1. January 2011 Complex Ecological Examination of Naftna Industrija Srbije (NIS) Production Facilities D’Appolonia S.p.A. AN ISO 9001 AND ISO 14001 CERTIFIED COMPANY www.dappolonia.it

2. Content and Scope of Services Scope of the services has been to conduct an environmental examination of several NIS manufacturing facilities The study has targeted 12 facilities (total area: about 400 ha): Pančevo Refinery (about 200 ha) Novi Sad Refinery (150 ha) Smederevo and Čucarika Tank Farms (20 ha) 2 Petrol Stations in Novi Sad and Belgrade Gas Refinery Elemir Kikinda and Mokrin Compression Stations TNG Regional Centre Novi Sad 2 facilities of Service Companies (Zrenjanin)

3. Specific Scope of Services The Study has been divided in four phases corresponding to four general goals: Phase 1: Ecological Assessment of Environmental Status (water, soil, air) within the NIS Economic Activity Zone Phase 2: Assessment of Potential Environmental Risks Phase 3: Assessment of Facility Ecological Management System Phase 4: Development of Instructions for Improvement of Ecological Status and Reduction of Ecological and Economic Risks

4. Phase 1: Ecological Assessment of Environmental Status (Water, Soil, Air) The main objectives of Phase 1 have been to obtain information on the current environmental status within each of the 12 facilities Phase 1 has been divided in the following Work Packages (WP):  WP 1: Acquisition of existing data  WP 2: Site Surveys at each facilities  WP 3: Data Gap Analysis  WP 4: Site Investigations (Soil and Groundwater)  WP 5: Evaluation of the present Environmental Status for each Facility

5. Phase 2: Assessment of Potential Environmental Risks Phase 2 has relied on the results of Phase 1 and has evaluated, for each facility, the risks associated with: impacts on subsoil and groundwater quality due to the presence of chemical substances possible exceedances of the legislation limits for wastewater possible obligations related to remediation and/or clean-up needs possible law breaching on environmental protection due to the activity of the facilities and the need of paying fees and fines Recommended corrective actions, based on local legislation and best international practice, have been outlined in the final reports

6. Phase 3: Assessment of Facility Ecological Management System Phase 3 has evaluated the compliance between the law requirements and the present ecological and environmental management system This project Phase has been based on: data on facilities and current environmental management systems provided by the Client Serbian Environmental Legislation outcomes of the field survey (Phase 1) This project Phase has delivered: An overview of local and international legislative requirements for soil, groundwater, wastewater, etc; An evaluation of the Ecological Management System in place for each facility with respect to the above regulations

7. Phase 4: Development of Instructions for Improvement of Ecological Status and Reduction of Environmental Liabilities Phase 4 has developed general corrective actions to: improve the ecological and environmental status at each facility Reduce the potential environmental liabilities identified in Phases 3 and 4 This Phase has delivered: a list of site-specific priority corrective actions to be implemented in the short/medium/long term period to reduce the environmental risks

8. Results: Overview The project has targeted the following four components for each facility Soil and Groundwater Wastewater Air Environmental Management For each component the following activities have been developed: Analysis of the environmental status Identification of the potential risks Identification of existing or potential law breakings Proposed corrective actions

9. Soil and Groundwater International Approach C SOIL/GW > C LIM Calculation of Site-specific Target Levels (SSTL) through Human Health Risk Assessment C SOIL/GW > SSTL Remediation / Mitigation Action The approach followed for the evaluation of the current state of soil and groundwater considered both the International regulations/best practices and the new Serbian law for soil and groundwater quality monitoring, risk assessment and preparation of remediation programs (Official Gazette RS No. 88/2010) (DIV and Italian Standards)

10. Soil and Groundwater The approach followed for the evaluation of the current state of soil and groundwater considered both the International regulations/best practices and the new Serbian law for soil and groundwater quality monitoring, risk assessment and preparation of remediation programs (Official Gazette RS No. 88/2010) RS Law for Soil and GW (2010) Approach C SOIL > Limit Value Remediation Program C SOIL/GW > Remediation Value Volume > 25 m 3 (soil) / 100 m 3 (GW) Remediation Project

