP operations

45 World Bank (1999) and IFC General EHS Guidelines (2007)

Maximum increase in background levels at the nearest existing sensitive receptor location off-site

3 World Bank (1999) and IFC General EHS Guidelines (2007)

Table 2 - Noise Standard for Compressor Station Fence During Operations for Greece and Albania

Parameter Value, dB(A)

Basis / Source Directive

Greece Albania

Noise level at the compressor station fence (measured as hourly averaged noise level)

LAeq ≤65 Presidential Decree (PD) 1180, 6 October 1981 (Gov. Gaz 83/A)

Albanian Directive No.8 dated 27.11.2007 “Noise limits in certain environments”

Note: the equivalent noise limit does not apply to the PRT in Italy

All vehicles, plant and equipment engines shall be maintained by the O&M Contractor to minimise noise emissions. Where appropriate, inherently quiet engines shall be selected for use on TAP facilities.

Ambient noise monitoring requirements are detailed within Method Statement Noise Monitoring (Ref. 11).

3.2 Dust Management

Dust generation from vehicle movements shall be controlled and minimised on roads used to access the compressor and metering stations. Movement of traffic on both paved and non-paved roads shall be subject to regulatory speed restrictions. The potential for dust generation is considered low and no routine dust monitoring shall be completed. Vehicle movements associated with operations and maintenance are considered low in volume, and therefore associated effects on air quality are not seen as key impacts.

Majority of traffic during operations shall use the paved main roads to access the GCS00, ACS02, ASC03 and PRT, thus minimising the potential for generation of dust.

In the event of justified complaints associated with generation of dust by TAP operations, TAP AG shall determine dust mitigation measures, as well as consider the need to undertake monitoring for PM10.






3.3 Light Management

3.3.1 TAP Facility Surveys

Light pollution is not considered to be a concern at any of the operational facilities. However, light monitoring shall be undertaken to ensure that light remains at acceptable levels. A reconnaissance visit shall take place prior to the start of the light monitoring survey to identify the type, direction and position of any lighting around the TAP facility boundaries. Five potential light monitoring points shall be identified for each facility and photographs of the lighting installations shall be taken where possible.

In Greece and Albania, the monitoring survey shall be undertaken according to the Institution of Lighting Professionals (ILP) guidance1. The residential areas surrounding the TAP AG facilities are considered to be “E2”, under the ILP guidance for identifying environmental zones. This means that the areas are classified as “low district brightness areas (rural or small village locations)”. The recommended lighting conditions for the “E2” Environmental Zone are given in Table 3 below. These are based on the level of obtrusive light, e.g. light streaming in through bedroom window keeping a person awake.

Table 3 – Obtrusive Light Limitations for Greece and Albania

Environmental Zone Recommended Level (Lux)

Pre-curfew Post-curfew

E2 5 1

Note: curfew is 23:00 hrs

No light monitoring will be undertaken at Italy facility (PRT) as it is not required under the approved Environmental Monitoring Project Italy (Ref. 12).

3.3.2 Community Surveys

For the community light surveys, one location at each receptor shall be selected for Greece and Albania. The purpose of the light monitoring assessment is to confirm that levels of light pollution associated with TAP facilities do not exceed the Institution of Lighting Professionals Guidance Levels for rural or small village locations. The survey shall be used to determine if any mitigation measures are required to keep light pollution to a minimum.

A baseline light survey is to be conducted at each survey location in order to establish the baseline lighting conditions and thus identify any increase that can be attributed to TAP operations. Light monitoring requirements are detailed further within Method Statement Light Monitoring (Ref. 13).

3.4 Groundwater Monitoring

Groundwater shall be sampled via boreholes to obtain a sample that is representative of groundwater conditions in the vicinity of the compressor station in Greece, compressor and metering stations in Albania and PRT in Italy. The samples shall be analysed and compared against background conditions and groundwater limit values. At each borehole location, a note shall be made of any visual observations on any contamination and a photograph shall be taken at each sampling location.

In Italy groundwater monitoring shall be conducted as prescribed in Verification of Compliance A.20 and A.31 and as detailed within Annex 7 of the approved Environmental Monitoring Project Italy (Ref. 12).

In Greece and Albania baseline groundwater samples shall be collected and analysed at each borehole location before commencement of operations to establish baseline existing conditions. This will allow for comparison and indicate any impacts TAP operations may have on the groundwater quality. In Italy baseline groundwater quality data is already available from pre-construction and construction phase monitoring performed.

1 Guidance Notes for the Reduction of Obtrusive Light GN01:2011: https://www.theilp.org.uk/documents/obtrusive-light/

https://www.theilp.org.uk/documents/obtrusive-light/






Further details on groundwater monitoring requirements are detailed within Method Statement: Groundwater Sampling (Ref. 14) which lists groundwater monitoring parameters and threshold values.

3.5 Discharge Management

The following types of wastewater shall be managed as part of TAP operations:

– Stormwater

– Sanitary wastewater

– Oil separator wastewater

– Process condensate.

Wastewater monitoring requirements, parameters and threshold values are detailed within Method Statement Wastewater Sampling (Ref. 15). A description of the discharge flows and sampling locations for each facility is provided in Figures 2-13.

Wastewater sampling shall be performed in order to obtain a sample that is representative of the discharge conditions. The samples shall be analysed and compared against the relevant discharge limit values. At each sampling location, a note shall be made of the meteorological conditions, any visual observations for contamination and a photograph shall be taken at each sampling location.

3.5.1 Stormwater

Greece and Albania

In Greece (GCS00) the uncontaminated storm water from unpaved and certain undeveloped areas shall be collected along with stormwater from paved areas, roofs and gullies, and shall be routed to the storm water drainage network (Figure 2). Such design is a result of geotechnical investigations that recommended that infiltration through the ground cannot be relied upon and the area shall be drained to prevent deterioration and instability. In Albania (ACS02 and ACS03) the uncontaminated stormwater from unpaved areas that infiltrates through the ground and loose gravel layer along with stormwater received from paved areas, roofs and gullies shall be routed to the stormwater drainage network (Figures 3 and 4).

