City Fort Contracting LLC

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City Fort

Contracting LLC

Operation Control Rev: 00

Environmental Management System EMP-OC/CFC/06

Operation Control

Approvals

The signatures below certify that this procedure has been reviewed and accepted, and demonstrates that the signatories are aware of all the requirements contained herein and are committed to ensuring their provision.

Name Signatu

re Positio

n Date

Prepared By Reviewed By Approved By

Amendment Record

This procedure reviewed to ensure its continuing relevance to the services and process that it describes. A record of contextual additions or omissions is given below:

Page

No. Context Revision Date

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City Fort

Contracting LLC

1. PURPOSE

To describe procedures used by the City Fort Contracting to identify those operations and activities that are associated with the System’s identified significant environmental aspects in line with its environmental policy, objectives and targets. These procedures also are intended to provide documentation to ensure that the System’s operations and activities, including maintenance, are carried out under specified conditions by covering situations where the absence of such documentation could lead to deviations from the System’s environmental policy and its objectives and targets, to stipulate operating criteria, and to enable the System to identify significant environmental aspects of goods and services used by the organization.

2. SCOPE

These procedures apply to the environmental management system (EMS) implementation process used by the System to ensure control of the operational criteria and procedures used by City Fort Contracting, and to communicate relevant procedures and requirements to its suppliers and contractors.

3. TERMS/DEFINITIONS

3.1. Documented procedures written procedures, instructions and guidance that describe proper operations and protocols to control adverse environmental impacts from processes and equipment under foreseeable and reasonably expected operating conditions

3.2. Operating criteria Control parameters, indicators, and/or thresholds that can assist in the determination of the potential environmental impact of operating equipment

3.3. The HSE Team of City Fort Contracting, which has responsibility for assisting in the implementation and operation of the EMS program.

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City Fort

Contracting LLC

4. APPLICABLE DOCUMENTS

4.1. ISO 14001:2004, Clause 4.4.6, Operational Control 5. RESPONSIBILITIES

5.1. The QHSE Representative (MR), with assistance from the HSE Team shall be responsible for implementing these procedures.

5.2. Department Supervisors are responsible for communicating applicable operational control procedures to System personnel under their supervision. The MR will assist Department Supervisors as appropriate with respect to internal communication of relevant operational control procedures.

5.3. The MR, with assistance from the HSE Team and Department Supervisors, shall identify relevant operating criteria to be incorporated in the System’s environmental management system operational control procedures.

5.4. The Purchasing Manager, with assistance from the HSE Team, is responsible for communicating relevant procedures and requirements to suppliers and contractors.

5.5. Specific responsibilities of System management and personnel with respect to the establishment and maintenance of the company’s operational control procedures.

6. PROCEDURE

6.1. Procedures/Instructions Relating to Operations/Activities with Significant Environmental Aspects

6.1.1. The HSE Team and Supervisors, as appropriate, shall establish and maintain operational control procedures and work instructions to address System operations and/or activities that are associated with the System’s identified significant environmental aspects.

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City Fort

Contracting LLC

Environmental Management System EMP-OC/CFC/06 6.1.2. The process for developing operational control procedures and work

instructions should include the following steps:

6.1.2.1. Identify production and non-production processes and/or activities with significant impacts. The processes and/or activities with significant impacts are identified in EMS Records of Environmental Aspects and Significant Impacts).

6.1.2.2. Identify operations and equipment that are associated with the identified significant impacts.

6.1.2.3. Determine if procedures or instructions already exist for operations and equipment associated with identified significant impacts.

6.1.2.4. Develop appropriate procedures and instructions as follows for operations and equipment associated with identified significant impacts.

These procedures/instructions are referred to as “Significant Work Instructions”:

6.1.2.4.1. Review existing procedures and instructions relating to System operations and equipment associated with identified significant impacts. Revise, as necessary, existing procedures to ensure that the procedures or instructions:

6.1.2.4.1.1. Provide appropriate guidance or instructions for controlling the significant environmental impacts of the particular operations or equipment;

6.1.2.4.1.2. Cover all operating requirements that are specified in applicable environmental regulations and legal requirements, including environmental permits;