11. Soil and Groundwater Soil and GW Sampling - General Strategy Soil (surficial and subsoil) Boreholes were performed at each identified potential pollution source Boreholes were drilled up to GW level One soil sample was collected at the bottom of each boring Surficial soil samples were collected at the waste storage areas Collected soil samples were analyzed for 8 metals, TPH, Aliphatic Aromatic Split, BTEX, Chlorinated Hydrocarbons, PAH, MTBE, cyanide, fluoride and other anions Analytical results compared with local and international limit values Ground Water Where not available, GW monitoring wells were installed GW samples were collected at each facility Collected GW samples were analyzed for 8 metals, TPH, Aliphatic Aromatic Split, BTEX, Chlorinated Hydrocarbons, PAH, MTBE, cyanide, fluoride, nitrite, sulphates Analytical results compared with local and international limit values

12. Soil and Groundwater Soil and GW Sampling Activities

13. Soil and Groundwater Current state of soil and groundwater (International Standards) Soil Diffuse exceedances of heavy metals (Hg at Pancevo Refinery, Pb at all minor Facilities), cyanides (especially at minor Facilities) and organics (Total Petroleum Hydrocarbons [TPH] and benzene, especially at the two refineries) Surficial Soil Diffuse exceedances of Pb (all Facilities) and benzene (two refineries) Groundwater Diffuse heavy metals contamination (Pb, Zn, As) Some exceedances for organics (TPH, BTEX, and benzene)

15. Soil and Groundwater HHRA Results (Potential Risks – International Approach) Heavy metals (both in surface and subsurface soil) resulted in no risk for on-site workers / off-site residential receptors Risk for on-site inhalation was calculated only for benzene and light TPH fractions in soil at the two refineries and for Hg at Pancevo refinery The estimation of the volume of contaminated soil was possible only at a preliminary (very conservative) level Risk for potential groundwater receptors was calculated considering the soil-leaching-to-groundwater pathway for benzene and light TPH fractions Groundwater contamination exceeded target levels for down gradient receptor protection at almost all Facilities

16. Soil and Groundwater Mitigation Actions (International Approach) With the exception of the two refineries, “cutting” the groundwater exposure pathway would allow excluding the remediation need at any Facility (no need for remediation intervention on soil) With reference to organic contamination at the two refineries, several techniques can be proposed, ranging from in situ bioremediation/bioventing or on-site/in situ thermal desorption for organics to on-site stabilization/solidification for mercury Further detailed site characterization (i.e. Remediation Program) is needed to: better defining the extension and depth of the contamination sources for each contaminant identified and develop a detailed HHRA develop a detailed remediation design

17. Soil and Groundwater Proposed Mitigation Actions for Groundwater Hydraulic Barrier (Pump & Treat System) Steel Sheet Piling (in case of river/canal presence) + Drainage Trench Considering that the contamination levels detected during the last sampling campaign do not show evidence of high/diffused contamination, the barrier/trench should be installed within the short- term period and tested on a regular basis, but it could be operated only when the contamination plume will reach the barrier/trench line

18. Soil and Groundwater Current state of soil and groundwater (Serbian Standards) Soil Diffuse exceedances of heavy metals (Hg and Ni at Pancevo Refinery, Pb at minor Facilities), cyanides (especially at minor Facilities) and benzene, (at the two refineries and TNG) Surface Soil Diffuse exceedances of Pb (all Facilities) and benzene (two refineries) Groundwater Diffuse Zn contamination at all Facilities Some exceedances for Pb (Smederevo and Belgrade TF), BTEX (Pancevo) and TPH (Zrenjanin SC Maintenance)

19. Soil and Groundwater Mitigation Actions (RS Law Approach) Soil Several exceedances of the Limit Values Some exceedances of the Remediation Values potentially involving volumes higher than 25 m 3 of soil Further detailed site characterization (i.e. Remediation Program development and implementation) is needed to: better defining the volume of the contamination developing a detailed remediation design (if needed) Groundwater Some exceedances of the Limit Values and few exceedances of the Remediation Values (however potentially involving volumes higher than 100 m 3 of aquifer) Further detailed site characterization is needed to better define the groundwater contamination presence, where confirmed, to define the plume dimensions