Oil separators shall be provided for the diesel generator areas, gas filters and lubricant oil coolers at all facilities and shall be designed to EN 858 standard with an outlet specification of 5 ppm oil. Equipment bunds at the gas filters and lubricant oil cooler areas shall have check valves which shall be normally closed allowing rainwater to accumulate. Following a rainfall event, the operator shall inspect the bunds, and if the water is uncontaminated, or if there is minor contamination, shall allow the water to pass to the oil separators at a controlled rate, prior to routing it to the storm water drainage network. Stormwater with major contamination within the bunds shall be emptied by a vacuum truck and sent to a third-party disposal at a licensed facility. Transfer of waste shall be subject to requirements of the Waste Control Procedure (Ref. 16).

At diesel generator areas the rainwater discharge rate is expected to be large; subsequently under normal rainfall events the water shall be sent to the oil separators prior to routing to the storm water network. In the event of peak rainfall, the water shall enter the stormwater drainage network directly through overflow pipes. Since the flowrate is high, any contamination present is expected to be highly diluted.

From the facility drainage networks, the stormwater shall be discharged into the existing drainage channels via provided outlets.

Italy

The PRT site (IPR01) shall have two separate storm water pipe diversion systems (Figure 5):






– System A for stormwater from access road and process areas with a potential of

hydrocarbons and

– System B for stormwater from buildings and areas not anticipated to be contaminated.

The catchment for system B shall also include large permeable areas with some infiltration of water. First flush collection tanks for both systems shall be sized to accommodate rainfall for a return time of 5 years. Stormwater flows exceeding first flush collection tanks both systems A and B shall flow directly into the lamination basin. Since this system shall only be used during large rainfall events it is expected that water will not be contaminated, and any oily discharge present will be highly diluted. Both first flush tank excess flow lines shall have a sample collection point.

System A also shall have an additional line that bypasses the first flush collection tank for high flows (~0.5m3/s). This water shall be sent to a sand/sludge removal system and an oil removal system before passing to the lamination basin. This extra provision is allowed since the water collected in system A is anticipated to contain higher concentrations of sand, sludge and oil than the water in system B. Discharge for both systems A and B shall be ultimately sent to the lamination basin, which shall be designed to allow infiltration of discharge to soil.






Figure 2 GSC00 Stormwater flow diagram

GCS00 Stormwater Discharge

SourceHolding Tank /

Collection PointDischarge Receiving SystemRoute

Op

erat

ion

s

Stormwater from unpaved surfaces and undeveloped

areas

Stormwater from paved surfaces, roofs and gullies

Stormwater Drainage Network

Gas Filter Catchment Area

Diesel Generator Area

Collected

No / minor contamination

Oil Separator 1.1

Oil Separator 3

Outlet 1

Outlet 2

Existing Drainage Channel

Collected

Major Contamination

Peak rainfall overflow line

GSW2

GSW1 (A) GSW4

GSW5

Collection by 3rd party for disposal at licensed facility

Lube Oil Coolers Catchment Area

Oil Separator 2

GSW3

Major Contamination


Outlet from non-paved

areas

Sampling Point Check valve (normally closed) Stormwater flow Potentially / contaminated wastewater flow

Oil Separator 1.2

Normal rainfall

GSW1 (B)

Flow Splitting

Pit

Note: GWS1 (A/B) – batch sample)






Figure 3 ACS02 Stormwater flow diagram

ACS02 Stormwater Discharge



Op

erat

ion

s

Stormwater from unpaved surfaces





Infiltrated through ground and loose gravel

No /minor contamination

Oil Separator 2

Oil Separator 3

Outlet 1

Outlet 2

Outlet 3


Collected

Major Contamination

Oil Separator 1

Peak rainfall overflow pipe

ASW3

ASW1

ASW4

ASW5

ASW6


ASW2

Normal rainfall

Flow Control Pit






Figure 4 ACS03 Stormwater flow diagram

ACS03 Stormwater Discharge



Op

erat

ion

s

Stormwater from unpaved surfaces





Infiltrated through ground and loose gravel


Oil Separator 1.1

Oil Separator 3

Outlet 4

Outlet 3

Outlet 1


Collected

Major Contamination

Peak rainfall overflow line

ASW 8

ASW7(A)

ASW13

ASW12

ASW10

Collection by 3rd party for disposal at licensed facilityLube Oil Coolers

Catchment Area

Oil Separator 2

ASW9

Major Contamination


Outlet 5

ASW14

Outlet 2

ASW11

Outlet 6

ASW15

Oil Separator 1.2

Oil Separator 1.3

Normal rainfall

ASW7 (B)

ASW7 (C)

Flow Splitting

Pit






Figure 5 IPR01 Stormwater flow diagram

IPR01 Stormwater Discharge

SourceIntermediate Holding

TanksCollection Point Discharge Receiving SystemRoute Secondary System

Op

erat

ion

s

Stormwater from access Road

Stormwater from buildings

Stormwater large impermeable

areas

Stormwater pipe diversion system A

Stormwater pipe diversion system B

First Flush Tank

First Flush Tank

Sand / sludge removal system

Oil Removal System

Lamination Basin

Oil Separator and Absorbent Filter

Oil Separator and Absorbent Filter

ISW6

ISW2

Flows <~ 0.46m3/s

Flows ~ 2.5m3/s

Flows >~0.46m3/s (in excess of first flush tank capacity)

Flows > 0.5m3/s

Activated Carbon Filter

ISW3

Flows ~2.5l/s

Flows ~ 0.5m3/s

IWS4

Infiltration

SOIL

ISW1

ISW5

Sampling Point Check valve (normally closed) Stormwater flow Potentially / contaminated wastewater flow

Flows <0.5m3/s






3.5.2 Sanitary Wastewater

At GCS00 (Figure 6) and ACS03 (Figure 7) sanitary wastewater and floor drains shall be collected from the stores, workshop, administration and utility buildings and routed to the wastewater drain network of each facility. The wastewater from floor drains for the station vehicle /crane areas and the lubricant oil storage areas within GSC00 and ACS03 shall be routed through oil separators located outside of the utility buildings before connecting with the wastewater drain network. At ACS003 all wastewater shall be treated within an onsite wastewater treatment plant before being discharged to the existing drainage channel. At GCS00 all wastewater shall be accumulated within the underground wastewater storage tank and removed by a vacuum truck for disposal at a licensed third-party facility. Transfer of waste shall be subject to requirements of the Waste Control Procedure (Ref. 16).

At ACS02 (Figure 8) volumes of sanitary wastewater are expected be low due to limited presence of personnel. It shall be collected and stored on site and sent for treatment at a licensed third party. Transfer of waste shall be subject to requirements of the Waste Control Procedure (Ref. 16).