6.1.2.4.1.3. Address and specify appropriate maintenance, repair and/or calibration needs;

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City Fort

Contracting LLC

Environmental Management System EMP-OC/CFC/06 6.1.2.4.1.4. Address process or equipment operational modes, such as

startup, normal operations, product changeover, upset or

emergency situations, shutdown and

commissioning/decommissioning, to ensure that significant environmental impacts are adequately controlled;

6.1.2.4.1.5. Specify necessary operating criteria, without which the process or equipment could adversely impact the environment;

6.1.2.4.1.6. Describe potential consequences of failing to adhere to specified procedures or instructions; and

6.1.2.4.1.7. Describe relevant procedures or instructions in a clear format, with appropriate references provided.

6.1.2.4.1.8. Where necessary, new procedures or instructions should be prepared for particular System equipment or operations associated with significant environmental impacts using the criteria set forth at paragraph 6.1.2.4.1 above.

6.1.2.5. As deemed appropriate, develop new or revised environmental management procedures or instructions for activities, processes and/or operations that are of general or “universal” applicability at the System facility. These procedures/instructions are referred to as “Universal Work Instructions.” Examples of “universal work instructions” include instructions relating to the System’s emergency preparedness and response/contingency plan, its spill prevention control and countermeasure plan, and instructions relating to planning of the System’s environmental management system.

6.1.2.6. Document all procedures, Operator Work Instructions and Universal Work Instructions and manage and maintain them as controlled documents in accordance with QHSE Procedure (Document Control). Documented procedures and work instructions should be included in the IMS Manual. Documented procedures and work instructions should be accessible by all

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City Fort

Contracting LLC

Environmental Management System EMP-OC/CFC/06 employees whose activities can have an impact on the environment.

6.1.2.7. Annually review and revise or update, if necessary, the company’s documented procedures and work instructions to reflect changes in the company’s significant environmental impacts, products, processes, operations and/or activities.

6.2. Procedures/Instructions Relating to Suppliers and Contractors

6.2.1. The MR, with assistance from the HSE Team and the Supply Chain Manager, shall establish and maintain procedures or instructions relating to the identifiable significant environmental aspects of goods and services used by the System, and for communicating relevant procedures and requirements to suppliers and contractors.

6.2.2. The process for developing and implementing procedures or instructions relating to the significant environmental aspects of the goods and services used by the company and communicating the company’s procedures and requirements should include the following steps:

6.2.2.1. The Purchasing Manager shall work with the MR to identify the significant environmental aspects of goods and services used by the company.

6.2.2.2. To identify these significant environmental aspects, the MR and Purchasing Manager shall follow HSE Work Instruction.

6.2.2.3. The Purchasing Manager and the MR, with assistance from the HSE team, shall annually review completed Environmental Supplier Surveys returned to the System to identify the significant environmental aspects associated with the goods and services used by the System, and to evaluate the environmental performance of the System’s suppliers and contractors.

6.2.2.4. The Purchasing Department and other affected Departments will consider as part of the supplier/contractor selection process the environmental commitments and performance of potential and

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City Fort

Contracting LLC

Environmental Management System EMP-OC/CFC/06 existing suppliers/contractors, as well as the environmental aspects of the goods and/or services to be purchased.

6.2.2.5. As part of the annual management review process, the Management Team will review the environmental performance of the System’s suppliers and contractors and may direct, as deemed appropriate, that suppliers or contractors be selected based on their environmental performance.

6.2.2.6. With assistance from legal counsel, as appropriate, the Purchasing Manager should ensure that supplier contracts, bid documents, evaluation survey forms notifications and/or other evaluation documents clarify that:

6.2.2.6.1. The company is not assuming any liability or responsibility for the supplier’s operations or activities as a result of the evaluation;

6.2.2.6.2. The company’s evaluation of the supplier should not be taken as a waiver of any future legal claims or defenses that City Fort Contracting may have with regard to the supplier; and

6.2.2.6.3. As appropriate, include a disclaimer that System shall not be

deemed to have assumed any control over, or any liability or responsibility for, its supplier’s or vendor’s operations or activities as a result of the company’s evaluation of or visit to the supplier’s/vendor’s facility (or any information relating thereto). This disclaimer may further state, as appropriate, that any visit or evaluation conducted by City Fort Contracting should not be taken as a waiver of or surrender of any claim, right, or defense that City Fort Contracting may possess or assert at any time concerning any of the supplier’s/vendor’s products, services or activities.