20. Wastewater WW and SW Management Approach Identification of WW issues Identification of potential environmental risks Identification of the most time-cost-benefit solution to be implemented Cost of the proposed corrective actions Prioritization of the identified solutions

21. Wastewater Main Regulatory Drivers Law on Environmental Protection (Official Gazette RS No. 135/04) Limits values for discharge of wastewater into surficial water bodies are based on prescribed quality indicators for a recipient category All water streams in Serbia are categorized in classes according to the level of their pollution (Decree on Water Classification, Official Gazette No. 6/78) The Decree specifies for each class, parameters and relevant limit values Limit values for the discharge into sewage system are defined by local Authorities in appropriate regulatory document

22. Wastewater Current Status of the Sites and Potential Risks WW and SW Drainage Systems not present or found in poor condition; potential leakages can infiltrate and contaminate the soil Waste Storage Areas: several outdoor storage areas with no containment; potential cross-contamination of SW runoff Storage Tank Areas unpaved and not provided with any drainage system to collect SW and possible spills; SW infiltrates the soil and potential oil spills or leakages can contaminate the ground WW Discharge: Absence of treatment devices upstream the WW discharge point; possible exceedances of the legislation limits for wastewater discharge can lead to the payment of fines ranging from 150,000 to 3,000,000 dinars, according to the Law on Environmental Protection (Official Gazette RS No. 135/2004, Art. 116)

23. Wastewater Proposed Corrective Actions WW and SW Drainage Systems Installation of new pipeline network Replacement of existing pipe network Segregation of SW runoff according to source and quality Waste Storage Areas Installation of roof to cover the storage area to limit/prevent runoff Installation of a containment (concrete curbs on the sides) Paving the roofed area

24. Wastewater Proposed Corrective Actions Storage Tank Areas Paving the storage tank area Installation of drainage system Installation of safety valve Installation of oil water separator

25. Wastewater Proposed Corrective Actions WW Discharge On site infiltration through Low Impact Development (LID) Systems (Foundation Planters, Bioretention Areas) Off-site discharge to external ditch or municipal sewage system (permitting and discharge quality monitoring)

26. Wastewater Prioritization of the Identified Solutions The ranking was based on: Engineering evaluations of constructability, operation and management (O&M) requirements Land use and site accessibility Technical Criteria Regulatory Costs Sustainability of proposed solutions

27. Air - What was checked? Review of the local and international legislation framework Site-specific analyses have been conducted

28. Air – Overall Outcomes Annual monitoring plan incomplete and inadequate purpose of the measurements locations of sampling schedule of sampling (production/process state, meteorological conditions, season) results interpretation Legal obligation to implement regular air emission monitoring not met in some cases Air emissions of some parameters above limit values

29. Air - Outcomes SITE SPECIFIC: Pančevo Refinery

30. Air - Outcomes CURRENT SITUATION – SITE SPECIFIC: Pančevo Refinery Storage area in 2010

31. Air - Outcomes CURRENT SITUATION – SITE SPECIFIC: Pančevo Refinery Some of the results of stack measurements

32. Air - Outcomes SITE SPECIFIC: Service complex Zrenjanin – Maintenance section no monitoring plan for air emission two stacks foreseen for measurement after construction is done air quality measurement done in 2010

33. Air - Risks and mitigation options 1. Set up a new site-specific monitoring plan/program to allow monitoring of: air emission in normal operation air emission in process deviation, incident situation and possible accidents compliance with the new regulation 2. Set up a new site-specific monitoring plan/program that will, as self standing, public document, define: the purpose of the measurements (legal compliance has not to be the key purpose) precise locations of sampling (by measurement points not only by type of emitter) Schedule of sampling (production/process state) meteorological conditions, season analytical method approach to results interpretation

34. Air - Risks and mitigation options 3. Set up Integrated System for Environmental and System Risks Monitoring to avoid wrong priorities in environmental monitoring Overlooking of new trends and critical monitored/measured values GIS supported system of environmental hazard monitoring including: Database of stored hazardous substances (according to REACH and GHS) Influence/impact zones Environmental measurement/monitoring Integrated data management Integrated documents management Analysis management