At IPR01 (Figure 9) the sanitary wastewater and floor drainage shall be collected from the pump and main building and routed to the onsite wastewater treatment plant before being routed to the lamination basin.

Wastewater treatment plants at ASC03 and IPR01 shall be subject to review in the Environmental Engineering Verification Register (Ref. 17). Individual operation and maintenance procedures shall be developed for each unit as part of the engineering verification process.






Figure 6 GCS00 Sanitary Wastewater flow diagram

GCS00 Sanitary Wastewater Discharge

SourceHold Tank /


Op

erat

ion

s

Electrical Building

Area floor drains

Bathroom drain

Sampling Point Sanitary wastewater flow

Administration Building

Area floor drains

Bathroom drain

Stores and Workshops Buildings

Area floor drains

Bathroom drain

Utility Building

Station Vehicle / Crane floor drain

Lube oil storage floor drain

Water Treatment Unit

Bathroom drain (basin)

Instrument Air drainage lines

Boiler Safety Valves

Area floor drains

Acid neutralisation units

Oil Separator

GWW1

Wastewater drain network

Potentially / contaminated wastewater flow

Underground Wastewater Storage Tank


GWW2

Filter Bund Drainage






Figure 7 ACS03 Sanitary Wastewater flow diagram

ACS03 Sanitary Wastewater Discharge



Op

erat

ion

s

Electrical Building

Sampling Point Sanitary wastewater flow

Administration Building

Area floor drains

Bathroom drain

Stores and Workshops Buildings

Area floor drains

Bathroom drain

Utility Building

Station Vehicle / Crane floor drain

Lube oil storage floor drain

Water Treatment Unit

Bathroom drain (basin)

Instrument Air drainage lines

Boiler Safety Valves

Area floor drains

Acid neutralisation units

Oil Separator

AWW2

Wastewater treatment plant


AWW3

Potentially / contaminated wastewater flow

Area floor drains

Bathroom drain







Figure 8 ACS02 Wastewater flow diagram

ACS02 Sanitary Wastewater Discharge

Source Route Receiving System Holding Tank / Collection Point Discharge

Op

erat

ions

Sampling Point Sanitary Wastewater flow

Wastewater Drain Network

Wastewater Storage Tank


AWW1

Electrical Building

Area floor drains

Bathroom drain


Figure 9 IPR01 Wastewater flow diagram

IPR01 Sanitary Wastewater Discharge

Source Route Receiving SystemHolding Tank / Collection

PointDischarge

Op

erat

ions

Sampling Point Sanitary Wastewater flow

Pump Building

Area floor drains

Bathroom drain

Wastewater Treatment Plant

Main Building

Area floor drains

Bathroom drain

Lamination Basin Infiltration

SOILIWW1






3.5.3 Process Wastewater (condensate)

At Greece (Figure 10) and Albania (Figures 11-12) facilities the floor drains and condensate pipe network from the FCUs shall be combined with the sanitary wastewater.

In Italy (Figure 13) the liquids collected in the first process unit of the PRT (fuel gas conditioning unit consisting of filter separators that remove any solids and liquids from the gas) shall be collected within the closed drainage system that convey the condensate into a condensate tank. The collected fluids shall be removed by a tanker for disposal at licensed third-party facility. Transfer of waste shall be subject to requirements of the Waste Control Procedure (Ref. 13). To ensure the proper and safe operation of the station, the tank shall be equipped with a flame arrestor 381-FLA as the atmosphere within the tank may become explosive. The tank shall be designed as a double wall tank with a leak detection system to avoid any leakages into ground. The entire condensate tank shall have electrical trace heating and shall be insulated to keep a liquid temperature of at least +700C at the lowest ambient temperature.

Figure 10 GCS00 FCU Condensate flow diagram

GCS00 FCU Condensate Discharge


PointDischarge

Op

erat

ion

s

Condensate flow

Closed condensate drainage network

Condensate Storage Tank


Gas filter separators

Figure 11 ACS02 FCU Condensate flow diagram

ACS02 FCU Condensate Discharge


PointDischarge

Op

erat

ion

s

Condensate flow










Figure 12 ACS03 Condensate flow diagram

ACS03 Condensate Discharge

Source Route Receiving SystemHolding Tank /

Collection PointDischarge

Op

erat

ions

Gas Boiler 1


Condensate flowSampling Point

Gas Boiler 2

Gas Boiler 3

Gas Boiler 4

Acid Neutralisation

Unit

Acid Neutralisation

Unit

Acid Neutralisation

Unit

Acid Neutralisation

Unit

Outlet 4

Outlet 3

Outlet 1


ASW13

ASW12

ASW10

Outlet 5

ASW14

Outlet 2

ASW11

IAEF

Stormwater flow

ACD1

ACD2

ACD3

ACD4

Outlet 6

ASW15





Figure 13 IPR01 Condensate flow diagram

IPR01 Condensate Discharge


PointDischarge

Op

erat

ions




Condensate flow

Gas Filter Separators






3.6 Pollution Prevention and Control

Hazardous materials are those that pose a potential risk to human health or the environment and include cleaning chemicals, solvents, fuels and lubricants.

The flow of permitted discharges from TAP operational facilities shall be managed in accordance with Section 3.5 of this procedure. The following measures shall be implemented across TAP operational facilities to minimise the risk of accidental loss of containment during handling and storage of hazardous materials. Management of hazardous waste shall be subject to requirements of the Waste Control Procedure (Ref. 16).

3.6.1 Hazardous Material Storage and Handling

Pollution Risk Assessment

TAP QHSE Officer shall perform a pollution risk assessment for hazardous liquids stored and used on site considering any legal requirements that may apply (e.g. maximum storage quantities or time periods)

following the risk assessment methodology outlined in the HSE Hazard – Impact and Risk Assessment Procedure (Ref. 18). This shall include assessing risks to the workforce, the environment and, where deemed necessary, the community, and shall include all stages of use (i.e. sourcing, handling, transport, storage, use and disposal). As a result of the risk assessment, TAP QHSE Officer shall identify areas of spill risks and shall maintain a map indicating location of the following:

– Chemical storage areas, tanks and smaller container (e.g. drum) accumulation points

– Fuel storage tanks

– Hazardous waste storage areas

– Spill response equipment.

