Environmental and Social

ANNEX A

ENVIRONMENTAL AND SOCIAL GUIDELINES

A-1: INTERNATIONAL ENVIRONMENTAL AND SOCIAL GUIDELINES

A-2: SUPPLEMENTAL GUIDELINES FOR HIGH CARBON INTENSITY PROJECTS

IMPORTANT: Please click here to see important updates to revised Annex A-2

A-3: GUIDELINES APPLICABLE TO PROJECTS IN THE NUCLEAR SECTOR

ANNEX A-1: INTERNATIONAL ENVIRONMENTAL AND SOCIAL GUIDELINES

1: General

The international guidelines applicable to projects financed by Ex-Im Bank are as follows:

For Private Sector Projects
The default international guidelines applicable to private sector projects, those with financing structured as limited recourse project finance or corporate risk, are the International Finance Corporation's (IFC) Performance Standards on Social & Environmental Sustainability (IFC Performance Standards), effective January 1, 2012, and the Environmental Health and Safety (EHS) Guidelines of the World Bank Group.

For Public Sector Projects (Sovereign Risk)
Ex-Im Bank encourages sovereign foreign buyers to apply the IFC Performance Standards and the EHS Guidelines of the World Bank Group to the construction and operation of projects. Alternatively, should a sovereign foreign buyer opt instead to apply the ten Environmental Safeguard Policies of the World Bank with the applicable EHS Guidelines of the World Bank Group, Ex-Im Bank will require supplemental information about the project's environmental and social impacts that may be needed to meet the requirements of the IFC Performance Standards.

For Projects co-financed with Multilateral Development Banks:
For those projects in which the European Bank for Reconstruction and Development (EBRD), the African Development Bank, the Asian Development Bank or the Inter-American Development Bank are involved, Ex-Im Bank may apply the guidelines, in whole or in part, of the respective Multilateral Development Bank (MDB) to the project. In the case of conflict between the MDB guidelines or gaps in the MDB requirements with applicable IFC Performance Standards and EHS Guidelines of the World Bank Group, the more stringent guidelines will apply as determined by Ex-Im Bank's E&E Division.

2: Fundamental Elements of Environmental and Social Reviews of Projects

The following ten elements illustrate the objectives and scope of Ex-Im Bank's Environmental Guidelines that are set forth in the IFC Performance Standards and the EHS Guidelines of the World Bank Group. Attention to these elements can help project participants to establish the environmental and social framework required for compliance with the applicable international standards and guidelines. Assessment and management of risks and impacts should follow the IFC's mitigation hierarchy to anticipate and avoid, or where avoidance is not possible, minimize, and where residual impacts remain, compensate/offset.

Air Quality. Protect air quality through best appropriate technologies and good practices by controlling or reducing air emissions to the quantitative limits set forth in the applicable international guidelines.
Water Use and Quality. Protect fresh, marine and groundwater resources from project-related over-demand and contamination through the efficient use of water and through the use of methods to control and treat project effluent discharges to quantitative limits set forth in the applicable international guidelines.
Waste Management. Management, recycling, storage, treatment and disposal of solid, hazardous and toxic materials and wastes, in accordance with provisions of the applicable international guidelines.
Natural and Manmade Hazards. Design and locate the project so as to reduce environmental and social risks from natural hazards, such as earthquakes, landslides and severe meteorological events, and manmade hazards such as hazardous waste spills and toxic emissions, in accordance with provisions of the applicable international guidelines.
Biodiversity. Protect ecological resources and biodiversity, encourage conservation, and support the protection and restoration of critical natural habitats containing threatened, endangered and rare species, in accordance with the provisions of the applicable international guidelines.
Involuntary Resettlement, Indigenous Peoples, Cultural Property. Develop the project to reduce or mitigate the effects of involuntary resettlement, adverse impacts to indigenous peoples and adverse impact to cultural property in accordance with the provisions of the applicable international guidelines.
Noise. Control and reduce the level of noise from projects to quantitative limits set forth in applicable international guidelines.
Protection of Workers. Establish controls to promote safe working conditions, the fair treatment of workers and to address child and forced labor situations in accordance with host country labor and employment laws and provisions of the applicable international guidelines.
Community Health and Safety. Establish measures and plans to avoid or minimize adverse project-related impacts on the health, safety and security of the local communities during the construction and operation of the project, in accordance with applicable international guidelines.
Global Climate. Promote measures to reduce the emission of carbon dioxide and other greenhouse gases that impact global climate.

3: Ex-Im Bank Requirements

All projects classified as Category A require the preparation and submission to Ex-Im Bank of a complete Environmental and Social Impact Assessment (ESIA) consistent with the information requirements set forth in the eight IFC Performance Standards on Environmental and Social Sustainability as revised in January 2012 and as described in Annex E. Information contained in the ESIA together with Environmental and Social Management Plans (ESMP), and/or Action Plans, should demonstrate the project's level of compliance to all of the applicable IFC Performance Standards and EHS Guidelines.

For projects classified as Category B, which include expansion projects having material changes in output or function, preparation of an ESIA is not required. Category B project risks and impacts are generally narrower in scope than those of Category A projects and are site specific in nature. Few of these impacts are irreversible, and readily identifiable measures exist to mitigate risks and impacts. For Category B projects, information is required to identify the level of risks and impacts, and proposed measures to reduce or mitigate identified impacts, consistent with the requirements of the IFC Performance Standards and EHS Guidelines of the World Bank Group.

In the case of existing projects undergoing no material change in output or function, but which are known to have significant risks and impacts, Ex-Im Bank may require information as to the measures employed to reduce or mitigate the project's impacts, consistent with applicable EHS Guidelines of the World Bank Group (and host country standards).

When Ex-Im Bank identifies an operational link or facility associated with a project and determines that information on the risks and impacts of the identified facility need to be included within the scope of the project's environmental review, it will inform the project as to the need for environmental information related to the associated facility or operations, and the guidelines applicable to the associated operations or facility.

