Plan to Control Chemicals Hazards

Revision notes
(Applicable from Rev.01 of the document)

Revision Revision date MoC number Modification Reason

Indicate: Number Indicate the date of If applicable, Indicate the paragraph number where the change Describe the reason
of the document the change indicate the MOC took place and the new paragraph number in case for the changes
revision number something new is added.
01 11.Sep.2014 N/A Section 1.0: Change in terminology of Management Annual revision. All
System. sections reviewed
Section 2.0: Introduced IMS terminology and and updated.
changes ESHS for HSE.
Section 3.1: New responsibilities for Contractors,
Procurement Department, QHSE Department
and Security added.
Section 3.2: Drip tray and Job safety analysis
definitions included.
Section 4.1: New considerations for new chemicals.
Section 4.1.1: Changes in wording.
Section 4.3: Second consideration changed. Final
consideration included.
Section 4.4: Change in section title, ESHS for HSE.
Section 4.5.1: Change in wording. Include form
name related to this section.
Section 4.5.3: New considerations for chemical
deliveries and requirements for entering Process
Area.
Section 4.6.5: Included section reference in fourth
bullet.
Section 4.7.1: Considerations change for transfer
and use inside Operations.
Section 4.10: References included.
Section 4.11: References included.
Section 5.0: List updated.
Appendix B: new apprendix.

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 Plan to Control Chemicals Hazards

Table of Contents
1.0 Purpose................................................................................................................................ 4
2.0 Scope ................................................................................................................................... 4
3.0 Responsibilities and Glossary ........................................................................................... 4
3.1 Responsibilities................................................................................................................... 4
3.2 Glossary............................................................................................................................... 4
4.0 Tasks .................................................................................................................................... 5
4.1 Procurement of New Chemicals ......................................................................................... 5
4.1.1 Contractors.................................................................................................................... 6
4.2 Inventory of Hazardous Materials & Chemicals ................................................................ 6
4.3 Material Safety Data Sheets................................................................................................ 6
4.4 Employee ESHS Training.................................................................................................... 6
4.4.1 Initial and Periodic Training ......................................................................................... 6
4.5 Transportation and Delivery to PERU LNG S.R.L. ............................................................ 6
4.5.1 Routine Operations ....................................................................................................... 6
4.5.2 Refrigerants ................................................................................................................... 7
4.5.3 Receiving Chemicals at PERU LNG ............................................................................. 7
4.6 Chemical and Hazardous Material Storage ....................................................................... 7
4.6.1 General Practices .......................................................................................................... 7
4.6.2 Labeling ......................................................................................................................... 8
4.6.3 Storage Facilities .......................................................................................................... 8
4.6.4 Refrigerant Storage ....................................................................................................... 9
4.6.5 Temporary Storage ....................................................................................................... 9
4.7 In Plant Transfer and Use of Hazardous Materials............................................................ 9
4.7.1 Operations ..................................................................................................................... 9
4.8 Maintenance Activities ...................................................................................................... 10
4.9 Refueling............................................................................................................................ 10
4.10 Disposal ......................................................................................................................... 10
4.11 Emergency Response and Incident Investigation....................................................... 10
5.0 References ......................................................................................................................... 11
APPENDIX A: Hazardous Material Labels ................................................................................... 12

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 Plan to Control Chemicals Hazards

1.0 Purpose
The Plan to Control Chemical Hazards is a key part of PERU LNGs Integrated Management
System (IMS). The objectives of the plan are to implement the risk controls required to assure the
health and safety of PERU LNG employees, visitors, and community members as well as the
protection of the environment from chemical hazards. The plan includes information for the
procurement of a new chemical, the risk assessment and authorization, the training for the
employees who will handle or be exposed to the chemical, the transportation of the chemical,
storage, disposal and, in case of a release or spill, the emergency response and Incident
Investigation.

2.0 Scope
The Plan covers a broad range of chemical risks identified for PERU LNG facilities and covers both
plant and pipeline operations. Chemical is a generic term that applies to a wide spectrum of
materials utilized in operations, maintenance, and services including process materials, lubricants,
fuels, coatings, catalysts, degreasers, and even water may fall under the term chemical. Each
substance must be evaluated to assure that the IMS is not compromised and that all HSE
obligations are met. It covers all chemicals, natural and manufactured, and the full range of
exposure situations of the employees and the operating environments of the plant, pipeline, and
marine terminal. The controls in this plan work in conjunction with other risk control plans and
procedures to assure that there are no negative impacts to operations, communities, or the
environment. Contractors are a potential source of non-compliance with HSE commitments and
must demonstrate how they will comply with the requirements in this document.

