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Primary contact: Sharif, Amer Abdul Raouf on 966-3-8746430

CopyrightSaudi Aramco 2009. All rights reserved.

Engineering Procedure
SAEP-32 28 J une 2009
Environmental Performance Assessment (EPA) Program
Environmental Standards Committee Members
Hejazi, Ramzi Fouad, Chairman
Abdulkader, Khaled Abdullah, Vice Chairman
Ayoubi, Ensan Mahmoud
Barrie, David George
Carne, Malcolm
Conner, William Glenn
Harbi, Nassir Thaali
Kadhim, Mohammad Hassan
Khalaf, Adli Shafik
Kunnummal, Noushad
Mulhim, Khalid Abdul Aziz
Nassar, Rafat Mohammad
Qahtani, Saleh Yahya
Reed Jr., Philip Edward
Rehm, Thomas E.










Saudi Aramco DeskTop Standards

Table of Contents

1 Scope............................................................. 2
2 Applicable Documents.................................... 2
3 Terms and Definitions..................................... 4
4 Program Objectives........................................ 4
5 Instructions..................................................... 5
6 Responsibilities............................................ 11

Appendix A Overview of Typical
Survey Activities................................... 14
Appendix B Minor Findings Close Out Form... 15



Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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1 Scope
This SAEP describes the procedures for the administration and implementation of the
Environmental Performance Assessment (EPA) Program. The purpose of this program
is to conduct periodic facility surveys to determine compliance with Saudi Aramco's
environmental requirements, as well as related Saudi government requirements.
2 Applicable Documents
All EPA surveys shall evaluate proponents compliance with the applicable documents
listed in this section.
2.1 Saudi Aramco References
Saudi Aramco Policy Statement
SAPS No. INT-5 Environmental Protection Policy
Saudi Aramco General Instructions
GI-0002.714 Environmental Protection Policy Implementation
GI-0002.717 Procedures and Guidelines for Handling
Polychlorinated Biphenyls (PCBs)
GI-0151.006 Implementing the Saudi Aramco Sanitary Code
GI-0425.000 Management of CFC & HCFC Refrigerants
GI-0430.001 Waste Management General Instruction
GI-0002.104 Leak and Spill Reporting
GI-0002.400 Offshore Oil Spill Contingency Plan
GI-0002.401 Inland Oil Spill Response
GI-0006.004 Near Miss Reporting Process
Saudi Aramco Engineering Standards
SAES-A-007 Hydrostatic Testing Fluids and Lay-Up
Procedures
SAES-A-102 Air Pollutant Emission Source Control
SAES-A-103 Discharges to the Marine Environment
SAES-A-104 Wastewater Treatment, Reuse and Disposal
SAES-A-111 Borrow Pit Requirements
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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SAES-A-115 Groundwater Monitoring Well Design,
Installation, and Decommissioning
SAES-B-005 Spacing and Diking for Atmospheric and Low-
Pressure Tanks
SAES-D-116 Underground Storage Tank System
SAES-O-101 Standard Security Fence - Category I
SAES-O-102 Category II Fence
SAES-O-103 Category III Fence
SAES-S-007 Solid Waste Landfill Standard
SAES-S-010 Sanitary Sewers
SAES-S-020 Industrial Drainage and Sewers
SAES-S-030 Storm Water Drainage Systems
Saudi Aramco Engineering Procedures
SAEP-302 Instructions for Obtaining a Waiver of a
Mandatory Saudi Aramco Engineering
Requirement
SAEP-327 Disposal of wastewater from cleaning, Flusing,
and Dewatering Pipelines and Vessels
SAEP-339 Marine dredging and Landfilling Approval and
Permiting
SAEP-340 Air Quality Impact Analysis & Assessment
SAEP-1661 Waste Minimization Opportunity Assessments
Saudi Aramco Forms and Data Sheets
SAP EHS (PRC-WAM03) Waste Manifest
GI-6.004 (Supplement 1) Near Miss Report Form
SA 8037 Land Use Permit
SA 3140 Marine Accident Report
2.2 Government Requirements
General Standards Environmental Protection Standards in the
Document No. 1409-01 Kingdom of Saudi Arabia - Presidency for
& Revisions Meteorology and the Environment (PME)
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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PME National Plan to Combat Pollution from Oil and
Other Harmful Substances in Emergency
Situations
ROPME Protocol Concerning Marine Pollution Resulting
from Exploration and Exploitation of the
Continental Shelf
Royal Commission for Royal Commission Environmental Regulations,
Jubail and Yanbu Volume I & Volome II, 2004
Royal Decree No. M/9 Regulations for Fishing, Exploitation and
Protection of Marine Life in Saudi Territorial
Waters, November 18, 1987
2.3 Other Requirements
MANUAL-MOTHBALL Saudi Aramco Mothball Manual
3 Terms and Definitions
EPA: Environmental Performance Assessment
EED: Environmental Engineering Division
EH&S: Environmental, Health & Safety
EPD: Environmental Protection Department
Finding: Results of the evaluation that are not in compliance with policies, procedures
or requirements.
SAP: It is a company that provides business database software, solutions, applications
& Services used by Saudi Aramco in different Organizations.
Survey: General or comprehensive view of or appraise, as a situation, area of study, etc.
4 Program Objectives
The EPA Program was developed in response to Saudi Aramco's Environmental
Protection Policy (INT-5) Statement, which commits the Company to manage and
conduct its activities in an environmentally responsible manner. Implementation of this
policy is provided under GI-0002.714 and promotes protection of the environment,
conservation of natural resources, and protection against liability. The objectives of the
EPA Program are to:
Assess the environmental performance of Saudi Aramco operating organizations.
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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Identify significant environmental compliance issues in Environmental Engineering
(air quality & emissions, wastewater discharges, management of solid, liquid, and
hazardous materials, groundwater quality, spill prevention and control).
To ensure that major findings (i.e., areas of noncompliance) are appropriately
resolved.
To provide annual reports to corporate management on the status of the EPA
Program.
5 Instructions
Commentary Note:
For further details, refer to the EPA Program Manual and the Team Leader's Handbook
issued by the Environmental Protection Department. The overview process for the EPA
surveys is shown in the Appendix A.
5.1 Planning Activities
5.1.1 Proponent Organization Selection and Scheduling
The Environmental Protection Department (EPD) selects facility or
group of facilities, to be surveyed during the following calendar year.
Selection is based on:
a) The potential impact of the operations on the environment.
b) Continuing compliance problems and/or complaints.
c) Available environmental monitoring data, recommendations and
feedback received from Environmental Engineering Division
(EED) specialists.
d) Current or planned operational status at the facility.
e) Requests by Proponent Departments.
The survey frequency for different types of operations is shown in Table1:

