While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The Project is located in a predominantly agricultural area and stakeholders have high expectations in respect to job opportunities, local procurements, and investment in local communities. The residential dwellings in proximity to the Project may be affected by construction and operational related nuisance impacts. The 2,090 MTPD ammonia plant will generate in excess of 1 million ton CO2-equivalent greenhouse gas per annum, mainly from the ammonia manufacturing process. The discharge of large amounts of cooling seawater, treated effluents, and storm water runoff also have the potential to impact the marine ecology. A natural reserve area for protected birds is located approximately 50 km to the southwest of the project site. Mitigation measures for the potential environmental and social impacts have been identified and are incorporated into an attached Environmental and Social Action Plan (ESAP).

The potential adverse E&S impacts of this project from the combined impacts aforementioned are therefore diverse and irreversible. This is therefore a Category A project.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Land and Natural Environment: The Project is located in an area predominated by agricultural plantations. PAU plans to develop the Project on 25 ha of land in the coastal area of Luwuk, Central Sulawesi Province, Indonesia. PAU has 180 hectares of land in the same complex as reserved land for a green barrier and future development. Most of the land will be used as buffer area, and for future development of downstream products of ammonia. The Project site is currently covered by coconut and other tropical plantations. To the south of the site is a beach; tropical vegetation and plantations to the north and east; and DSLNG is located to the west of the site. A conservation area for the maleo bird, an endemic species in Sulawesi and an IUCN red-listed endangered species is located approximately 50 km south-west of the site. There are no mangroves in the Project area and no shallow corals were observed. There are scattered residential dwellings along the coastal area with the nearest being approximately 1 km from the proposed ammonia storage tanks.



Corporate Environmental and Social Policy: The Project is in the early development stage and land clearance is yet to commence. The company has developed a corporate E&S policy stating that PAU is committed to conduct all its activities in a safe and eco-friendly manner. The corporate E&S policy requires its operations to comply with all the relevant environmental regulations and promote harmonious relationship with surrounding communities through implementing corporate social responsibility activities. PAU is also committed to comply with IFC’s Performance Standards and applicable World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines for this and future projects related to ammonia downstream products. As indicated in the ESAP, PAU is committed to prepare the Construction E&S Management Plan before the full scale construction and prepare the Operational E&S Management Plan one year before Project commissioning.



Identification of Risks and Impacts: An EIA for the proposed ammonia project was approved by the local authority in September 2012. Subsequently, PAU contracted international consultants to prepare draft EIA Addendums to comply with IFC requirements. The addendums focus on biodiversity conservation, pollution controls, resource efficiency, earthquake impacts, cumulative impacts, E&S management and monitoring programs, and social impacts. The social impact assessment concludes that social impacts from both the current and previous land acquisition as well as issues related to construction and operational nuisance are not significant. The EIA Addendums will be finalized prior to submission of the Project to IFC’s Board. The EIA, draft EIA addendums, and IFC’s E&S appraisal conclude that PAU operations will comply with both the local regulatory requirements and IFC’s Performance Standards upon successful implementation of the agreed mitigation methods. The EIA, draft EIA Ad
dendums and Stakeholder Engagement Plan (SEP) will be disclosed together with this document. The final EIA Addendums and SEP will also be disclosed once they are available. PAU is also committed to undertaking an environmental and social impact assessment for all future projects that will align with both local regulatory requirements and IFC’s Performance Standards.



Cumulative Impacts: As a part of the EIA addendum, a cumulative impact assessment (CIA) was undertaken to take into consideration of the impacts associated with other projects in the area. The draft CIA concludes there are no major cumulative impacts. There are benefits from these project developments. Besides, all the identified cumulative impacts are minor or moderate in nature. Moderate impacts identified are related to terrestrial flora/fauna and the marine environment. For all moderate impacts, PAU will prepare and implement the mitigation methods as part of the Stakeholder Engagement Plan, Construction E&S Management Plan, Flora/Fauna Management Plan, and Operational EHS Management Plan as discussed below.