Storage

Hazardous materials shall be stored in designated areas except for quantities generated or required for the daily operational activities. Hazardous materials required to be temporarily stored onsite shall be stored within secondary containment. The secondary containment shall not be sited within a floodplain or where there is the potential for spilled substance to enter groundwater.

All hazardous material storage facilities shall be located only on flat ground and within a bund designed to contain at least 110% of the total capacity of the storage containers plus 10% of the aggregate tank volume within the containment area or as otherwise specified by regulatory requirements. The bund walls and floor shall be constructed of concrete or other suitably impermeable material. The filling connection shall be positioned within the bund. No drain valves or other connections through the bund walls shall be permitted. Tanks shall be fitted with a gauge to allow the fill level to be monitored during refilling and preferably with a high-level alarm.

The loading and offloading area shall be on hard standing (e.g. concrete) or on an impermeable material and fully kerbed/bunded to collect potential spills.

Individual drums of hazardous materials shall be stored under cover within a secondary containment designed to hold 110% of the capacity of the largest container.

Hazardous materials shall be stored and segregated in accordance with the manufacturers’ material safety data sheet (MSDS) requirements. Hazardous materials shall be appropriately labelled in English and host country language and MSDSs shall be available at each storage area.

All hazardous materials storage areas shall be secured to prevent unauthorised access or use.

Any contaminated rainwater or spills within the bund shall be pumped out, collected, and stored in accordance with Waste Control Procedure (Ref. 16).






Hazardous wastes such as used paint, spent batteries, oil, methanol, ethylene glycol, cleaning agents, and water contaminated by freezing depressants shall be stored and managed in accordance with Waste Control Procedure (Ref. 16).

Transportation and handling

Transportation of hazardous material required for operational needs shall comply with legislative requirements of each jurisdiction through which the materials travel. The O&M Contractor shall ensure that vehicles and containers used are capable of safely transporting hazardous materials in compliance with applicable international and national legislation and international best practice.

Hazardous materials shall only be handled by trained personnel (including qualified drivers). Vehicles transporting hazardous materials shall carry spill kits appropriate for the hazardous materials being transported.

Procedures for safe loading and unloading of bulk products shall be, among others:

– service vehicles shall be equipped with automatic shut-off valves

– brakes shall be set

– wheels shall be chocked

– vehicle shall be grounded/earthed if the product is flammable

– operator shall monitor loading and unloading operations at all times

– when complete, the operator shall examine outlets for leakage and take corrective action if

required.

Hazardous Material Selection

As part of the pollution risk assessment, TAP QHSE Officer shall identify the chemical products to be used and wherever possible avoid the need for their use or propose replacement of environmentally harmful materials with less harmful alternatives. TAP AG shall avoid the use of hazardous materials subject to European and international bans or phase-outs due to their high toxicity to living organisms, environmental persistence, potential for bioaccumulation, or potential for depletion of the ozone layer. TAP AG shall prevent or minimise the potential for community exposure to hazardous materials that may be released by TAP Operations, including during transportation.

TAP shall not use products that fall in the World Health Organisation Recommended Classification of Pesticides by Hazard Class I.a (extremely hazardous) and Class I.b (highly hazardous); or Class II (moderately hazardous). When pest management activities include the use of pesticides, TAP QHSE Officer shall develop a Pest Management Plan that includes:

– minimising, or where possible eliminating the use of pesticides and the hazards and risks to

health and environment from the use of pesticides

– reducing the levels of harmful active substances by replacing the most dangerous with safer

(including non-chemical) alternatives

– selecting pesticides that are low in human toxicity, known to be effective against the target

species, and have minimal effects on non-target species and the environment

– designing the pesticide application regime to minimize damage to natural enemies and

preventing the development of pesticide resistance.

Hazardous Material Inventory

TAP QHSE Officer shall maintain a hazardous material inventory for each hazardous material storage area within the worksite and review it monthly. The template for the inventory is provided in Appendix 2. TAP QHSE Officer shall maintain monthly records of all hazardous materials used and stored on site. This shall include recording information on the sourcing of hazardous materials, the type and quantity stored and used, the location and method of storage and use, and any spills or other incidents that occur.






TAP QHSE Officer shall maintain a database of material safety data sheets (MSDS) for all chemicals/lubricants/fuels used and stored at TAP operations worksites. The file shall be reviewed monthly and updated whenever a new substance arrives at the facility. A copy of this database shall be accessible in the event of an emergency.

3.6.2 Maintenance of Process Equipment, Facilities and Vehicles

The maintenance shall be planned and executed to safeguard correct operation of all facilities and process equipment and shall include inspection and maintenance of pollution abatement and prevention equipment installed within TAP operational facilities.

Where unplanned maintenance has to be carried out, safeguards to avoid contamination of the soil shall be considered (e.g. in unpaved areas the use of tarpaulin to cover the ground if there is a risk of a spill, spill kits positioned adjacent to the work area, etc.). Any maintenance activities within 100m of surface water bodies and vulnerable unconfined aquifers shall only be undertaken with the approval of the QHSE Officer.

Any hazardous waste generated as a result of planned and unplanned maintenance works shall be stored, handled and disposed of in accordance with Waste Control Procedure (Ref. 16). Discharge of oily materials of any kind into waterways or channels leading to waterways shall be prohibited.

All TAP Operations vehicles and vehicles of the O&M contractor(s) shall be serviced and repaired at authorised workshops. Washing of TAP operations vehicles and vehicles of the O&M contractor(s) shall also take place at authorised third-party facilities.

3.6.3 Refuelling

At TAP operational facilities refuelling shall only be carried out, or supervised by, workers trained in refuelling, spill containment and clean-up procedures.

Measures to prevent spillage during refuelling shall include:

– Use of funnels and drip trays where topping up is carried out by jerry cans or similar items

– All fuel nozzles shall be equipped with automatic shut-off refuelling guns on dispensers; any fuel

remaining in the hose shall be returned to the storage facility

– Refuelling equipment shall not be left unattended; operators shall be stationed at both ends of

the hose during fuelling unless the ends are visible and are readily accessed by one operator

– Workers in charge of transfers shall monitor levels to prevent overfilling

– Where mobile fuel tankers are used, appropriate spill kits shall be carried by each team; the

wheels of all vehicles involved in refuelling shall be chocked while refuelling is in progress.