Table 1 EPA- Survey Frequency

Type Operation
Frequency (years)
Min. Max.
Refineries, Oil/Gas Plants 3 5
Production facilities, Drilling Operations,
Distribution & Terminals
5 7
Industrial Services, community services,
medical services
7 9
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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Proponent Organization selection shall be confirmed in November of the
year preceding the surveys.
All facilities administered by the proponent organization should be
included in the survey, whether or not the land used is under its
ownership.
Mothballed facilities will be surveyed to ensure that there are no
unresolved environmental violations. Abandoned facilities will be
surveyed on a case-by-case basis.
5.1.2 Survey Team Selection
EPD determines the number of survey team members and the type of
expertise needed for each survey, based upon the type and complexity of
the facility.
The Team Leader and one representative team member from each
discipline Air Quality & Meteorology Unit, Wastewater Management &
Marine Protection Unit, Land & Groundwater Protection Unit - shall be
provided by EED. Specialists from other EPD divisions might be invited
to participate if the facility conditions and characteristics require it.
Other Company Departments may be requested to provide
representatives whose specialized technical knowledge will contribute to
the effectiveness of the EPA Program.
The proponent department shall provide a facilitator during the survey.
This facilitator will assure security access and logistics support. The
facilitator must prepare and provide relevant documentation for the
survey. The facilitator is not considered to be a survey team member.
Survey team composition is finalized by November of the preceding year.
5.2 Pre-Survey Activities
5.2.1 Security Access
Once the facility selection is confirmed by the proponent department, the
proponent facilitator must inform EED of all requirements to access their
facilities at the time of the survey. Requirements might include special
training and/or special passes (e.g., H
2
S training, Helicopter
Certification, etc).
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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EED will request the security access according to EPA Manual
procedure.
5.2.2 Pre-Survey Information
Minimum four (4) weeks prior to the on-site visit, the proponent
department will provide EED with all information requested by EED.
This information mainly consists of the pre-survey questionnaire that is
released by EPD through SAP EH&S to the proponent. The
questionnaire must be completed and entered on SAP EH&S as support
documentation for the survey and future surveys.
5.2.3 Team Preparation and Documentation Review
The team members prepare for the survey by familiarizing themselves
with the facility organization and functions. All previous EPA reports
should be reviewed, as well as documentation regarding past
environmental problems, non-compliance incidents and formal
complaints. The Team reviews the pre-survey information input in SAP
EH&S by the proponent and may ask the proponent to submit additional
information that will help prepare the EPA team for their visit.
5.3 On-site Survey Activities
5.3.1 Opening Meeting
The EPA Opening Meeting is held before the site visit commences and is
organized and presided by the EPA Survey Team Leader. In attendance
are the survey team, the Proponent Manager, appropriate facility
supervision (as invited by the manager) and proponent facilitator. The
purpose of the Opening Meeting is to introduce the EPA survey team and
facility management, give an overview of the EPA process, clarify any
areas of uncertainty, discuss site details and logistics, and set a time and
location for the Closing Meeting.
5.3.2 Collecting and Verifying Information
During the site visit, the EPA team members might request to the
proponent department provides additional information for review. This
documentation may include procedures, licenses and permits, records of
monitoring and results of measurements. The team will verify the
information given by the proponent during the pre-survey stage.
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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5.3.3 Field Visit
The survey team will assess the facility's environmental performance by
evaluating compliance with the Company documents listed in Sections
2.1 through 2.3. The duration of the survey varies according to the size,
nature and complexity of the organization. This duration is established
during the planning activities described in section 5.1.1.
The environmental items to be reviewed and evaluated during the
survey, as a minimum are:
Air pollutant emissions and air quality problems
Wastewater discharges and management
Solid and hazardous waste disposal and management
Environmental monitoring, testing & sampling program data
Spill containment and contingency planning
Environmental incidents reporting
Environmental awareness campaigns and training
SAP EH&S waste manifest records
Verification of the pre-survey information sent by the proponent.
To assess the items listed in this section, the survey team should walk
through and inspect the facility, interview personnel, review pertinent