Corporate Environmental and Social Management and Organization: The Project is still in early preparation stage. Civil construction is yet to commence and the basic engineering design was finished in December 2012. PAU plans to establish an EHS department and gradually staff it with 19 people before Project commissioning in June 2015. Part-time EHS coordinators will also be appointed at each process unit. PAU has appointed a Social and Community Relationship Officer who is also responsible on land matters, and PAU intends to put him through a training program to enhance skills. Technical support to this role will be provided by competent consultants to manage community relationships. In accordance with the ESAP, PAU will formally appoint the EHS Manager and designate the Social Program Manager in the first quarter of 2013.



The Toyo Engineering Corporation has been selected as the engineering, procurement, and construction (EPC) contractor. Toyo will have an EHS team on site during the construction period. PAU will continue to hire personnel for its EHS department to deliver the key E&S functions as the Project planning develops. The PAU EHS department, supported by the construction management contractor, will oversee activities by the Toyo EHS team through the construction period to ensure E&S risks during construction are mitigated in accordance with the Construction E&S Management Plan.



PAU will develop the Operational E&S Management Plan in 2013 and 2014 for the operational phase, including EHS procedures for each operational position, air emissions and liquid effluents controls, ambient environmental monitoring, hazardous materials management, solid/hazardous waste management, emergency response, energy efficiency and water saving, and social issues related to operational nuisances and high local expectations, etc. The Operational E&S Management Plan wil
l be developed according to local regulations, good international industry practices (GIIP), and IFC Performance Standards and applicable WBG EHS Guidelines. PAU will apply for international certification for EHS management systems such as ISO 14000 and OHSAS 18001 after the Project commences normal operations.



New employees will be hired 12 months before Project commissioning. New employees will be trained for 9 months and also will be sent to other ammonia plants for 3-month training sessions, which include position-related to EHS management. During the operational phase, employees will be required to have 40 hours of refresher training every six months or every year, depending on the position, which will include 16 hours EHS training.



Emergency Preparedness and Response: Fire hazards and ammonia leaks are the main operational risks associated with the Project and PAU will develop strict management procedures to control these. Personal electronics will not be allowed in the process area and all the vehicles in the process area will be equipped with spark arrestors. There will be fire and hazardous gas sensors at high risk areas. The sensor systems and closed circuit TVs (CCTVs) will be connected with the central control room in real time. The central control room will be equipped with blast proof features and can also be operated as an emergency response (ER) center under the worst case scenarios. The closest fire station is some 40-km distant and thus PAU will set up its own fire station on-site. The details of the fire stations will be defined in the detailed designs. PAU has approached the neighboring LNG plant to develop a joint firefighting and ER program. Joint firefighting and ER drills will be undertaken during the operational phase.



There will be a firefighting water and foam storage facility on-site to sustain 6-hours of firefighting. Sprinkler systems and foam firefighting equipment will be installed on all tank farms and other key potential fire sources. All firefighting equipment will be routinely inspected by the EHS department or their contractors. In addition, there will be an on-site clinic staffed with experienced personnel 24 hours a day.



Monitoring and Review: The monitoring and performance review programs will be developed prior to the operational phase. The EHS department will convene daily meetings to review EHS performance and there will be monthly EHS summary meetings, chaired by the plant General Manager, to review the monthly EHS performance, summarize the corrective actions, and evaluate the implementation of previous corrective actions. The EHS Department will establish annual EHS improvement targets with the budgets and implementation plans each year. These targets will also be reviewed annually to ensure proper implementation.



Stakeholder Engagement: To respond to high expectations related to job opportunities, local procurement, and investment in local communities, PAU developed a “Social Poli
cy” and has committed to follow this to establish harmonious relations with its surrounding community and other stakeholders.