3.6.4 Spill Preparedness and Response

Emergency equipment

All TAP operational worksites shall have emergency response equipment (e.g. spill kits) easily available. As a minimum, spill kits shall be placed at any location where liquid hazardous material is stored. In addition, transportable spill kits shall be available in vehicles that are involved in mobile refuelling activities. The content of spill kits shall be appropriate for the type (i.e. chemical properties) and the volume of hazardous material stored. TAP QHSE Officer shall be responsible for reviewing spill response equipment needs based on the results of pollution risk assessment and shall arrange for replenishment of the spill kits in a timely manner. The number, location and content of spill kits shall be checked by TAP QHSE Officer during regular inspections as per Section 3.7 to ensure they remain adequate for the needs of the TAP operations facility.






Emergency preparedness training

For information on emergency preparedness training and exercises refer to Crisis and Emergency Response Plan (Ref. 19).

Spill Response Actions

In the event of a spill, the process outlined within Scenario Specific Response Guidelines - Fuel Oil Condensate Spill During Transfer (Ref. 20) shall be followed. All spills shall be reported and investigated as per TAP QHSE Incident Reporting and Investigation Procedure (Ref. 21).

Spill Clean Up

Following the spill response, TAP QHSE Officer shall conduct an inspection to identify areas that may potentially require clean-up, disposal (e.g. contaminated ground) and/or additional material or equipment requirements. The contaminated area shall be fully determined in its extent. TAP QHSE Officer shall ensure that appropriate health, safety, and environmental protection measures required by TAP AG and by applicable legislation are adopted during the clean-up process. A risk assessment approach to manage the contaminated land shall be used to evaluate the potential impact of soil or groundwater contamination on local receptors. This approach shall determine the remedial targets as outlined within TAP Operations Environmental Standards (Ref. 2).

TAP QHSE officer shall assess that waste arising from spill clean-up is managed in accordance with Waste Control Procedure (Ref. 16).

3.7 Compliance Monitoring and Reporting

Monitoring of compliance for noise, light, groundwater and discharge standards shall be conducted in accordance with Table 4. Pollution prevention compliance indicators shall be reported in accordance with Appendix 1 of the ESMM (Ref. 1).

Any exceedance of a noise, groundwater and discharge thresholds shall be initially considered a potential incident and shall be investigated to confirm TAP AG’s contribution during the monitoring period, ambient atmospheric conditions and third-party sources and contributions. If its determined that TAP AG was the primary contributor and cause for the threshold exceedance, a full investigation shall be completed.

All contractors engaged in pollution prevention monitoring and reporting shall be selected via TAP AG procurement process to ensure they achieve a minimum standard for quality (e.g. accreditation to ISO 17025), QHSE management as well as ability to comply with detailed method statements when undertaking noise and light monitoring and groundwater and discharge sampling and analysis.

TAP QHSE Officer (or his delegate) shall assess the effectiveness of pollution prevention measures through quarterly visual inspections of the facility. The template for the Environmental Inspection is provided in Appendix 3.

In the case of non-compliance with this procedure or the applicable legislation, TAP QHSE Officer (or his delegate) shall record the non-conformance and track it to closure in accordance with Non-Conformity Management Procedure (Ref. 22).






Table 4 - Compliance Monitoring Requirements

Operations ESMS Document Monitoring / Reporting Requirement

Frequency GREECE ALBANIA ITALY

GCS00 ACS02 ACS03 IPRT

NOISE

Method Statement Noise Monitoring (Ref. 11)

Thresholds provided in Tables 1 and 2 of the Method Statement

Monitoring During Operations Bi-annual Relaxed to annual if: – All noise levels are within limits (or shown to be due toexternal sources)– The site throughput has reached a long-term plateauRelaxed further to once every 2 years after 2 successiveannual surveys meeting the above conditions.

Required 5 community receptors &

5 points at station perimeter fence

Required: 5 community receptors &


Required: 4 community receptors &


Required: 5 locations (N1, N2, N3, N11 and N12 as

per EMP)

LIGHT

Method Statement Light Monitoring (Ref. 13)

Thresholds provided in Table 1 of the Method Statement

Facility Survey Once (not to be repeated if thresholds are not exceeded) Required: 5 points at station perimeter fence

Required: 5 points at station perimeter fence

Required: 4 points at station perimeter fence

Community Surveys Once (not to be repeated if thresholds are not exceeded) Required: 5 community

receptors

Required: 5 community

receptors

Required: 4 community

receptors

GROUNDWATER

Method Statement Groundwater Sampling (Ref. 14)

Thresholds provided in Tables 4, 5 and 6 of the Method Statement

Monitoring During Operations Albania: Quarterly Greece: Bi-annually. Annually after the first 2 rounds of monitoring. Italy: Variable by Piezo as per EMP (Ref. 9)2:PRT and onshore Right of Way – PZ1, PZ3N (instead of PZ3 in EMP), Piezo10N(instead of PZ4 in EMP) and PZ5N (instead of PZ5 in EMP) - Annually during first 2 years of PRT operation– PZ2 - Annually during entire PRT lifecycle– PZ11 - Once after clearing of the PRT waste storage area– Microtunnel site Piezo 2, 3, 5, 7 and 8: Piezometer levels - quarterly for the first 2 years from the end of construction; chemical-physical parameters -every three months for the first 2 years from the commissioning date

Required: 4 locations



Required: 5 PZ at PRT/ROW

and 5 Piezos at Microtunnel site

DISCHARGES

Method Statement Wastewater Sampling (Ref. 15)

Thresholds provided in Tables 7, 8, 9 and 10 of the Method Statement

Stormwater network Quarterly Required: 5 points (Discharge outlets 1 and 2, oil separator 1 (batch

sample from separator 1.1 and

1.2), 2 and 3)

Required: 6 points (Discharge outlets 1, 2, 3, oil

separators 1, 2 and 3)

Required: 9 points (Discharge outlets 1, 2, 3, 4, 5, 6, oil separators 1

(batch sample from separator 1.1, 1.2 and 1.3), 2 and 3)

Required: 6 points (4 points in diversion system A, 2 points in diversion

system B)

2 Change to PZ locations for groundwater monitoring has been agreed with competent authorities






Operations ESMS Document Monitoring / Reporting Requirement

Frequency GREECE ALBANIA ITALY

GCS00 ACS02 ACS03 IPRT

No routine sampling at outlets of storage tanks emptied by vacuum tanks for disposal at a licensed 3rd party

Wastewater network Quarterly Required: 1 point (oil separator from Utility Building) No routine sampling

at sanitary wastewater storage

tank outlet

No routine sampling at sanitary

wastewater storage tank outlet

Required: 2 points (oil

separator from Utility Building,

wastewater treatment plant

outlet)

Required: 1 point (wastewater

treatment plant outlet)






3.7.1 Community Engagement

Community engagement shall be led by TAP Stakeholder Engagement function throughout the operations phase in accordance with TAP Stakeholder Engagement Procedure (Ref. 23). All complaints and grievances received by TAP AG or O&M Contractor(s) shall be managed in accordance with Grievance Management Procedure (Ref. 24).