4: The IFC Performance Standards on Environmental and Social Sustainability

The IFC Performance Standards, as revised in January 2012, provide project participants with instruments to structure, design, construct and manage the operations of projects in an environmentally and socially acceptable manner, while identifying measures to avoid or mitigate adverse impacts resulting from the projects. These Performance Standards are intended to focus on outcomes rather than process, thereby stressing the implementation of sound environmental and social management systems that achieve desired outcomes, including the mitigation of adverse impacts. There are eight IFC Performance Standards, listed as follows:

PS-1: Assessment and Management of Environmental andSocial 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 & Sustainable Managementof Living Natural Resources
PS-7: Indigenous Peoples
PS-8: Cultural Heritage

Copies of the full text of the IFC Performance Standards, including the related "guidance notes," are available from Ex-Im Bank, the IFC, or they can be downloaded at: http://www.ifc.org/performancestandards.

PS-1 establishes the importance of (i) integrated assessment to identify the environmental and social impacts, risks, and opportunities of projects; (ii) effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them; and (iii) the client's management of environmental and social performance throughout the life of the project. Performance Standards 2 through 8 establish objectives and requirements to avoid, minimize, and where residual impacts remain, to compensate/offset for risks and impacts to workers, Affected Communities, and the environment. While all relevant environmental and social risks and potential impacts should be considered as part of the assessment, PS-2 through PS-8 describe potential environmental and social risks and impacts that require particular attention. Where environmental or social risks and impacts are identified, the client is required to manage them through its Environmental and Social Management System (ESMS) consistent with PS-1.

PS-1 applies to all projects that have environmental and social risks and impacts. Depending on project circumstances, other Performance Standards may apply as well. The Performance Standards should be read together and cross-referenced as needed. The requirements section of each Performance Standard applies to all activities financed under the project, unless otherwise noted in the specific limitations described in each paragraph. Project sponsors are encouraged to apply the ESMS developed under PS-1 to all their project activities, regardless of financing source. A number of cross-cutting topics such as climate change, gender, human rights, and water, are addressed across multiple Performance Standards. In addition to meeting the requirements under the Performance Standards, projects must comply with applicable national law, including those laws implementing host country obligations under international law.

5: The Environmental, Health and Safety Guidelines of the World Bank Group

The World Bank Group EHS Guidelines supplement the IFC Performance Standards. They provide technical reference documents with general and industry-specific examples of good international industry practices as defined in the IFC's PS-3, on Resource Efficiency and Pollution Prevention. The EHS Guidelines can be downloaded at: World Bank Group Environmental, Health and Safety Guidelines

The EHS Guidelines contain environmental performance levels and measures for projects in the various industrial sectors that are considered to be achievable in new facilities at reasonable costs using existing technology. The ESIA process may recommend alternative levels or measures to reduce risks and impacts, which Ex-Im Bank may require the project to adopt. When host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever is more stringent. If less stringent levels or measures are proposed in view of project circumstances, a full and detailed justification for the proposed alternatives is required as part of the site-specific environmental assessment, demonstrating that selection of the alternative performance level is protective of human health and the environment.

Ex-Im Bank's Engineering & Environment Division will determine the appropriate application of the EHS Guidelines to a particular project in consultation with the project sponsors. The following is a list of the EHS Guidelines.

General EHS Guidelines

The General EHS Guidelines contain information on cross-cutting environmental, health, and safety issues potentially applicable to all industry sectors. They are designed to be used together with the relevant industry sector guideline(s) that are listed below.

1. Environmental (air emissions and ambient air quality, energy conservation, wastewater and ambient water quality, water conservation, hazardous materials management, waste management, noise, contaminated land.)

2. Occupational Health and Safety (general facility design & operation, communications & training, physical hazards, chemical hazards, biological hazards, radiological hazards, personal protective equipment, special hazard environments, monitoring, etc.)

3. Community Health and Safety (water quality and availability, structural safety of project infrastructure, life and fire safety, traffic safety, transport of hazardous materials, disease prevention, emergency preparedness & response, etc.)

4. Construction and Decommissioning (environment, occupational health & safety, community health & safety)

Industry Sector Guidelines

Forestry

Board and Particle-based Products
Sawmilling and Wood-based Products
Forest Harvesting Operations
Pulp and Paper Mills

Agribusiness/Food Production

Mammalian Livestock Production
Poultry Production
Plantation Crop Production
Annual Crop Production
Aquaculture
Sugar Manufacturing
Vegetable Oil Processing
Dairy Processing
Fish Processing
Meat Processing
Poultry Processing
Breweries
Food and Beverage Processing

General Manufacturing

Cement and Lime Manufacturing
Ceramic Tile and Sanitary Ware Manufacturing
Glass Manufacturing
Construction Materials Extraction
Textiles Manufacturing
Tanning and Leather Finishing
Semiconductors and Electronics Manufacturing
Printing
Foundries
Integrated Steel Mills
Base Metal Smelting and Refining
Metal, Plastic, Rubber Products Manufacturing

Oil and Gas

Offshore Oil and Gas Development
Onshore Oil and Gas Development
Liquefied Natural Gas (LNG) Facilities

Infrastructure

Tourism and Hospitality Development
Railways
Ports, Harbors and Terminals
Airports
Airlines
Shipping
Gas Distribution Systems
Toll Roads
Telecommunications
Crude Oil and Petroleum Product Terminals
Retail Petroleum Networks
Health Care Facilities
Waste Management Facilities
Water and Sanitation

Chemicals

Pharmaceuticals and Biotechnology Manufacturing
Coal Processing
Natural Gas Processing
Oleochemicals Manufacturing
Nitrogenous Fertilizer Manufacturing
Phosphate Fertilizer Manufacturing
Pesticides Formulation, Manufacturing and Packaging
Petroleum-based Polymers Manufacturing
Petroleum Refining
Large Volume Petroleum-based Organic Chemicals Manufacturing
Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation

Mining

Power

Wind Energy
Geothermal Power Generation
Electric Power Transmission and Distribution
Thermal Power

6: The World Bank Environmental Safeguard Policies

The World Bank Environmental Safeguard Policies apply only to public sector, sovereign risk projects which opt to apply these Safeguard Policies as opposed to the IFC Performance Standards. (Ex-Im Bank recommends that the IFC Performance Standards be applied to all projects, and notes that the International Bank for Reconstruction and Development of the World Bank has begun procedures to review and revise these Environmental Safeguard Policies.)