files, and investigate facility procedures. Checklists are required to be
used by the team members as a reminder of things to look for and to
document findings.
The survey team will check the status of the minor findings from
previous EPA survey. Unresolved minor findings may be elevated to
major status in the current EPA survey.
Each EPA is an independent survey and will be managed as such. The
survey team shall ensure that major findings are not repeated from
previous EPA surveys. Findings from each surveys will be tracked
separately.
Commentary Note:
EPD has the right to add an EPA finding to any proponent organization
outside the scheduled EPA event if serious violations have been reported
to EPD/EED either by an entity inside or outside the company. EPD/EED
will investigate the violation, evaluate its seriousness and will decide
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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whether or not will be considered an EPA finding. This will be
communicated to the proponent organization in writing signed by the
General Supervisor of EPD/EED.
5.3.4 Summary Report and Closing Meeting
After completion of the onsite survey and initial data evaluation, the
team shall prepare a Summary Report that contains the major and minor
findings. This report will be presented in a closing meeting. In
attendance are the survey team, the proponent manager, and appropriate
facility supervision (as invited by the manager). Three types of findings
may be reported:
a) Major findings are items that conflict with a Saudi Arabian
government and/or Saudi Aramco environmental requirement,
and/or represent significant cost to the Company if left unresolved,
and/or could have a significant adverse effect on the environment if
unresolved. The findings should be supported by reference to a
specific mandatory requirement.
b) Minor findings are issues that should be brought to the attention of
facility management. These are generally findings that can be
resolved within 6 months and may require some local funding. The
facility should seek to permanently resolve these findings as soon
as possible.
c) Exceptional efforts and/or best practices will be highlighted. EPD
recognizes and promotes environmental commitment.
The Summary Report is presented to facility management at the Closing
Meeting, which is normally held the last day of the site visit. The team
presents all findings, highlighting items that need immediate attention
and those that require significant capital expenditure. A copy of the
Summary Report is left with facility management.
The Summary Report will be included as an attachment to the EPA Final
Report and will be attached to the SAP EH&S notification which will be
opened for the tracking of the major environmental findings.
5.4 Post - Survey Activities
5.4.1 Final Report
The Survey Team Leader is responsible for issuing and circulating a
draft report to the team members and the EPA Program Coordinator
within three (3) weeks of completion of the site visit. The Final Report
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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shall be completed within four (4) weeks of the site visit and is sent to
the Proponent Manager.
Concurrently, EED will originate a SAP EH&S notification with all
major findings described in the final report and initiate a workflow. The
SAP workflow is approved by EPD manager and is sent to the proponent
manager.
The written Final Report and Summary Report will be attached to the
SAP EH&S notification.
SAP EH&S system is considered to be the company's official database
for reporting and tracking the major EPA findings.
Note: A year-end annual report is submitted to corporate and executive
management by the Vice President, Engineering Services,
summarizing all of the EPA surveys completed to date and the
progress made by facilities in resolving major findings as per the facility
action plans.
5.4.2 Proponent Organization Action Plan
After receiving and reviewing the Final Report and receiving SAP
workflow, the proponent shall complete the action plan for each finding
through SAP EH&S, which addresses resolution of the major findings.
This plan, with estimated dates of completion, shall be input into the SAP
system within four weeks of receipt of the Final Report.
The proponent shall resolve the major findings within the estimated dates
of completion (EDC), using appropriate Company resources as needed.
EPD concurrence with this Action Plan is necessary to ensure promp
closure. If the EDC must be revised, department head approval is
required for the first revision and admin area head approval is required
for the second revision.
Proponents should provide pertinent and verifiable documentation to
support closure of major findings. Relevant documentation should be
attached to the SAP EH&S notification in support of closure. Field
verification of implementation may be conducted by the EPD.
Minor findings should be resolved in no more than one year. These
findings will be will be tracked in a separate database so that they can be
re-evaluated at the next scheduled survey and, if unresolved, may be
elevated to major status.
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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The proponent must inform the EPA Coordinator of the closure of each