3.7.2 Training and Awareness

TAP AG shall ensure that all TAP AG employees, with direct involvement and responsibility for activities relevant to TAP operations are adequately qualified and trained so that they have the knowledge and skills necessary to perform their work. Training on nuisance and pollution prevention awareness and minimisation shall be provided to all TAP AG personnel covering noise, dust, odour, pests, vermin and general housekeeping.

Different types and levels of training shall be delivered, covering general training, ESCH/H&S-related training, skills/task–specific training, toolbox talks and stakeholder engagement. Workers shall also be given training on safe and considerate driving practices and drivers of vehicles shall be trained in safe driving with respect to other drivers, pedestrians, cyclists, and livestock.

Appropriate training shall be provided to all TAP AG personnel that have the responsibility for conducting the monitoring detailed in Section 3.7. These training shall include any H&S risks and information about the personal protective equipment (PPE) that shall be worn. Specific instructions related the use of monitoring equipment and handling of samples shall also be provided in accordance with relevant Method Statements.

All training shall be provided in accordance with QHSE Training Procedure (Ref. 25).






4. Records

Record Document

Code/Number Generated

By Resp To

Store Storage Method

Location Storage Period

Prior to Disposition

Noise monitoring and equipment calibration records

In accordance with TAP corporate

procedures

TAP QHSE Officer

TAP QHSE Officer

Electronic / Hard copy

TAP Facility

In line with TAP Records

Retention Guidelines (Ref. 26)

Light monitoring and equipment calibration records


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



Groundwater monitoring and equipment calibration records


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



Wastewater monitoring and requirement calibration records


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



Environmental Inspection records


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



Community Engagement records


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



Pollution prevention training records


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



Records of non-compliance and follow up actions


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility



External reports to competent authorities


procedures

TAP QHSE Officer

TAP QHSE Officer


TAP Facility








5. Changes Since Last Revision

Summary of Changes (Brief) Section Page

Document revised throughout following TAP Legal and Lenders review

All All






6. List of Appendices

Appendix 1 - TAP Operations Activities, Products and Services List

Appendix 2 - Hazardous Material Inventory

Appendix 3 - Environmental Inspection Checklist






6.1 Appendix 1 TAP Operations Activities, Products and Services List

TAP OPERATIONS ACTIVITIES, PRODUCTS AND SERVICES LIST

No APS Category APS Description BAAR GREECE ALBANIA ITALY

TAP Office

GCS00 GCS01 BVSs Pipeline onshore

Admin Offices

Albania ACS02

Albania ACS03

BVSs Albania pipeline onshore

Albania pipeline offshore

Admin Offices

Italy PRT

Italy BVS

Italy pipeline onshore

Italy pipeline offshore

Italy Admin Offices

SAFETY, INTERGRITY AND EMERGENCY RESPONSE

1 Pressure Vessels (gas, air and air

cooling systems)

Operation of pressure vessels - gas system (e.g. gas coolers, main filters, fuel gas filters)

✓ N/A

✓ ✓ ✓

2 Operation of high-pressure pipeline onshore N/A ✓ ✓

✓

3 Operation of high-pressure pipeline offshore N/A

✓

✓

4 Turbo-compression system

Operation of gas turbines (and associated emissions and noise)

✓ N/A ✓ ✓

5 Operation of gas compression system ✓ N/A ✓ ✓

6 Emergency Shutdown System (EDS) ✓ N/A ✓ ✓ ✓

7 Alarm and Monitoring System

Gas Detection System ✓ N/A ✓ ✓ ✓

8 Fire Detection System ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

9 Audio Visual Alerting System

✓ N/A ✓ ✓ ✓

10 Leak detection system N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

11 Emergency Response

ER Plan including contact details of individuals close to facilities

✓ N/A ✓ ✓ ✓

12 Emergency Venting of station gas from station vent stacks

✓ N/A ✓ ✓

✓

13 Emergency Venting of pipeline gas from station and BV vent stacks

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

14 Emergency land access (i.e. non designated TAP / ROW / access road)

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

15 Operation of firefighting system - firewater system ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

16 Operation of firefighting system - fire extinguishers ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

17 Temporary import of emergency response equipment ✓ N/A ✓

✓ ✓ ✓

✓ ✓

18 Third party emergency response assistance ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

19 Emergency Pipeline repair and or laying temporary pipe

N/A

✓ ✓ ✓ ✓ ✓

21 Emergency response exercises (contact with communities, third parties etc)

✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

OPERATIONAL SYSTEMS

21 Operational Control System

Supervisory Control Centre (SCC) and backup SCC N/A

✓

22 Station Control System (SCS) ✓ N/A ✓ ✓ ✓

23 Local Control Centres (LCCs) ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓

24 SCADA ✓

N/A ✓ ✓ ✓ ✓

25 Telecommunications System

Passive Optical Network ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

26 Operation of radios ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

27 Operation of satellite phones ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

28 Operation of mobile phones ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

29 Separator, gas measurement and

plant valves

Operation of filter separators ✓ N/A ✓ ✓ ✓

30 Operation of plant valves ✓ N/A ✓ ✓ ✓

31 Operation of gas chromatographer / analyser ✓ N/A ✓ ✓ ✓

32 Operation of ultrasonic flow meters ✓ N/A ✓ ✓ ✓








TAP Office


Admin Offices

Albania ACS02

Albania ACS03



Admin Offices

Italy PRT

Italy BVS



Italy Admin Offices

33 Electrical and power supply System

Electrical power from grid ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

34 Gas generators (and associated emissions and noise)

N/A

✓

35 Emergency diesel generators (and associated emissions and noise)

✓ N/A ✓ ✓ ✓ ✓ ✓

36 Supply of excess power to grid N/A

✓

37 Battery UPS systems (BV's) N/A ✓

✓

✓

38 Medium voltage system (substation, transformers, switchgear, grounding and lighting protection etc.)

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

39 Overhead transmission lines ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

40 Fuel and gas supply system

Operation of filtering system ✓ N/A ✓ ✓ ✓

41 Operation of heating system ✓ N/A ✓ ✓ ✓

42 Operation of metering systems ✓ N/A ✓ ✓ ✓

43 Operation of regulation and control system ✓ N/A ✓ ✓ ✓

44 Vent system Blowdown of process lines to affect repairs (Operational venting)

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

45 Operational Venting (from local vents) ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

46 Fugitive Emissions (from turbine gas seals, valve stems, etc)

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

47 Operational venting during pigging ✓ N/A

✓ ✓

✓

48 Cathodic Protection System

Passive cathodic protection N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