The World Bank's Environmental Safeguard Policies have evolved over the past 30 years to the establishment of ten formal Operational Policies (OPs) that present requirements and recommended practices to mitigate project risks and impacts. These Policies address sovereign or state-owned projects, and they provide participants of these projects with information to design, construct, operate and manage projects in an environmentally and socially acceptable manner, while describing measures to avoid or mitigate adverse risks and impacts. Following is a list of the ten World Bank Operational Policies:

OP 4.01 – Environmental Assessment
OP 4.04 – Natural Habitats
OP 4.09 – Pest Management
OP 4.10 – Indigenous Peoples
OP 4.11 – Physical Cultural Resources
OP 4.12 – Involuntary Resettlement
OP 4.36 – Forests
OP 4.37 – Safety of Dams
OP 7.50 – Projects on International Waterways
OP 7.60 – Projects in Disputed Areas

The full text of these Operational Policies is available from Ex-Im Bank, the World Bank, or they can be downloaded at: http://go.worldbank.org/WTA1ODE7T0.

When Ex-Im Bank evaluates the impacts of projects using the ten OPs and the relevant EHS Guidelines, it will require additional information from the project buyer in order to fill any gaps necessary for the project to meet the requirements set forth in the IFC Performance Standards, such as those of PS-2 (Labor and Working Conditions), those dealing with plant efficiency and greenhouse gas emissions in PS-3 (Resource Efficiency and Pollution Prevention), and certain requirements of PS-4 (Community Health, Safety and Security).

ANNEX A-2: SUPPLEMENTAL GUIDELINES FOR HIGH CARBON INTENSITY PROJECTS

UPDATE OF EXIM ENVIRONMENTAL REVIEW REQUIREMENTS under Annex A-2: Supplemental Guidelines for High Carbon Intensity Projects

Update: Pursuant to federal appropriations legislation, the Bank's Supplemental Guidelines for High Carbon Intensity Projects are currently suspended for coal-fired power plants in IDA-eligible countries. Please refer to the list of IDA-only and IDA-blend countries found at http://ida.worldbank.org/about/borrowing-countries, and EXIM Bank's Country Limitation Schedule to determine EXIM Bank's program availability in any specific country, https://www.exim.gov/tools-for-exporters/country-limitation-schedule. All other environmental reviews, guidelines and requirements remain in place.

Country Category Poorer left to Richer right

Environmental Review Requirements	IDA-only	IDA-blend	All other countries
Ex-Im Bank Environmental and Social Due Diligence Procedures and Guidelines (incorporating IFC Performance Standards (PS) per OECD Agreement and Equator Principles, as well as compliance with host country laws)	Project sponsors submit full Environmental and Social Impact Assessment (ESIA), which includes an evaluation of compliance with PS 3 (7): "Greenhouse Gases - The client will consider alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during the design and operation of the project."	Project sponsors submit full Environmental and Social Impact Assessment (ESIA), which includes an evaluation of compliance with PS 3 (7): "Greenhouse Gases - The client will consider alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during the design and operation of the project."	Project sponsors submit full Environmental and Social Impact Assessment (ESIA), which includes an evaluation of compliance with PS 3 (7): "Greenhouse Gases - The client will consider alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during the design and operation of the project."
CO2 Calculation and Reporting	Sponsors provide estimate of total project CO2 equivalent emissions and CO2 intensity (energy efficiency)	Sponsors provide estimate of total project CO2 equivalent emissions and CO2 intensity (energy efficiency)	Sponsors provide estimate of total project CO2 equivalent emissions and CO2 intensity (energy efficiency)
General	Technical engineering assessment, including use of supercritical or subcritical technologies, coal quality, etc.	Technical engineering assessment, including use of supercritical or subcritical technologies, coal quality, etc.	Technical engineering assessment, including use of supercritical or subcritical technologies, coal quality, etc.
High Carbon Project Supplemental Guidelines	Use of best appropriate technology available. Alternatives analysis demonstrating no other economically feasible alternative	Carbon Capture and Sequestration to reduce project's carbon intensity to 500 grams CO2/kWh or less	Carbon Capture and Sequestration to reduce project's carbon intensity to 500 grams CO2/kWh or less

= Requirement currently suspended.

SUPPLEMENTAL GUIDELINES FOR HIGH CARBON INTENSITY PROJECTS

Revised December 12, 2013

Under Ex-Im Bank's environmental policy, the Bank will not provide support for exports for high carbon intensity plants, except for high carbon intensity plants that (a) are located in the world's poorest countries, utilize the most efficient coal technology available and where no other economically feasible alternative exists, or (b) deploy carbon capture and sequestration (CCS), in each case, in accordance with the requirements set forth in these Supplemental Guidelines.