The field team responsible for the preparation of the Project has been active in the identification of Project stakeholders in the local area and was central to the data gathering for the baseline studies. There have been two formal public consultation events conducted in the Project area. Stakeholders consulted during the EIA represented the diversity of the neighboring communities and included locally elected officials, religious leaders, and community based organizations as well as the public. The consultation was conducted so as to ensure that stakeholders were aware of the Project, its purpose and objectives, the different development phases and identify concerns and issues raised by the local communities, key stakeholders and non-governmental organizations (NGOs). Key requests from stakeholders relate to job opportunities and the need for local procurements to stimulate and promote the local economy. In addition, consultation with project directly affected community members was conducted in informal settings during the land transaction process.



PAU recently developed a draft Stakeholder Engagement Plan which documents historic stakeholder engagement activities and defines a road map for future engagement. The Plan demonstrates PAU’s recognition of stakeholders and community issues and concerns and defines an ongoing process of stakeholder engagement on the basis of “Informed Consultation and Participation” throughout the site preparation, construction and operational phases. Competent and qualified community relations personnel will be appointed by the EPC contractor for the duration of the construction program. Key members of the PAU current field team will remain in place to oversee community relations throughout all stages of the Project.

The number of employees required for operation of the PAU facility is approximately 350. During construction, up to 2,000 personnel will be required at peak times. PAU will actively work with their contractors to promote local access to employment in both the site preparation and construction phases. Early indications suggest that the necessary technical skills required for the Project’s construction and operational phases may be scarce in communities in proximity. PAU has been working with local communities and NGO’s to identify training needs and vocational training programs for the local communities to assist the EPC contractor in achieving the community employment target.



It is expected that majority of the construction workforce will be comprised of Indonesian nationals. PAU intends to maximize local labor, and target the majority of unskilled labor from local areas; where local skills match needs, priority will be given to locals.



Corporate Human Resources Policy and Management: A Human Resources (HR) Manager was recently hired and is responsible for the formalization and implementation of PAU’s Human Resources policy and procedures. Policies and procedures will include measures to ensure conformance with ILO core labor standards, promote a non-discriminatory and equal opportunity working environment, and ensure safe working conditions for PAU personnel and contractors alike. The policies and procedures will be shared with all employees as part of the new employee orientation process in relation to their specific responsibilities. These will also be documented with individual rights under the law in the employment contract and the law. Individual conditions of employment will be communicated through a written contract to be issued at the time of employment.



The HR Manager is also responsible for establishing conditions to ensure fair and transparent recruitment procedures are applied and to implement the community employment targets.



Employment conditions for PAU and those of the Project’s construction contractors will comply with Indonesian labor laws including regulations with respect to working hours, overtime payments, vacation, and other benefits and compensation. Further, employment regulations and requirements will comply with IFC’s Performance Standard 2 as agreed between PAU and the EPC contractor and included in the EPC contract.



The EPC contractor will be responsible for developing the detailed HR procedures to be followed by the construction workforce. The EPC contractor has legal and contractual obligations to implement safe working practices at the construction site and will demonstrate compliance with policies and procedures through a monitoring program that will record and routinely report performance to PAU. An evaluation system will be in place to ensure labor laws are being followed by all sub-contractors; outstanding issues once identified will be reported to PAU.



Workers’ Organization: Colle
ctive bargaining is in place in Indonesia and governed by labor law; such bargaining will be accessible to all labor linked to PAU. PAU will have a grievance procedure in place which will include processes for receiving applicable grievances in person, in writing and by phone. PAU’s contractors will be held responsible for the fair and appropriate handling of employee grievances and this will be subject to monitoring by PAU’s Human Resources Department.



Protecting the Work Force: There is no forced or under aged personnel hiring by PAU and the age limit for employment in Indonesia is 16. A recruitment process is in place preventing the hiring of under aged personnel. The EPC contractor has contractual and legal obligation to prevent hiring of forced or under aged personnel; appointment of all subcontractors will be evaluated and reported upon by the EPC contractor to PAU.