minor finding using the format in Appendix B.
5.4.3 Survey Follow-up
EPD will request that the proponent department update the status of the
major findings every 6 months. An automatic status request message
will be sent by EPD through SAP EH&S. This automatic message will
be received by the proponent manager and proponent environmental
coordinator until the findings are resolved to the satisfaction of EPD.
Proponent's updates will be reviewed by EED specialist and commented
accordingly.
A finding involving project action is not considered closed until the
project has been completed and commissioned. Copy of the
commissioning certificate should be attached to the SAP EH&S
notification.
Where a regulatory agency is involved, a letter indicating the solution
has been accepted or approved by that agency is required. Copy of the
approval letter should be attached to the SAP EH&S notification.
EPD shall have final concurrence on the resolution and authorize closure
of all major findings.
6 Responsibilities
6.1 Environmental Protection Department
Is responsible for the administration, coordination, and execution of the EPA
Program.
Shall finalize facility selection by September, and the survey team
composition by November of the preceding year.
Shall circulate the draft EPA Final Report within three (3) weeks of the site
survey to the team members and EPA Program Coordinator for comments,
and shall distribute the Final EPA Survey Report within four (4) weeks of
the site survey.
Shall originate and approve a SAP EH&S notification with all major
findings information contained in the final report.
Shall initiate a SAP workflow, and send the SAP notification to the
proponent manager.
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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If requested, EPD shall provide consultation on the development of a
corrective action plan for the facility.
Shall request the Proponent Department via SAP EH&S to update the status
of all open items on their action towards resolving the major findings every
six (6) months, until the findings are resolved.
Shall track the findings via SAP EH&S and work with the Proponent
Department to ensure resolution.
Shall prepare an Annual Report for submission to Corporate and Executive
Management that summarizes all of the EPA surveys conducted to date and
the progress made by facilities in resolving major findings.
6.2 Proponent Organization
The Proponent Department shall provide a facilitator with the qualifications,
environmental knowledge and experience. Facilitator must provide pre-
survey information requested by EED, relevant documentation, maps and
drawings.
Proponent Department shall provide any information requested by EPD
within the deadline stipulated by EPD during the pre-survey activities stage,
section 4.2.
The Proponent Department shall provide access and logistical support to the
survey team to inspect its facilities, interview its employees, and review its
documents.
The Proponent Department shall submit a facility action plan for the
resolution of major findings (if any) within four (4) weeks of receipt of SAP
EH&S workflow and EPA Final Report.
The Proponent Department shall track the resolution of all findings and
provide six (6) months periodic status for major open findings as outlined in
Section 4.4.3. Proper documentation will be uploaded in SAP EH&S to
support closure of resolved findings.
The proponent department must inform EED of the closure of minor
findings using the format in Appendix A.
The proponent department shall provide a person to be responsible for the
follow up of all environmental findings via SAP EH&S and to be the contact
point between the proponent and EED.
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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The proponent department shall inform the EPA team of all facilities that are
under his ownership. Also, all mothballed and abandoned facilities shall be
noted and known in advance.
The proponent department shall inform the EPA team of all facilities under
their administration. Also, all mothballed and abandoned facilities shall be
noted in advance.
6.3 Support Departments
If requested to participate, support departments shall provide specialized
technical representatives that will contribute to the thoroughness of the EPA
program.
6.4 EPA Survey Team
The EPA Team Leader shall direct the course of the survey. This may
include assigning tasks to team members in order to efficiently utilize their
expertise.
The EPA team members shall participate full-time during the onsite survey.
The team members shall finalize their findings by the end of the survey
period and present them in a Summary Report at the Closing Meeting. They
shall assist the Team Leader in preparing the EPA Final Report.
The team members shall review proponent updates for open findings and
provide feedback on the proponent's actions via SAP EH&S.
Commentary Note:
For SAP EH&S Waste Manifest findings, EPD will not close the finding until it
sees that proponent has used the system for at least one full year. This
policy can also be extended to other findings in which the proponent did not
do the required documentation (e.g., water disposal approval form).