3.0 Responsibilities and Glossary

3.1 Responsibilities
The following responsibilities have been defined in this procedure:

Contractors Have MSDSs available to all their employees.

Receiving and Issuing Keeping the MSDS Master list complete and up to date. Ensure
clerk all chemicals purchased have their MSDS.
Maintain MMS Inventory and MSDS Master List updated.
Ensure all chemicals purchased come with their corresponding
Procurement Department
MSDS.
Maintain a dual language MSDS system (whenever possible).
QHSE Department Perform random inspections to vehicles transporting hazardous
materials.
Review MSDS of new chemicals.
Check all transportation requirements are met before cargo
Security
enters the plant facilities.

3.2 Glossary
The following describes terms used in this procedure.

Chemical Anything made of matter is therefore a chemical. Any liquid,

solid, gas. Any pure substance; any mixture, even water is a
chemical. See Section 2.0 Scope
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 Plan to Control Chemicals Hazards

Container A receptacle that houses a chemical or material (i.e. cylinder,

drum, reactor, or vessel.) This does not include piping systems,
engines, and vehicle fuel tanks.
Containment A device or structure designed to limit the dispersion of a
material to the surrounding environment.
Drip tray Secondary containment used as a second line of defense for
preventing, controlling or mitigating major hazardous events with
chemicals.
Hazardous Material or Any material that poses a threat to people's health, safety,
HAZMAT or Hazardous property, public welfare or the environment. These terms may
Chemical or Hazardous have specific regulatory definitions but are interchangeable when
Substance used by lay persons or employees. They often refer to a specific
hazard such as explosive, compressed gases, flammable gases,
flammable liquids, and flammable solids, oxidizing substances,
toxic materials, radioactive materials or corrosive substances.
Hazardous Wastes Hazardous wastes are generated when a hazardous material is
no longer usable for its original purpose.
Job Safety Analysis Process where hazards associated with each step of a job are
identified and control measures are put in place to minimize the
risk to personnel, property and environment.
Label Written or graphic materials displayed on or affixed to a container
of hazardous materials.
MMS Inventory Materials Management System SAP inventory, by Procurement
MSDS Material Safety Data Sheet is a document containing health,
safety and environmental data related to hazardous materials
and chemicals
New chemical Any hazardous chemical to be introduced to the site, which at the
time of its introduction is not listed on the Plant MMS Inventory
and for which a Chemical Risk Assessment, including a
manufacturer-specific Material Safety Data Sheet has not been
carried out and authorized. Any existing chemical that is
reformulated will be considered a New Chemical.
PPE Personal protective equipment
UN Numbers UN IDs are four-digit numbers that identify hazardous
substances, and articles (such as explosives, flammable liquids,
toxic substances, etc.)

4.0 Tasks
4.1 Procurement of New Chemicals
The acquisition of all new chemicals and potentially hazardous materials will be
undertaken through the PERU LNG Procurement Department.
Procurement Department shall notify the QHSE Department when new chemicals are
being purchased and sent a copy of the MSDS for its review.
Procurement Department will maintain the official PERU LNG MMS Inventory and
MSDS Master List updated and will ensure that all chemicals purchased come with their
MSDS.

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 Plan to Control Chemicals Hazards

4.1.1 Contractors

Contractors purchasing on behalf of the PERU LNG Procurement Department must

follow the new chemical authorization process through their contract administrator.
Contractors storing or disposing of chemical substances at or for PERU LNG facilities
must provide the QHSE Department with a complete list of such materials including dual
language (English and Spanish) MSDSs.
Any chemical or substance which compromises the PERU LNG IMS will be prohibited.
Any contractor new chemical must undergo a risk assessment, as defined in Section
4.2.
Contractors must be responsible for having MSDSs available to all their employees
when using any chemical.