Scope of Supplemental Guidelines
1. The Supplemental Guidelines set forth in this Annex apply to all final applications for financing that cover exports to high carbon intensity plants (as defined below) for which construction is planned, which are undergoing construction, or which have entered into operation.
2. "High carbon intensity plant" is defined as:
  1. Any plant that uses coal as a source of fuel for the generation of power or for the production of heat, including combined heat and power (CHP) plants; or
  2. Any portion of a project that consists of a new coal-fired plant (power, heating or CHP) and a new mine developed as an integrated project by a single sponsor or owner or by affiliated sponsors/owners (often referred to as a mine-mouth coal power (and/or heat) generation plant); or
  3. Any (non-coal) fossil fuel plant (power, heating or CHP) that is expected to produce annual direct greenhouse gas (GHG) emissions equivalent to a level greater than 700 grams of carbon dioxide per kilowatt-hour of generated electricity (grams CO2/kWh) equivalent, based on its gross output, and consists of a plant unit (or units) that have a gross electric generating capacity (and/or equivalent heat production capacity) greater than 50 MW.
3. These Supplemental Guidelines do not apply to:
  1. Applications for financing covering exports either to existing coal mines or to new coal mines that are notpart of an integrated coal-fired plant project as described in I. b. (ii) above; and
  2. Applications for financing covering exports to projects (including industrial, manufacturing, natural resource extraction, chemical, refinery or material processing projects) that use the output (heat or electric power) produced (or to be produced) by a high carbon intensity plant, to the extent that no Ex-Im Bank financing is used to cover exports or local goods or services to the project's high carbon intensity plant,i.e., financing must cover only exports or local goods or services that are exclusively for the downstream part of the project, and no financing is used to cover exports to the power (or heat) generation part of the project; and
  3. Applications for financing covering exports to hybrid plants which use two generation sources, a high carbon intensity source and a renewable energy source (including coal plants using "solar boost" techniques), that have an aggregate annual carbon intensity of 500 grams CO2/Kwh or less, based on its gross output. Where the hybrid plant's aggregate annual carbon intensity exceeds 500 grams CO2/kWh, only those exports used for the renewable energy portion of the plant will be exempt from these Supplemental Guidelines; and
  4. Applications for financing covering exports to upgrade or retrofit existing high carbon intensity plants where the upgrade or retrofit to the plant does not materially extend the plant's originally designated useful life. Examples of permissible exports to upgrade or retrofit include: exports to control or reduce emissions of particulate matter, NOx, mercury or sulfur dioxide, plant controls, mechanical equipment or switchgear replacement, including nominal maintenance and operational service and replacement parts, but not boiler or turbine generator replacement.
Supplemental Guidelines for High Carbon Intensity Plants
1. Applications for financing covering exports for high carbon intensity plants that are located in the "World's Poorest Countries" as listed on Ex-Im Bank's web site, here, must be accompanied by each of the following:
  1. Information demonstrating that the high carbon intensity plant will utilize the most efficient technology available, i.e., the best appropriate technology available to the country where the plant is located, reflecting the capabilities of the country and feasible options to produce power at the most efficient level practical. All design, engineering and plant operational characteristics will be taken into account, including the plant's size and design, coal quality and characteristics, cooling system and emission controls. In the case of a retrofit or upgrade, the retrofit or upgrade must utilize the most efficient technology available as described above; and
  2. An alternatives analysis demonstrating that there are no other economically feasible alternatives to the new high carbon intensity plant. The analysis should include comparisons of the financial and economic cost of the plant with other viable sources of power and/or heat production or savings that have lower carbon intensities including renewable energy, end use efficiencies, energy transmission/distribution improvements, energy policy reforms (where applicable)or fossil fuels that produce lower levels of carbon emissions that could be an alternative to, supplement, or partial substitute for the power to be generated by the high carbon intensity plant. Economic costs should include subsidies and externalities, such as the social cost of carbon emissions, even if not quantified. The analysis should compare all technically available options to reduce or offset the plant's expected production of CO2 during its operation (including the option to deploy carbon capture and sequestration (CCS)) and take into account any current or projected costs associated with CO2 production such as fees, taxes or regulatory compliance costs. In the case of a retrofit or upgrade, the alternatives analysis should compare the plant as retrofitted or upgraded to other sources of power as described above; and
  3. An analysis of the expected level of CO2 production of the high carbon intensity plant that quantifies all direct emissions (Scope 1 emissions as defined in the Greenhouse Gas Protocolhttp://www.ghgprotocol.org/standards from the plant, including information related to the carbon content of the fuel source the plant's projected availability and its level of efficiency; and
  4. Information demonstrating the extent to which the high carbon intensity plant will align with the objectives of any applicable low carbon growth plans of the country where it is located, including any mitigation measures contemplated, as reflected by the degree to which the plant may be designed as "CCS ready" or its output supplemented by renewable energy.
2. Applications for financing covering exports to high carbon intensity plants that are notlocated in the "World's Poorest Countries" (as described above) must be deployed with a carbon capture and sequestration (CCS) system sufficient to reduce the plant's equivalent carbon intensity to a level of 500 grams CO2/kWh or less based on its gross output. The CCS system must be fully functional within one year of a new plant's commercial operation, or within one year of the completion of an upgrade or retrofit to an existing plant. In the post combustion CCS process, the CO2 from the emissions produced by the high carbon intensity plant must be separated from the emissions stream and transported to a storage site for the purpose of environmentally safe and permanent geological storage of the carbon. Alternately, a CCS system may be employed to capture and permanently store the CO2 produced by a coal gasification process, prior to the combustion of the processed gas (syngas) by the power plant, in which case the level of CCS must be sufficient to reduce the combined carbon intensity of the gasifier and the power plant to a level of 500 grams CO2/kWh or less.
Engagement of an Independent Environmental Consultant to Ex-Im Bank
The Engineering & Environment Division of Ex-Im Bank may require the engagement of an independent consultant on behalf of Ex-Im Bank, at the expense of the applicant for financing or other relevant party, among other things, to review the information submitted in connection with an application for financing under these Supplemental Guidelines. The consultant may supplement the information with additional information relevant to the plant's greenhouse gas production, as required by these Supplemental Guidelines and as otherwise requested by Ex-Im Bank, in order to aid Ex-Im Bank in its analysis of the application for financing under these Supplemental Guidelines.

ANNEX A-3; TABLE 1

ENVIRONMENTAL AND SAFETY GUIDELINES FOR NUCLEAR POWER PLANTS

I - General Environmental Review Requirements:

Ex-Im Bank's environmental review of financing applications related to commercial nuclear power plants will be conducted in accordance with International Guidelines set forth in Annex A-1, and guidelines specifically related to safety aspects of nuclear power plants.

Applications for financing of exports for new Nuclear Power Plants will be classified as Environmental Category A, requiring submission of an Environmental and Social Impact Assessment (ESIA) as described in the International Guidelines set forth in Annex A-1, and the requirements of the applicable eight IFC Performance Standards on Social and Environmental Sustainability and any Environmental Health and Safety (EHS) Guidelines of the World Bank Group applicable to aspects of the overall project. The EHS Guidelines for Thermal Power Plants are the ones most relevant to Nuclear Power Projects. The Performance Standards and EHS Guidelines can be obtained from the following links:

Performance Standards (ifc.org)

Environmental, Health, and Safety Guidelines (ifc.org)

Since the IFC Performance Standards do not address the important safety aspects specific to nuclear power plants, This Annex Table sets forth the additional requirements related to plant safety and other environmentally related aspects unique to nuclear power project.