49 Active cathodic protection N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

50 Utilities Consumption of electricity (energy efficiency) ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

51 Consumption of water ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

52 Operation of pressure vessels - air system (e.g. instrument and control systems air supply)

✓ N/A

✓ ✓

✓

53 Operation of hot water boilers ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

54 Operation of sewage treatment system ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

55 Operation of potable water system ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

56 Groundwater extraction N/A

✓

57 Use of nitrogen (including introduction during commissioning)

N/A

58 "Operation" of Crossings

Railway crossings N/A ✓ ✓

59 Road crossings N/A ✓ ✓ ✓

60 Watercourse crossings N/A ✓ ✓

61 Crossings of third-party services (electricity, gas, water) N/A ✓ ✓ ✓

62 Crossings of third-party marine infrastructure N/A ✓ ✓

63 Storage and Transportation of

chemicals

Receipt, filling of tanks, storage and use of diesel ✓ N/A ✓ ✓ ✓

64 Receipt, Storage and use of oil and lubricants (in transformers, turbines, generators etc)

✓ N/A ✓ ✓ ✓

65 Storage and transportation of condensate ✓ N/A ✓ ✓ ✓

66 Storage, transportation and disposal of wastes

Storage of hazardous waste ✓ N/A ✓ ✓ ✓

67 Storage of non-hazardous waste ✓ N/A ✓ ✓ ✓

68 Transportation and disposal of hazardous wastes ✓ N/A ✓ ✓ ✓








TAP Office


Admin Offices

Albania ACS02

Albania ACS03



Admin Offices

Italy PRT

Italy BVS



Italy Admin Offices

69 Transportation and disposal of non-hazardous wastes ✓ N/A ✓ ✓ ✓

70 Discharge of treated sewage to ground N/A ✓

71 Discharge of treated sewage to surface water N/A ✓ ✓

72 Transportation and disposal of untreated sewage to municipal facility

✓ N/A

73 Treatment and discharge of potentially contaminated with oil

✓ N/A ✓ ✓ ✓

74 Transportation and disposal of untreated process wastewater

✓ N/A ✓ ✓ ✓

75 Treatment and discharge of stormwater to surface water ✓ N/A ✓ ✓ ✓

76 Discharge of untreated water exceeding first flush treatment system capability

N/A ✓

77 Administration Administrative Buildings ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

78 Operation of onsite first aid room ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

79 Operation of office kitchen facility ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

80 Facilities Inspection and Maintenance

Mechanical maintenance of plant and equipment at pre-determined intervals

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

81 Functional operations checks and verification of plant and equipment

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

82 Repairs as necessary ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

83 Instrument calibration ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

84 Work at height maintenance ✓ N/A

✓ ✓

✓

85 Electrical maintenance ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓

✓ ✓ ✓

86 Over-board maintenance

N/A ✓ ✓

87 Tank cleaning (hazardous sludge removal) - Diesel tanks ✓ N/A ✓ ✓ ✓

88 Pig launching and receiving for internal pipeline inspection

✓ N/A ✓ ✓ ✓

89 Import / export of pigs through the pipeline

N/A ✓ ✓ ✓ ✓ ✓

90 Building maintenance ✓ N/A

✓ ✓ ✓

91 Maintenance of HVAC system ✓ N/A

✓ ✓ ✓

92 Non-destructive testing

N/A ✓ ✓ ✓ ✓ ✓

93 Inspection and maintenance analysis (vibration analysis, oil analysis, borescope inspection, pressure tests, thermography)

✓ N/A ✓ ✓ ✓

94 Pipeline Surveys and Routine Maintenance

Environmental emissions, noise and discharge monitoring

✓ N/A ✓ ✓ ✓

95 Helicopter Operations ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

96 Satellite Monitoring (photos) ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

97 Drone Monitoring (photos, video) ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

98 ROV surveys offshore N/A ✓ ✓

99 Other (non ROV) boat supported surveys (diving etc) N/A ✓ ✓

100 Vantage point monitoring / vehicle monitoring using defined access roads

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

101 ROW Monitoring on-foot

N/A ✓ ✓ ✓ ✓

✓ ✓

102 ROW Monitoring of restriction zones (A, B and C) ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

103 ROW depth/loss of cover survey N/A

✓

✓ ✓

104 ROW geohazard survey N/A ✓ ✓ ✓ ✓

✓ ✓








TAP Office


Admin Offices

Albania ACS02

Albania ACS03



Admin Offices

Italy PRT

Italy BVS



Italy Admin Offices

105 Leak surveys N/A ✓ ✓ ✓ ✓ ✓

✓ ✓ ✓

106 ROW and marker maintenance (excavations, river crossings, access roads, erosion protection, etc.)

N/A ✓ ✓ ✓ ✓ ✓ ✓

107 Work in rivers maintenance N/A ✓ ✓

108 Safety and Health Systems

Electronic Permit to work and People on Board System (POB)

✓ N/A ✓ ✓ ✓

109 Use of Electronic signatures in PTW and other Electronic Systems

✓ N/A ✓ ✓ ✓

110 Competency Management System (i.e. holding data on contractors’ staff etc.)

✓ N/A ✓ ✓ ✓

111 HSE Assessments of Contractors ✓ N/A ✓ ✓ ✓

112 In Vehicle Monitoring System (IVMS) Use ✓ ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

113 Security and Community Liaison

Patrolling by technicians and security staff ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