4.2 Inventory of Hazardous Materials & Chemicals

PERU LNG Procurement Department will maintain an inventory of hazardous chemicals
known to be present within each Unit/Area (Operations, Maintenance, Laboratory, etc.).
This is part of the MMS inventory.
The inventory will be updated as new chemicals are introduced, or discontinued, and
hazard rating changes.

4.3 Material Safety Data Sheets

The Procurement Department will maintain a dual language (English and Spanish),
whenever possible, MSDS Master List, accessible to all employees, which can be
accessed through the Protect & Prevent Portal.
Medical clinic shall have access to the MSDS Master List.
All personnel performing chemical handling activities will have access to the required
MSDS information. The MSDS of each product used will be kept in the work areas
and/or temporary storage.
Contractors must be responsible for having MSDSs available to employees when using
any chemical.
Each time a MSDS is updated, the Procurement Department shall update physical
copies of them at the central chemical storage and communicate the affected
departments and the QHSE Department to ensure the hard copies maintained on the
field are also updated.

4.4 Employee HSE Training

4.4.1 Initial and Periodic Training

All employees receive training in accord with Element #6 of the IMS. Chemical and hazardous
materials training is included as part of new hire induction programs. Annual refresher training and
specialty courses such as HazCom will be provided as needed.

4.5 Transportation and Delivery to PERU LNG S.R.L.

4.5.1 Routine Operations

The majority of all materials received by PERU LNG facilities are delivered routinely by industrial
vendors and suppliers operating according to Peruvian national regulations and without the need for
additional HSE requirements. Vehicles delivering certain hazardous materials or outside of normal

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 Plan to Control Chemicals Hazards

operations are subject to additional risk controls as outlined below. Random vehicles transporting
hazardous materials will be inspected by the QHSE Department using a checklist for inspection of
hazardous materials vehicles SAF-000-FOR-0004 Checklist de Inspeccin a Transportistas de
Materiales Peligrosos.

4.5.2 Refrigerants

Refrigerants including propane and ethylene will be transported on specialized trucks to the plant by
qualified third parties. The ethylene for refrigerant make-up will be shipped to Peru using routine
container-type liner services into commercial ports and transported to the LNG plant facilities by
truck via the Pan American Highway in ISO vacuum-insulated containers under limited pressure to
maintain the ethylene in a liquid state. Propane refrigerant make-up will be trucked in from Pisco or
Callao. Transportation of these chemical consumables will comply with best national practices and:

Meet all Relevant Peruvian regulations including Supreme Decree No. 021-2008-MTC,
covering hazardous cargo signage or placarding and manifesting and PERU LNG
Transport Guide which addresses, travel time, routes, vehicle speeds, restrictions and
other risk control measures.
The shipper shall assure that all drivers have received adequate training and any
needed certifications.
The shipper shall assure that vehicles that deliver or receive Hazmat shall have the
proper permits, certificates and placards in the transport vehicle.
Hazmat and chemicals must be shipped in proper containers in good condition.
The shipper shall be capable for responding to spills of Hazmat and Chemicals.
The shipper has proper spill containment and emergency response material in the
transport vehicle.
Bills of lading and manifests will be kept for a period of 3 years.
Shipping practices conform to US DOT, UN, lATA or IMO guidelines as appropriate and
with IFC Hazardous Materials Management guides.

Contract haulers transporting hazardous materials will be initially and periodically audited by PERU
LNG to verify that transport vehicles and methods meet the requirements of this document.

4.5.3 Receiving Chemicals at PERU LNG

The transportation units will only enter the site if all Security requirements are met. Upon arrival to
the Warehouse, there will be a visual inspection of the products to assess their condition, following
Procurement procedure. When delivery containers are not in good condition, a report will be
generated and may be returned to the supplier. For propane, ethylene, liquid nitrogen and carbon
dioxide, diesel and gasoline deliveries, Operations will be in charge for the container inspections,
following SOPs. In case any of the transportation units need to access the Process Area inside the
Plant facilities, driver(s) shall use all the required PPE.
For contractors bringing hazardous materials to the plant facilities, Security will do a visual
inspection of the cargo to verify it is correctly labeled, secured, with secondary containment and
without leaks. If these conditions are not met, the contract administrator and QHSE Department
should be contacted.