Ex-Im Bank will require appointment of an "Lender's Technical Advisor " who will assist in the Bank's technical and environmental due diligence review of the Project, and as information becomes available about the Project and its potential nuclear and non-nuclear safety and environmental effects, the scope of the Bank's information requirements may be refined.

II – Nuclear Safety Related Requirements:

Project Sponsors shall provide assurances that the nuclear facility will be designed and operated in accordance with measures for the protection of people and the environment from harmful effects of ionizing radiation These measures are set forth in current versions of the IAEA Safety Standards including SF-1 "Fundamental Safety Principles", (2006) as well as the relevant IAEA General Safety Requirements (GSR) including GSR Part 1 "Governmental, Legal and Regulatory Framework for Safety", GS-R-3 "The Management System for Facilities and Activities", GSR Part 3 "Radiation Protection and the Safety of Radiation Sources" GSR Part 4 "Safety Assessment for Facilities and Activities" GSR Part 5 " Predisposal Management of Radioactive Waste", WS-R-5 "Decommissioning of Facilities and Activities Using Radioactive Material" GS-R-2 "Preparedness and Response for a Nuclear or Radiological Emergency" and the relevant Specific Safety Requirements including NS-R-3 "Site Evaluation for Nuclear Installations", SSR 2/1 "Safety of Nuclear Power Plants: Design", SSR 2/2 "Safety of Nuclear Power Plants: Commissioning and Operation" SSR 5 "Disposal of Radioactive Waste", supplemental safety guides, related documents and host country regulations. In addition, the project shall address any post-Fukushima modifications or improvements, as recommended by the IAEA, regulatory authorities of country of origin of the plant's technology, and host country governmental agencies, including the host country regulatory authorities.

1: Liability: The host country must have a regime acceptable to Ex-Im Bank governing liability for nuclear damage.

2: Nuclear Conventions and Treaties: The host country must provide a list of the applicable nuclear- related treaties and conventions, including the in-country status, to which the host country is a signatory.

3: Health and Safety Guidelines applicable to Commercial Nuclear Power Projects: The following Guidelines apply to all new and upgrades to existing projects and shall be used to review and evaluate the Project's health and safety aspects. The fundamental objective being to protect people and the environment from harmful effects of ionizing radiation, in addition to mitigating any adverse environmental impact of the project. Where specific IAEA standards or guidelines are cited, the latest version in effect at the time of financing approval shall apply.

4: Local Regulatory Structure and Authority: The host country must have an established legal code addressing nuclear regulations and environmental protection. It must have an established nuclear regulatory authority capable of developing and implementing sound licensing and, as appropriate, re-licensing procedures. The country's nuclear regulatory authority should have the independence and demonstrate the qualifications to oversee the siting, design, construction, commissioning, operation and decommissioning of the entire project to a level sufficient to ensure that all relevant safety measures and procedures are addressed and followed in accordance with IAEA's General Safety Requirements (GSR) Part 1 "Governmental, Legal and Regulatory Framework for Safety" (2010). Furthermore, the licensing process followed by the country's nuclear regulatory authority should follow the relevant General Safety Standards, relevant supplemental Safety Guides set forth by the IAEA Safety Guides, such as SSG-12 Licensing Process for Nuclear Installations (2010), GS-G-1.1 Organization and Staffing of the Regulatory Body for Nuclear Facilities (2002), GS-G-1.2 Review and Assessment of Nuclear Facilities by the Regulatory Body (2002), GS–G-1.3 "Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body" (2002), GS-G-1.4 "Documentation for Use in Regulating Nuclear Facilities" (2002) and GS-G-1.5 "Regulatory Control of Radiation Sources" (2004). Any IAEA reports on the status of the nuclear regulatory authority, such as an "Integrated Regulatory Review Service" (IRRS) assessment, shall be used to assist in the evaluation of the regulatory authority.

5: Site Selection and Evaluation Criteria: The site for a new nuclear power plant should be in compliance with IAEA Safety Requirements NS-R-3 "Site Evaluation for Nuclear Installations" (2003) and the relevant IAEA Safety Guides issued by the IAEA.

6: Plant Design Criteria: The NSSS system and relevant plant systems shall be designed, supplied and installed in accordance with all applicable IAEA and local regulatory guidelines such as IAEA Safety Standards SF-1 (2006) "Fundamental Safety Principles", General Safety Requirements GSR Part 4 (2009) "Safety Assessment for Facilities and Activities" and Specific Safety Requirements (SSR 2/1) 2012 "Safety of Nuclear Power Plants: Design", and Supplemental Safety Guides. All safety guidelines recommended by the host country regulatory authority and/or the IAEA shall be incorporated into the design of the project. If the plant consists of a standard reactor design that has been certified by the U.S. NRC, minimal information about safety guidelines associated with its design will be required, except as needed to verify any major changes to the plant's design basis resulting from site specific conditions or current safety requirements (Post Fukushima), as recommended by the IAEA, regulatory authorities of country of origin of the plant's technology, and host country governmental agencies, including the host country regulatory authorities.

7: Plant Design and Construction Procedures: The construction and management of the plant must be in accordance with the fundamental principles set forth in IAEA documents. Design procedures should include provisions for Safety Analysis Reports (Preliminary and/or Final) or equivalent study undertaken in accordance with IAEA Safety Standards and Guides on Safety Assessment and subject to the approval of the regulatory authority. Information contained in these reports, including any completed sections or preliminary versions, should be made available to Ex-Im Bank upon request. Quality Assurance (QA) and Quality Control (QC) measures and procedures shall be followed by suppliers of all applicable plant components, equipment and systems. When the fabrication of NSSS components is to be undertaken in the host country or in another country, QA/QC measures must be instituted and followed by that country's suppliers of critical plant components. All equipment and components shall adhere to applicable fabrication codes recommended by the IAEA Safety Standards as set forth in its relevant General Safety Requirement (GS-R) series, its General Safety Guides GS-G- 3.1 "Application of the Management System for Facilities and Activities" GS-G-3.5 "The Management System for Nuclear Installations". The project's design and construction must be subject to the approval of the host country's regulatory authority.