Occupational Health and Safety (OHS): A Construction E&S Management Plan will be compiled prior to construction. OHS risks will be identified using job hazard analysis (JHA) procedures. The identified risks will be reviewed against the GIIP to define appropriate mitigation measures to be adopted to avoid or eliminate defined hazards and risks. The contractors will conduct OHS induction training for all site personnel. Specific training will be provided as required to ensure that personnel have the necessary skills to identify hazards and carry out their work responsibilities safely. Zero fatalities is the target for the construction phase. The PAU EHS department, supported by a construction management contractor, will review and approve construction contractors’ EHS plan, and monitor the OHS performance of the contractors.



Operational safety is highly emphasized during the Project preparation and a JHA will also be conducted for each operational position. Based on the JHA results, OHS procedures for each position will be developed in 2013 and 2014. PAU will plan routine OHS training, including annual refreshers for its employees. Safety awareness will be emphasized during construction and operations and near-misses monitored during operations. PAU also plans to control the incidences for both construction and operation to meet GIIP. PAU is committed to meet GIIP for workplace air quality and noise levels through proper designs and OHS management during operations. The treated drinking water for the operational stage will meet WHO drinking water standards. PAU will incorporate OHS management into the Operational E&S Management Plan.

Raw Materials and Resource Efficiency: The major raw materials used at the PAU plant will be natural gas and water. Natural gas will be supplied via the neighboring LNG plant. The natural gas consumption rate will be 54.36 MMSCFD, in which 1.64 MMSCFD will be used for the on-site power plant and 52.72 MMSCFD will be used for ammonia production. The electricity will be solely provided by the on-site power plant which includes four 5 MW gas engines. During normal operations three engines will operate, with the other on standby. There is no fresh water supply in the Project area. All the process and sanitary water will be supplied by an on-site seawater desalinization facility thorough reverse osmosis. Approximately 2,000 tons per day of freshwater will be produced by this plant. Seawater will be used as cooling water in a closed loop at the rate of 19,900 m3/hr, and then discharged back to the sea together with the brine from the reverse osmosis. The discharged sea water quality and temperature will be monitored as part of the routine environmental monitoring program and documented in the Annual Monitoring Report prepared for IFC.



Advanced ammonia manufacturing technology from Kellogg Brown & Root (KBR) is being adopted. Based on the technology specifications and design criteria, it is estimated that the energy consumption rate will be 29.92 GJ lower heating value (LHV)/ton ammonia, which meets the energy efficiency benchmark of the WBG EHS Guidelines.



Corporate EHS Performance Management and Compliances: The EHS department will work together with EPC contractor to develop all the necessary EHS procedures for the operational phase. The EHS department, together with EHS coordinators at each process unit, will manage EHS performance during operations. In addition, the EHS department will conduct routine performance inspections to identify outstanding EHS issues that need improvement. At the General Manager’s monthly operations meeting corrective actions for outstanding EHS issues will be discussed, including an implementation timetable and responsible parties. The progress on implementation of corrective actions will be reviewed during the subsequent monthly operations meetings.



According to the EIA, PAU will generate approximately 31 m3/hr wastewater from the process and 5 m3/hr of sanitary wastewater. According to the concept design, wastewater and potentially contaminated storm water will be treated at the on-site wastewater treatment unit (WWTU) prior to discharge to the deep sea via an outfall. PAU is committed to meet all local regulatory requirements and WBG EHS Guideline limits for wastewater discharge.



The cooling seawater temperature will be increased by 10 degree Celsius. An open cooling channel will be adopted to cool the cooling water before it is discharged back to sea. The discharging mouth will be specially designed for a quick and efficient mixing to ensure the temperature at the edge of mixing zone is less than 3 °C
above the ambient seawater temperature, which is in line with the requirement of the WBG EHS Guidelines. Retention ponds will be built on-site prior to site preparation to collect non-contaminated storm water during both construction and operations. The retention ponds will be designed with sufficient capacity to ensure adequate sedimentation prior to discharge of the water to sea.