4.6 Chemical and Hazardous Material Storage

4.6.1 General Practices

As a general good practice, the minimum required quantities of hazardous chemicals should be
stored on the Plant site. Incompatible hazardous materials will be segregated. Specifically, the

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 Plan to Control Chemicals Hazards

following will always be handled and stored separately:

Acid and bases

Acids and metals
Oxidizing agents and organics solvents
Reducing agents and organic solvents, and
Water reactive materials and other substances

The condition of chemical storage drums, bunds and drip trays will be visually assessed periodically
to ensure that they are in good condition, free from rust, dents and penetrations that could
compromise integrity. Containers will also be checked to ensure that lids are secured in place when
not in use. On a regular basis, HSE inspections shall also assess the integrity of containment
systems and product storage containers.

4.6.2 Labeling

All storage containers will be appropriately labeled according to Peruvian national regulations before
being stored, used, released, or transported for use. Labels must indicate the following information:

Name of the chemical

Hazard information (NFPA diamond, UN number, hazard class, etc.)

QHSE department will provide labels (Appendix A) if required. The information to complete these
labels will come from the MSDS; fields with information missing from the MSDS shall be crossed out
in the label.

4.6.3 Storage Facilities

The PERU LNG Plant facility has purpose built central storage areas for all bulk storage of
chemicals and hazardous materials, these areas must have:

Clearly visible signs with NFPA and internationally recognized symbols describing the
PPE requirements for personnel entering the storage area and the nature of the
hazardous materials stored (e.g., flammable, corrosive)
Perimeter security fence to prevent unauthorized access.
The storage area is protected from impact by vehicles from the plant facilities;
Satellite hazardous material storage is contained in drip trays, bunds or drum containers
capable of 110% containment;
Location and design analysis to prevent contamination of surface waters or open drains.
Impermeable bund capable of retaining 110% of largest vessel volume in the event of a
spill, or where more than 1,000 liters are stored, capable of retaining 25% of the
combined tank volume;
Material and construction compatible with the properties of the materials to be stored
and storage conditions (e.g., pressure and temperature);
Storage areas not connected to wastewater / storm water collection system (i.e. sloped
to isolated sump)
Spill kits suitable for the material and volume being stored shall be located adjacent to
storage areas.
Have the MSDSs available of all the stored chemicals.
Fire extinguisher with UL certification system.
Eye wash where liquid chemicals are stored.

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 Plan to Control Chemicals Hazards

4.6.4 Refrigerant Storage

The ethylene and propane storage bullets are located dedicated refrigerant storage and loading
areas. The storage bullets have full spill containment systems with leak detection and fire
suppression systems. Both the ethylene and propane bullets will have pressure control valves to
relieve excess pressure to the dry flare system to prevent overfilling of the bullets. Each bullet also
has redundant pressure safety relief valves that relieve to the dry flare system for individual bullet
protection.

4.6.5 Temporary Storage

Temporary storage facilities may be required as part of normal business operations. The storage
area must comply at least with the following considerations:

Demarcated area.
Secondary containment systems such as drip trays, bunds or drum pallets capable of
110% containment;
Location should prevent contamination of surface waters or open drains.
Keep updated MSDS available of the stored chemicals. See section 4.3.
Spill kits suitable for the material and volume being stored shall be located adjacent to
storage areas.
Fire extinguisher with UL certification.

4.7 In Plant Transfer and Use of Hazardous Materials

4.7.1 Operations

1. Standard Operating Procedures (SOP) have been developed for all routine process
operations and operators are trained in normal and abnormal conditions as part of their
training on each plant system. SOPs govern material handling during process
operations and include a safety review section. Routine activities such as propane,
ethylene, gasoline, diesel or liquid nitrogen transfer shall have written transfer
procedures.
2. Personnel shall not handle, work with or use any hazardous chemicals if the worker
does not have adequate training or if the material has not been properly labeled.
3. No personnel shall go near the Reverse Osmosis Unit without wearing the additional
PPE as per chemicals MSDS.
4. Personnel are trained in the PERU LNG Emergency Response and Spill Control Plans.
5. The PERU LNG Medical Unit shall develop and establish medical protocols for
emergency situations resulting from accidents caused by hazardous materials.
6. Additionally, periodic inspections of all storage areas, fittings and tank contents are
undertaken as part of routine plant operations and HSE inspections..
7. The design of operating facilities includes passive safeguards designed to minimize the
potential for hazardous materials incidents. These design elements include:
a. Use of transfer equipment that is compatible and suitable for the characteristics of
the materials transferred and designed to ensure safe transfer;
b. Installation of gauges on tanks to measure volume inside;
c. Use of drip-less hose connections for vehicle tank and fixed connections with
storage tanks;
d. Provision of automatic fill shut-off valves on storage tanks to prevent overfilling;
e. Use of a catch basin around the fill pipe to collect spills;
f. Use of piping connections with automatic overfill protection (float valve);
g. Provision of overfill or over pressure vents that allow controlled release to a
capture point;
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 Plan to Control Chemicals Hazards