114 Operation of CCTV System ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

115 Security Lighting ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

116 Patrol by Community Watchmen ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓

117 Operational Workforce

Work Permits for foreign employees ✓ N/A ✓ ✓ ✓

118 Occupational health monitoring of workforce (fitness for work)

✓ N/A ✓ ✓ ✓

119 Transportation of workforce to/from worksites (dedicated vehicles, offshore training)

✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓






6.2 Appendix 2 Hazardous Material Inventory

TAP Facility / Worksite:______________________________________ Date: ____________________________________________________

Hazardous Material Name Key Hazard Quantity / Volume Stored on Site

Storage Area Location MSDS available and displayed (Yes / No)






6.3 Appendix 3: Environmental Inspection Checklist3

Environmental Inspection

General Project Location: Date of Inspection:

Specific Sites Assessed: Date of Report:

TAP AG Reps: Weather Conditions:

Area of Inspection

Applies? Assessment

Corrective action A

pplic

able

Not

applic

able

Non-C

om

plia

nt

50%

Com

plia

nt

75%

Com

plia

nt

100%

Com

plia

nt

Resource Management

All water sources and extraction locations used have been granted relevant permit by competent authorities with the GPS coordinates and the maximum water volumes allowed from each source.

Standing water (ponds, lakes, etc.) are not be used to extract water from or to discharge used water/effluents into.

Discharging waters occur in a way that minimise physical impacts to channel morphology, no additives have been added to discharged water. Discharges have not been made without prior agreement and appropriate consents and approvals from the authorities and surface runoff is being managed.

Subtotal for Resource Management

Pollution Prevention

Dust suppression measures (water carts, loads covered, geo-textile stockpiles suspend earth works, dust extraction, paving/soil binders other measures as applicable) are in place where required to minimise dust impacts

RoW access roads are clear of dust and spoil or measures are in place to minimise impact (e.g. street sweepers, brushing roads down).

Equipment and vehicles are regularly maintained and are operated to minimise emissions. Black smoke emitting vehicles are removed for maintenance.

Mobile plant is maintained in good working order (and operated so vehicles are not left standing idle in residential areas and stationary plant is integral bunded (110% capacity) or provided with drip trays.

3 Subtotals and totals are calculated automatically in the excel version of the checklist.




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Area of Inspection

Applies? Assessment

Corrective action

Applic

able

Not

applic

able

Non-C

om

plia

nt

50%

Com

plia

nt

75%

Com

plia

nt

100%

Com

plia

nt

Fuel storage areas are adequately bunded (110%), and are not within 100m of a major watercourse, within a floodplain, or where there is the potential for spilled fuel to enter groundwater.

Noise monitoring has been undertaken where required

Appropriate controls (barriers or site layout, low nuisance (noise) equipment, noise abatement equipment such as dampers, effective silencer on their air exhaust port of pneumatic tools, less noisy movement/reversing warning systems).

No evidence of project related discharges (effluent, washing of plant, clothing and vehicles) in watercourses have occurred

Secondary containment systems (e.g. maintenance areas, waste storage yard, hazardous liquid waste storage areas and oil/chemical storage areas) are maintained and generally free from spills / rainwater build up and are functioning effectively.

Vehicles and equipment are being washed off-site in an appropriately licensed public wash bay

Are measures in place to restrict visual impact to sensitive receptors (e.g. topsoil stockpiles, minimising time period, screens, fencing and hoarding to limit visual impact) where required

Lights are being shrouded/directed with the aim of reducing off-site light spill at the construction sites, camp and pipe storage areas and limited at night and dawn.

Fuels and chemicals are loaded on hard standing (e.g. concrete) or on an impermeable material and fully kerbed/bunded to collect spills.

Chemical containers are clearly labelled and MSDS available.

Personnel and supervisors are aware of pollution prevention, good practice (e.g. funnels, drip trays, fuel nozzles with automatic shut-off refuelling guns on dispensers, operator attendance, minimising storage volumes, general spill response, refuelling procedure and incident notification requirements).

Confirming mobile fuel tankers are double walled.









Area of Inspection

Applies? Assessment

Corrective action

Applic

able

Not

applic

able

Non-C

om

plia

nt

50%

Com

plia

nt

75%

Com

plia

nt

100%

Com

plia

nt

Spill kits on site (including mobile equipment) and fully stocked. Trained spill response team on stand-by as required.

Drain valves shall be locked off to prevent incidental or unauthorised releases.

Subtotal for Pollution Prevention

Ecological Management

Staff have been appropriately trained in the importance of identification and preservation of wild fauna and identifying worksite boundaries.

Has Post Construction Surveys of terrestrial ecology been developed to ensure the satisfactory implementation of proposed mitigation measures, and identify any changes that occur over the construction period

Have signs been placed in areas identified as environmentally sensitive areas

Site staff aware of rule for No hunting, fishing, unauthorised gathering of products (including plants and cultural heritage artefacts), burning and the introduction foreign/non-naturalised vegetation to the worksites

No evidence of invasive species into native habitats or the use or release Genetically Modified Organisms (GMOs) into the surrounding environment.

Subtotal for Ecological Management

Spill Preparedness and Response

A map has been developed and maintained indicating all chemical/ lubricant/fuel storage locations, volumes stored, and spill kit locations

The number, location and content of spill kits is adequate for worksite needs

A schedule of emergency response exercises and ensures that it is implemented

Has an Emergency Response Plan been developed to address potential spills?









Area of Inspection

Applies? Assessment

Corrective action

Applic

able

Not

applic

able

Non-C

om

plia

nt

50%

Com

plia

nt

75%

Com

plia

nt

100%

Com

plia

nt

All contaminated soil has been cleaned up or removed for appropriate disposal, with all wastes being handled, stored and disposed of as per local regulations and international best practice and removed by licensed waste contractor.

Subtotal for Spill Preparedness and Response

INSPECTION TOTAL:

Action Items / Notes Agreed Close Out

Date Actual Close

out Date

ID Action Items (from this inspection)

ID Overdue Actions from previous inspection (agreed close out dates not met)

ID Completed Actions (record only once)









Area of Inspection

Applies? Assessment

Corrective action

Applic

able

Not

applic

able

Non-C

om

plia

nt

50%

Com

plia

nt

75%

Com

plia

nt

100%

Com

plia

nt

Photographs

PHOTO 1: PHOTO 2:

PHOTO 3: PHOTO 4:

Pollution Prevention Procedure - Trans Adriatic Pipeline

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