8: Plant Operation Procedures: Operation of the plant will be subject to the issuance of an operating license by the host country's nuclear regulatory authority. There must be evidence that the project has adopted or will adopt sound operating plans, which address emergency procedures, evacuation programs and waste handling approved by the regulatory authority and in accordance with applicable IAEA Standards such as IAEA Specific Safety Requirements (SSR) 2/2 "Safety of Nuclear Power Plants: Commissioning and Operation" and that there is (or will be) an adequate number of trained and qualified personnel licensed by the regulatory authority to operate the plant in a safe manner in accordance with the operating plan of the project. The project should conform to the relevant supplemental documents including but not limited to, IAEA Safety Standards NS-G-2.8 (2002), "Recruitment, Qualification, and Training for Nuclear Power Plants." Any IAEA reports on the status of the nuclear plant operating organization, such as a "Pre-operating or Operational Safety Review Team" (Pre-OSART or OSART) assessment, shall be used to assist in the evaluation of the plant operating body.

9: Spent Fuel and Radioactive Waste: A Spent Fuel and Radioactive Waste Handling, Storage and Disposal Plan which incorporates the General Safety Requirements GSR Part 5 "Predisposal Management of Radioactive Waste" (2009) and Specific Safety Requirements including SSR 5 "Disposal of Radioactive Waste" (2011) and/or any host country requirements should be prepared and approved by the country's regulatory bodies.

10: Emergency Preparedness and Response: An Emergency Preparedness and Response Plan which incorporates elements stated in Safety Requirements, GS-R-2(2002) "Preparedness and Response for a Nuclear or Radiological Emergency" and GS-G-2.1(2007) "Arrangements for Preparedness for a Nuclear or Radiological Emergency" should be prepared and approved by the country's regulatory bodies.

11: Decommissioning: The plant design and its operational procedures should incorporate elements of the IAEA Safety Standards including WS-R-5 (2006) "Decommissioning of Facilities Using Radioactive Material" and WS-G-2.1 (1999) "Decommissioning of Nuclear Power Plants and Research Reactors"

12: Environmental Monitoring Facility: An environmental monitoring facility shall be installed at or near the project site, to monitor levels of radioactivity from the plant and any effects of the plant on the environment and ecology of the region around the plant. The facility shall submit regular reports, showing the results of its monitoring activities to the regulatory authority and to the environmental authority of the country.

ANNEX A-3; TABLE 2

ENVIRONMENTAL AND SAFETY GUIDELINES APPLICABLE TO EXISTING >NUCLEAR PLANTS RECEIVING FUEL RELOADS AND RELATED EQUIPMENT

I - General Environmental Review Requirements

Ex-Im Bank's environmental review of financing applications related to existing commercial nuclear power plants receiving fuel reloads and related equipment will be conducted in accordance with International Guidelines set forth in Annex A-1, and guidelines specifically related to safety aspects of nuclear power plants

In accordance with its Environmental Procedures, applications covering the financing of exports for existing nuclear power plants will generally be classified as Environmental Category B, for which information is required to identify the level of risks and impacts, and proposed measures to reduce or mitigate identified impacts, consistent with the requirements of the IFC Performance Standards on Environmental and Social Sustainability and the EHS Guidelines of the World Bank Group. The Performance Standards and EHS Guidelines can be obtained from the following websites: http://www.ifc.org/performancestandards and
World Bank Group Environmental, Health and Safety Guidelines
Although these plants may not be undergoing any material change in output or function, they are known to have the potential for significant risks and impacts, and as such, Ex-Im Bank will review elements including the operational history of the project any potential risks and impacts related to safety aspects associated with the operations of the existing plant.

II – Nuclear Safety Related Requirements

Ex-Im will require Assurances that the nuclear facility will be designed and operated in accordance with measures for the protection of people and the environment from harmful effects of ionizing radiation These measures are set forth in current versions of the IAEA Safety Standards including SF-1 "Fundamental Safety Principles", (2006) as well as the relevant IAEA General Safety Requirements including GSR Part 1 "Governmental, Legal and Regulatory Framework for Safety, GS-R-3 "The Management System for Facilities and Activities", GSR Part 3 "Radiation Protection and the Safety of Radiation Sources" GSR Part 4 " Safety Assessment for Facilities and Activities" GSR Part 5 " Predisposal Management of Radioactive Waste", WS-R-5 "Decommissioning of Facilities and Activities Using Radioactive Material" and GS-R-2 "Preparedness and Response for a Nuclear or Radiological Emergency" and the relevant Specific Safety Requirements including SSR 2/2 "Safety of Nuclear Power Plants: Commissioning and Operation" SSR 5 "Disposal of Radioactive Waste", and relevant supplemental safety guides, related documents and host country regulations.

1: Liability: The host country must have a regime acceptable to Ex-Im Bank governing liability for nuclear damage.

2: Nuclear Conventions and Treaties: The host country must provide a list of the applicable nuclear-related treaties and conventions, including the in-country status, to which the host country is a signatory.

3: Local Regulatory Structure and Authority: The host country must have an established legal code addressing nuclear regulations and environmental protection. It must have an established nuclear regulatory authority capable of developing and implementing sound licensing and, as appropriate, re‑licensing procedures. The country's nuclear regulatory authority should have the independence and demonstrate the qualifications to oversee the siting, design, construction, commissioning, operation and decommissioning of the entire project to a level sufficient to ensure that all relevant safety measures and procedures are addressed and followed in accordance with IAEA's General Safety Requirements GSR Part 1 "Governmental, Legal and Regulatory Framework for Safety" (2010). Furthermore, the licensing process followed by the country's nuclear regulatory authority should follow the relevant General Safety Standards, relevant supplemental Safety Guides set forth by the IAEA Safety Guides, such as SSG-12 Licensing Process for Nuclear Installations (2010), GS-G-1.1 Organization and Staffing of the Regulatory Body for Nuclear Facilities (2002),GS-G-1.2 Review and Assessment of Nuclear Facilities by the Regulatory Body (2002), No. GS –G-1.3 "Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body" (2002) and GS-G-1.4 "Documentation for Use in Regulating Nuclear Facilities" (2002), GS-G-1.5 "Regulatory Control of Radiation Sources" (2004). Any IAEA reports on the status of the nuclear regulatory authority, such as an "Integrated Regulatory Review Service" (IRRS) assessment, shall be used to assist in the evaluation of the regulatory authority.