h. Regular inspection, maintenance and repair of fittings, pipes and hoses;

i. Provision of secondary containment, drip trays or other overflow and drip
containment measures, for hazardous materials containers at connection points or
other possible overflow points.

8. Where it is not practical to provide permanent, dedicated containment structures for

transfer operations, one or more alternative forms of spill containment should be
provided, such as portable drain covers (which can be deployed for the duration of the
operations), automatic shut-off valves on storm water basins, or shut off valves in
drainage or sewer facilities, combined with oil-water separators.

4.8 Maintenance Activities

When chemicals and hazardous materials are mobilized to the work front to perform maintenance,
additional protection measures shall be undertaken. Measures for handling the material shall
include the following:
a. Materials will be signed out of the designated storage facility only by trained
personnel
b. MSDS will be transferred with the product
c. Hazardous materials transport on site will ensure that materials transferred in
sealed and labeled containers with loads secured to the point of deployment
d. Handling operations will be conducted by personnel instructed in the handling of
the hazardous substance, including the use of PPE, and will take place on an
impermeable surface;
e. Return of the unused material in the original sealed container to the designated
storage site, or sending of chemical containers to the central hazardous waste
area in accordance with the Waste Management Procedures.

4.9 Refueling
The following refueling procedures apply to fuel transfer at the plant:
1. Refueling activities will only be permitted in designated areas by trained staff.
2. Checks of fill hoses, valves and nozzles for signs of wear and tear prior to operation.
3. Checks of tank levels prior to delivery to prevent overfilling.
4. Locating fill pipes within the bund (unless shut-off valves are fitted), and;
5. Ensuring a spill response kit is available at re-fuelling points for use in dealing with minor
spills

4.10 Disposal
While the generation of hazardous waste will be minimized through careful selection and
minimization of chemicals, hazardous waste will be generated when a hazardous material is no
longer usable for its original purpose. Waste management is a significant element of the IMS and is
part of the Environmental Risk Control plans. Hazardous waste management, including disposal, is
covered under the ENV-000-PRO-0005 Plant Waste Management Procedure and ENV-000-PRO-
0006 Pipeline Waste and Effluents Management Procedure. All chemical waste containers must be
identified with the labels provided by the QHSE Department (Appendix B).

4.11 Emergency Response and Incident Investigation

PERU LNGs emergency response plan addresses all foreseeable emergencies including spills and
releases of hazardous materials. The Emergency Response Plans provides specific guidelines for
hazardous material incidents. The MAR-000-PLN-0001S Respuesta a Derrames de Hidrocarburos

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 Plan to Control Chemicals Hazards

en el Mar, is a subset of the Emergency Response Plan. Emergencies and incidents shall be
investigated and corrective actions assigned and tracked through the HSE-000-PRO-0009 Incident
Investigation Procedure. Analysis will also be undertaken to determine trends, including those
associated with hazardous materials and chemical management.

5.0 References
ENV-000-PRO-0005
ENV-000-PRO-0006
HSE-000-PLN-0010
HSE-000-PRO-0009
MAR-000-PLN-0001S
SAF-000-FOR-0004S
NFPA 704
Plant Waste Management Procedure
Pipeline Waste and Effluents Management Procedure
Plant and Pipeline Emergency Response Plan
Incident Investigation Procedure
Respuesta a Derrames de Hidrocarburos en el Mar
Checklist de Inspeccin para transportistas de Materiales
Peligrosos
Standard System for the identification of the hazards of materials
for emergency response
MSDS Master List

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APPENDIX A: Hazardous Material Labels

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APPENDIX B: Hazardous Waste Labels

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