Revision Summary
28 June 2009 Minor revision. Environmental Health & Industrial Hygiene were removed from all
sections. SAP EH&S as reporting and tracking system was included.
Revised the "Next Planned Update."
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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Appendix A Overview of Typical Survey Activities



Planning Activities

Facility selection and scheduling
Survey team selection
Pre-Survey Activities

Security access
Pre-survey information
Team preparation and
documentation review
Survey Activities

Opening meeting
Field visit
Collecting and verifying
information
Summary report and closing
meeting
Post-Survey Activities

Preparing the final survey report
Approving and distributing final
survey report (written & via SAP
EH&S)
Facility Action Plan
Survey follow-up
Document Responsibility: Environmental SAEP-32
Issue Date: 28 June 2009
Next Planned Update: 28 June 2014 Environmental Performance Assessment (EPA) Program


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Appendix B Minor Findings Close Out Form


MINOR FINDINGS CLOSE OUT FORM
Date:
EPA Number & Survey Date



Minor Finding No & Description



Recommendation Description



Actions involved & Recommendation Status



Reason for modifying the Recommendation, if applicable


Identification of key documents (i.e., Work Order #, MCC, etc.)


Completion Confirmation
Processor Name Signature Date

Accepted
Environmental
Coordinator
Name

Signature Date

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