35. Air - Risks and mitigation options 4. Conduct detail analysis and select solutions for actual emission in the air exceeding limit values Pancevo Refinery, Novi Sad Refinery 5. Conduct measurements as required by actual regulation and in accordance to the monitoring plan, existing tank farms (Smederevo, Belgrade) petrol stations (Zmaj 1, Novi Sad 1, Elemir Refinery) 6. Review identification of emission sources in the air and amend monitoring plans

36. Env. Management - Corporate & Branch EMS: EXISTING SITUATION NIS and NIS Petrol are not ISO14000 certified NIS has a general EHS policy and a wide number of procedures, but lacks a general Environmental Management System (EMS) NIS Petrol has not a company-wide integrated EMS NIS Petrol has a series of documents and procedures that regulate the facility operations but these are not formally structured

37. Env. Management - Corporate & Branch EMS: EXISTING SITUATION NAFTAGAS, has implemented a fully developed integrated EMS in accordance with ISO 14000 The EMS includes all the major components, from the company policy and the main EHS general procedures to site-specific standard operation procedures Evidences of implementation of NAFTAGAS policies and procedures are found at the facilities Little personnel is responsible to oversee and coordinate E- management at a huge number of facilities

38. Env. Management - Waste Management Waste Management: EXISTING SITUATION NAFTAGAS facilities produce few waste streams, especially oily waste, and have developed WMPs that are adequately implemented A couple of small facilities produce very little waste and do not require any WMP (Pump Stations) Some facilities, like Tank Farms and TNG-NS, produce few waste streams, mainly oily waste. At these facilities, no relevant issues are present, although a structured WMP is missing and Waste management is based on a number of policies and procedure yet to be properly structured

39. Env. Management - Waste Management Waste Management: EXISTING SITUATION Major facilities, like PAR and NSR, produce several waste streams, handle waste on the basis of different procedures, and have not yet a WMP These facilities store huge amounts of undifferentiated and differentiate waste (including historical waste) A general issue common to all the sites, is the lack of a proper solution for disposal of oil sludge or contaminated soil in Serbia. Huge amounts of this waste are stored at some sites (OS Kikinda, PAR, NSR)

40. Env. Management – General Env. Issues General Environmental Issues Many Waste or Hazardous Material Storage areas are not roofed/paved or do not have secondary containment Several Aboveground Storage Tanks have earthy secondary containment and the base is not paved Oil sludge, oil waste and HW in general stored in earthy pits, or concrete pits with potential cracks Underground Storage Tanks for fuel or waste oil are old, single- walled, do not have leakage detection systems Reportedly buried flowlines might have licks or cracks since seldom or never checked, especially in facilities bombed in 1999 Some facilities, especially Service Complexes, use to store, staple or park contaminated equipment and spares on the soil or on cracked concrete pavements

41. HW Storage Area: Unroofed, Unbermed

42. HM Storage Area: Unroofed, Unbermed

43. AST and Base Made of Discontinuous Plates

44. AST laying on an Earthy Base

45. Concrete Pit for Oil Sludge

46. Contaminated Soil, HW Stored in a Pit

47. Earthy Pit for Oil Sludge ad Oil Waste

48. UST for Oil Waste

49. Contaminated Material on earthy/cracked surface

50. Buried Pipes and Flow Lines

51. E Management at the Facilities Suggested Corrective Actions include: Establish an EMS at corporate, branch and facility level Supplement the EMS with site-specific WMPs, where missing. Main issues to be covered are: Waste labeling Identification of adequate storage areas Waste amounts Waste classification Waste segregation options Reporting schemes Management of special waste flows (batteries, PCB, Oil sludge, etc) Increase the number of personnel to oversee E-management Certify corporate, branch and facilities

52. E Management at the Facilities Suggested Corrective Actions include: Find adequate end solutions for special waste flows (Es Kikinda) and historical waste (PAR, NSR) Improve hazardous material storage areas (roof, berm, pavement) Check integrity of buried flow lines (video inspection, pigging, pressure tests, etc) Check integrity/revamp of UST, discontinue when heavily damaged, install monitoring wells Ensure proper secondary containment for AST Discontinue storing contaminated material on soil or unpaved surfaces

53. THANKS FOR YOUR ATTENTION