The EIA predicts the air emissions from the power plant and the ammonia manufacturing processes will meet both local regulatory requirements and the WBG EHS Guidelines. Based on the concept design, the CO2 and NOX emission rates will also meet WBG EHS Guideline benchmarks which reflect efficient production processes and emission controls. The cumulative impacts are defined as being minor to moderate.



Solid and Hazardous Wastes: According to the Project concept design, there will be no waste treatment or disposal facility at the PAU site. Wastes will be temporarily stored on-site at secure warehouses before off-site disposal. The sanitary wastes will be collected by municipal contractors for disposal. The industrial wastes, including the used resins, will be sent to licensed industrial solid waste management contractor for disposal. The used catalysts will be sent back to the manufacturers for regeneration or disposal.



Hazardous Materials and Operation Hazard: PAU’s raw material and product are hazardous. The manufacturing, storage, handling, and transportation of these materials may pose risks to employees and nearby communities alike. PAU will work with the EPC contractor to develop detailed procedures to manage the hazardous materials. There is no on-site storage of natural gas, or hydrogen generated. Liquefied ammonia will be stored in double-wall storage tanks and there will be backup electricity supply for the tanks. The tank integrity will be inspected by specialized contractors periodically. A hazard operability study (HAZOP) will be conducted during detailed design phase to assess risks and define mitigation measures. PAU will update the HAZOP whenever a process is modified. Automatic shutdown functions will be included in the process control in case of an emergency. All the excess hazardous gases during abnormal operation are designed to be routed to an on-site flare for destruction. The plant will be designed according to KBR technology, a global leader in ammonia manufacturing, and all the operational hazard management will follow Toyo’s procedures at its Japanese plants.



PAU conducted seismic hazard analysis for the project site. The Project area falls in the category of peak ground acceleration (PGA) of 0.25g. PAU will adopt conservative approaches and design all the non-process buildings in accordance with PGA of 0.30g and process building/structures, including ammonia storage tanks, in accordance with PGA of 0.40g.



In accordance with the ESAP, PAU will contract external experts to conduct a quantitative risk assessment (QRA) for th
e ammonia storage tanks once the critical parameters are available from the detailed design. Potential impact radii under various scenarios for a leak, fire and explosion, including the worst case scenario, will be analyzed based on the QRA modeling calculation. PAU will take appropriate mitigation methods according to the QRA results to ensure the safety of its staff and nearby communities.



The ammonia shipping tankers will be required to comply with all applicable environmental standards of the International Maritime Organization (IMO) for hazardous liquid transportation. The characteristics of the vessel must be certified to the standards by an independent specialist in the field and approved by the PAU EHS Manager before they are allowed to dock at the jetty. There will be routine inspections for spill/fire prevention at the jetty during loading periods, including pipe connections, water pump readiness, fire source inspection, etc.



Greenhouse Gases (GHG): After Project commissioning, PAU will generate approximately 1.04 million tonnes of CO2-equivalent GHG annually, mainly from the ammonia manufacturing and the on-site power plant. The GHG generation rate for the manufacturing process is 1.27 ton/ton ammonia which is aligned with the WBG EHS Guideline benchmark.

Community Health, Safety and Security: The Project is located in a tropical plantation area with local smallholders. Uso Village, the closest populated community, is 5 km to the south-west of the Project site. There are only a few scattered houses near the PAU site along the coast. The EIA modeling indicates that under normal operations at PAU there will be limited impacts on the nearby houses. Natural gas will be supplied from the neighboring LNG plant, and ammonia will be shipped via the on-site jetty. PAU will evaluate the safety related to the nearby residential dwellings under various ammonia leak/fire scenarios based on the QRA modeling results. Mitigation methods will be proposed and implemented, including relocation of residential dwellings if the QRA modeling indicates potentially unsafe conditions. The road traffic will increase during the construction period and PAU will develop and implement a traffic management plan as a part of its Construction E&S Management Pan.