4: Spent Fuel and Radioactive Waste: A Spent Fuel and Radioactive Waste Handling, Storage and Disposal Plan which incorporates the General Safety Requirements GSR Part 5 " Predisposal Management of Radioactive Waste" (2009) and Specific Safety Requirements including SSR 5 "Disposal of Radioactive Waste" (2011) and/or any host country requirements should be prepared and approved by the country's regulatory bodies.

5: Emergency Preparedness and Response: An Emergency Preparedness and Response Plan which incorporates elements stated in Safety Requirements, GS-R-2(2002) "Preparedness and Response for a Nuclear or Radiological Emergency" and GS-G-2.1(2007) "Arrangements for Preparedness for a Nuclear or Radiological Emergency" should be prepared and approved by the country's regulatory bodies.

6: Decommissioning: The plant design and its operational procedures should incorporate elements of the IAEA Safety Standards including WS-R-5 (2006) "Decommissioning of Facilities Using Radioactive Material" and WS-G-2.1 (1999) "Decommissioning of Nuclear Power Plants and Research Reactors"

7: Environmental Monitoring Facility: An environmental monitoring facility is required at or near the project site to monitor levels of radioactivity from the facility and any effects of the facility on the environment and ecology of the region. The facility shall submit regular reports showing the results of its monitoring activities to the regulatory authority and to the environmental authority of the country.

ANNEX A-3, TABLE 3

ENVIRONMENTAL AND SAFETY GUIDELINES FOR RESEARCH REACTORS AND FACILITIES USED TO PRODUCE RADIOISOTOPES FOR MEDICAL AND OTHER PURPOSES

The following guidelines are applicable to all new projects covering the construction and installation of research reactors and facilities associated with research reactors used to produce radioisotopes for medical and other uses. Upgrades to existing reactors and facilities of this type are covered by the following guidelines where applicable.

I – General Environmental Review Requirements

Applications for financing of exports for ==s will be classified as Environmental Category A, requiring submission of an Environmental and Social Impact Assessment (ESIA) as described in the International Guidelines set forth in Annex A-1, and the requirements of the applicable eight IFC Performance Standards on Social and Environmental Sustainability and any Environmental Health and Safety (EHS) Guidelines of the World Bank Group applicable to aspects of the overall project. The Performance Standards and EHS Guidelines can be obtained from the following links:
http://www.ifc.org/performancestandards and World Bank Group Environmental, Health and Safety Guidelines

Since the IFC Performance Standards do not address the important safety aspects specific to projects in the nuclear sector, this Annex Table sets forth the additional requirements related to project safety and other environmentally related aspects unique to research reactor and facilities used to produce radioisotopes. Ex-Im Bank may require appointment of an "Lender's Technical Advisor " who will assist in the Bank's technical and environmental due diligence review of the project, and as information becomes available about the Project and its potential nuclear and non-nuclear safety and environmental effects, the scope of the Bank's information requirements may be refined.

II - Nuclear Safety Related Requirements

The following Guidelines apply to all new and existing research reactor projects or facilities to produce radioisotopes, and they will be used to evaluate the nuclear safety aspects of the project. The fundamental objective is to ensure that adequate measures are taken to protect people and the environment from the harmful effects of ionizing radiation while mitigating any adverse environmental impact of the project.

1: General Safety: Project Sponsors shall provide assurances that the nuclear facility will be designed and operated in accordance with measures for the protection of people and the environment from harmful effects of ionizing radiation. These measures are set forth in current versions of the IAEA Safety Standards including SF-1 "Fundamental Safety Principles" (2006) as well as the relevant IAEA General Safety Requirements including GSR Part 1 "Governmental, Legal and Regulatory Framework for Safety", GS-R-3 "The Management System for Facilities and Activities", GSR Part 3 "Radiation Protection and the Safety of Radiation Sources" GSR Part 4 " Safety Assessment for Facilities and Activities" GSR, Part 5 "Predisposal Management of Radioactive Waste", WS-R-5 "Decommissioning of Facilities and Activities Using Radioactive Material" and GS-R-2 "Preparedness and Response for a Nuclear or Radiological Emergency" and the relevant Specific Safety Requirements including NS-R-3 "Site Evaluation for Nuclear Installations", NS-R-4 " Safety of Research Reactors SSR 5 "Disposal of Radioactive Waste", supplemental safety guides, related documents and host country regulations. Any IAEA reports on the research reactors, such as an "Integrated Safety Assessment for Research Reactors" (INSARR) shall be used to assist in the evaluation of the plant operating body. Where specific IAEA standards or guidelines are cited, the latest version in effect at the time of financing approval shall apply

2: Liability: The host country must have a regime acceptable to Ex-Im Bank governing liability for nuclear damage.

3: Nuclear Conventions and Treaties: The host country must provide a list of the applicable nuclear-related treaties and conventions, including the in-country status, to which the host country is a signatory.