Emergency Preparedness and Response: PAU will develop a comprehensive emergency response (ER) plan together with the EPC contractor as part of the Operational E&S Management Plan. The ER plan will include the involvement and the safety of the nearby residents as required. Communities will be informed of the ER drills. PAU will only contract transportation companies that have defensive driving programs, acceptable safe driving records, and sufficient emergency response methods. PAU will require the transportation company to report accident rates quarterly.



Security Personnel: PAU will hire an external agency for plant site security that conducts routine identification checks at the gates and security monitoring. Those security guards will not be armed and will be trained to use force commensurate with the threat presented.

According to the EIA and EIA Addendums, there are no mangroves in the Project area. A natural conservation area for the maleo bird (Macrocephalonmaleo), an IUCN red-listed endangered species, is located approximately 50 km south-west of the PAU site. A known nesting beach for green turtle is located approximately 10 km to the south of the proposed project site. The EIA also indicates that there are wide spread corals on the coasts of Central Sulawsi Province. The EIA and EIA Addendums did not identify any other floral or faunal species with high biodiversity values near the Project area.



According to the interviews with local community members, maleo birds do not occur in the Project area given human activities in the area. In accordance with ESAP, PAU will develop a Flora and Fauna Management Plan to be implemented during site clearance, which will detail specific actions that should be taken in case maleo bird are encountered during site clearing activities, construction and operations.



To protect the marine ecology, PAU will maintain a 50 meter greenbelt along the coast and only develop the site inland. PAU plans to fence the 50 meters green belt and the whole beach area as a conservation mitigation method. The reserved coast together with the greenbelt could be also used as a natural habitat for turtles if they migrate to the Project area from their nesting beach. All the on-site stormwater runoff will go through a sedimentation process at the onsite retention pond before discharge to sea. The densely vegetated greenbelt will also filter the uncaught stormwater runoff from site.



Though there are widespread corals along the coast of the Central Sulawesi Province, corals are much less populated in the Project area. PAU’s initial survey indicates no coral reefs occur at the location of the proposed jetty area. However, PAU will conduct a detailed coral survey prior to construction of the jetty. If there is high value coral in the proposed jetty area, PAU will move the jetty location or, based on expert advice, transplant the high value coral reefs to other non-impacted locations. PAU will apply pile construction methods to the jetty which could minimize the impacts to any remaining coral in the vicinity. The Construction E&S Management Plan will also include the marine ecology protection procedure for the jetty construction. PAU will select an area without corals for discharge of the cooling water and treated effluent.



In accordance with the ESAP, PAU will cooperate with the WWF regional office in Luwuk on biodiversity preservation actions in the greater Luwuk area. PAU will also engage other industries in the region to work together with the WWF Luwuk branch for broader biodiversity conservation activities.

PAU has had a team on site for two years dedicated to the land purchase process. Their daily work involves the identification and engagement with land owners, village decision makers, and village representatives to ensure that communities are aware of the Project and can meaningfully participate in the land acquisition process. In addition, considerable community engagement activities have been undertaken to support the EIA and the EIA Addendums to establish sound relationships with local communities and stakeholders. The team consists of one land manager and several supporting staff all of whom have long-standing experience and knowledge of the local area, the status quo and approach required to land purchase.

In response to community requests for employment opportunities, PAU plans to maximize these for local communities both during the construction and operational phases. Furthermore, PAU is in the process of developing a community investment framework and phased community development programs to implement its social policy to support health facilities, community infrastructure and education program initiatives. The PAU field team is central to the identification and delivery of community programs. The identification of programs has commenced and one of the programs identified is vocational training (related to electrics, welding, fabricating, and computing) for local people to assume skilled job positions. Training will taking place in the nearby Luwuk training center with skilled graduates expected to be employed by PAU, or other firms. PAU is assessing the potential for partnerships with neighboring projects and local NGOs to identify and implement specific community development programs. The Stakeholder Engagement Plan PAU recently developed follows the company’s “Social Policy” so as to establish harmonious relations with the surrounding community and other stakeholders throughout the Project development.

PAU will disclose this document in Indonesian at the bulletin board outside of PAU’s Luwuk Office, located at Jl. Nyiur, Luwuk, Banggai, Central Sulawesi Province, Indonesia. For enquiries or concerns about the environmental and social impacts of the Project please contact:

NAME Muzalkazim Ali
ADDRESS Jl. Nyiur, Luwuk, Banggai, Central Sulawesi Province, Indonesia
PHONE +62 81381002972

An Environmental and Social Action Plan, a draft EIA Addendums, and a draft Stakeholder Engagement Plan are disclosed together with this document. The final EIA Addendums and Stakeholder Engagement Plan will also be disclosed 50 days following this disclosure.

Broad Community Support is not applicable for this project

PAU Indonesia(32198) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
1. Appoint an Environmental Health and Safety Manager.	31-Mar-2013	Completed	Completed	3/31/2013
1. Prepare and implement a Construction Environmental and Safety (E&S) Management Plan inclusive of:· EPC contractors’ occupational health and safety plan	01-Jan-2015	Completed	Completed	1/25/2016
1. Prepare and implement a Construction Environmental and Safety (E&S) Management Plan inclusive of: · The E&S management structure and general procedures · Procedure defining PAU’s approach to auditing to the EPC contractor to ensure compliance with local regulatory requirements and PS 2: Labor and Working Conditions · ·	30-Sep-2014	Completed	Completed	4/12/2017
. Prepare and implement a Construction Environmental and Safety (E&S) Management Plan inclusive of: Flora/Fauna Management Plan	30-Sep-2014	Completed	Completed	6/16/2016
1. Prepare and implement an Operational E&S Management Plan inclusive of: · The E&S management structure and general procedures · Emergency response plans and procedures · Occupational health and safety management · Monitoring of environmental parameters. The E&S Plan is to align with the requirements of PS 1: Assessment and Management of Environmental and Social Risks and Impacts and PS 2: Labor and Working Conditions.	31-Oct-2014	Completed	Completed	11/12/2017
Prepare and implement a Construction Environmental and Safety (E&S) Management Plan inclusive of:Traffic management plan Procedures defining PAU’s and the EPC Contractors responsibilities for implementation and auditing the Plan	31-Dec-2014	Completed	Completed	10/10/2016
Prepare a community investment program framework	30-Sep-2014	Completed	Completed	6/16/2016
Conduct HAZOP	31-Mar-2015	Completed	Completed	12/29/2015
Develop and implement human resources documentation compliant with local legislation and PS 2: Labor and Working Conditions for the operational phase.	31-Dec-2014	Completed	Completed	11/12/2017
Job hazard analysis (JHA) for main process positions	15-Nov-2015	Completed	Completed	11/25/2015
Conduct a quantitative risk assessment (QRA) for the ammonia storage tanks. Based on the findings thereof, agree with IFC on mitigation measures to be implemented.	31-Mar-2015	Completed	Completed	10/10/2016
Conduct a coral survey along the coast in the vicinity of the Project and agree with IFC on the location of jetty and discharge points for cooling water and effluent.	30-Sep-2013	Completed	Completed	9/30/2013
1. Contact World Wildlife Fund regional office in Luwuk and jointly agree biodiversity management in greater Luwuk area for both the construction and operational phases. - Initial contact with World Wildlife Fund regional office in Luwuk Agreement for biodiversity management	01-Aug-2014	Completed	Completed	8/1/2014