4: Local Regulatory Structure and Authority: The host country must have an established legal code addressing nuclear regulations and environmental protection. It must have an established nuclear regulatory authority capable of developing and implementing sound licensing and, as appropriate, re‑licensing procedures. The country's nuclear regulatory authority should have the independence and demonstrate the qualifications to oversee the siting, design, construction, commissioning, operation and decommissioning of the entire project to a level sufficient to ensure that all relevant safety measures and procedures are addressed and followed in accordance with IAEA's General Safety Requirements (GSR) Part 1 "Governmental, Legal and Regulatory Framework for Safety" (2010).Furthermore, the licensing process followed by the country's nuclear regulatory authority should follow the relevant General Safety Standards, relevant supplemental Safety Guides set forth by the IAEA Safety Guides, such as SSG-12 Licensing Process for Nuclear Installations (2010), GS-G-1.1 Organization and Staffing of the Regulatory Body for Nuclear Facilities (2002),GS-G-1.2 Review and Assessment of Nuclear Facilities by the Regulatory Body (2002), GS–G-1.3 "Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body" (2002), GS-G-1.4 "Documentation for Use in Regulating Nuclear Facilities" (2002) and GS-G-1.5 "Regulatory Control of Radiation Sources" (2004). Any IAEA reports on the status of the nuclear regulatory authority, such as an "Integrated Regulatory Review Service" (IRRS) assessment, shall be used to assist in the evaluation of the regulatory authority.

5: Site Selection and Evaluation Criteria: The site for a new nuclear facility should be in accordance with the relevant host country regulatory authority and/or IAEA Safety Requirements NS-R-3 "Site Evaluation for Nuclear Installations" (2003), IAEA Safety Standards NS-R-4 "Safety of Research Reactors" and the relevant IAEA Safety Guides issued by the IAEA.

6: Facility Design Criteria: The nuclear facility shall be designed and operated in accordance with measures for the protection of people and the environment from harmful effects of ionizing radiation during both normal operation and emergency procedures intended to bring the reactor to a safe shutdown mode. The facility and relevant plant systems shall be designed, supplied and installed in accordance with all applicable IAEA and local regulatory guidelines such as IAEA Safety Standards SF-1(2006) "Fundamental Safety Principles", General Safety Requirements GSR Part 4 (2009) "Safety Assessment for Facilities and Activities" and Specific Safety Requirements NS-R-4 "Safety of Research Reactors", and the relevant Safety Guides including SSG-20 (2012) "Safety Assessment for Research Reactors and Preparation of the Safety Analysis Report". All safety guidelines recommended by the host country regulatory authority and/or the IAEA shall be incorporated into the design of the project. If the plant consists of a standard reactor design that has been certified by the U.S. NRC, minimal information about safety guidelines associated with its design are required, except as needed to verify any major changes to the plant's design basis resulting from site specific conditions or current safety requirements, as recommended by the IAEA or other reputable nuclear organizations or as required by the local regulatory authority

7: Facility Design and Construction Procedures: The construction and management of the research reactor or isotope producing facility must be in accordance with the fundamental principles set forth in IAEA documents.

Quality Assurance (QA) and Quality Control (QC) measures and procedures shall be followed by suppliers of all applicable equipment and systems. When the fabrication of NSSS components is to be undertaken in the host country or in another country, QA/QC measures must be instituted and followed by that country's suppliers of critical plant components. All equipment and components shall adhere to applicable fabrication codes recommended by the IAEA Safety Standards as set forth in its relevant General Safety Requirement (GS-R) series, its General Safety Guides GS-G- 3.1 "Application of the Management System for Facilities and Activities" GS-G-3.5 "The Management System for Nuclear Installations".The project's design and construction must be subject to the approval of the host country's regulatory authority.

8: Facility Commissioning and Operation Procedures: Operation of the research reactor or isotope producing facility will be subject to the issuance of an operating license by the host country's nuclear regulatory authority. There must be evidence that the project has adopted or will adopt sound operating plans, which address emergency procedures, evacuation programs and waste handling approved by the regulatory authority and in accordance with applicable IAEA Standardssuch as IAEA Safety Guides. NS-G-4.1 "Commissioning of Research Reactors" NS-G-4.4 Operational Limits and Conditions and Operating Procedures for Research Reactors" and NS-G-4.5 "The Operating Organization ad the Recruitment, Training and Qualification of Personnel for Research Reactors" and NS-G-4.6" Radiation Protection and Radioactive Waste Management in the Design and Operation in Research Reactors.

9: Spent Fuel and Radioactive Waste: A Spent Fuel and Radioactive Waste Handling, Storage and Disposal Plan which incorporates the General Safety Requirements GSR Part 5 (2009) "Predisposal Management of Radioactive Waste" (2009) and Specific Safety Requirements including SSR 5 (2011) "Disposal of Radioactive Waste" and/or any host country requirements should be prepared and approved by the country's regulatory bodies.

12: Environmental Monitoring Facility: An environmental monitoring facility may be required at or near the project site to monitor levels of radioactivity from the facility and any effects of the facility on the environment and ecology of the region. The facility shall submit regular reports showing the results of its monitoring activities to the regulatory authority and to the environmental authority of the country.

ANNEX A-3, TABLE 4

ENVIRONMENTAL AND SAFETY GUIDELINES FOR THE HANDLING, TREATMENT, TRANSPORTATION AND STORAGE OF SPENT FUEL OR RADIOACTIVE WASTE

I - General Environmental Review Requirements

Ex-Im Bank's environmental review of financing applications related to projects involving the handling, treatment, transportation and/or storage of spent fuel or radioactive waste will be conducted in accordance with International Guidelines set forth in Annex A-1, and guidelines specifically related to the safety aspects of projects dealing with spent fuel and radioactive waste products.

Applications for financing of exports for the handling, treatment, transportation and storage of spent fuel or radioactive waste will be classified as Environmental Category A, requiring submission of an Environmental and Social Impact Assessment (ESIA) as described in the International Guidelines set forth in Annex A-1, and the requirements of the applicable eight IFC Performance Standards on Social and Environmental Sustainability and any Environmental Health and Safety (EHS) Guidelines of the World Bank Group applicable to aspects of the overall project. The Performance Standards and EHS Guidelines can be obtained from the following links:
http://www.ifc.org/performancestandards and World Bank Group Environmental, Health and Safety Guidelines

Since the IFC Performance Standards do not address the important safety aspects specific to projects in the nuclear sector, this Annex Table sets forth the additional requirements related to project safety and other environmentally related aspects unique to projects involving the handling, treatment, transport and storage of spent fuel or radioactive waste. Ex-Im Bank may require appointment of an "Lender's Technical Advisor " who will assist in the Bank's technical and environmental due diligence review of the project, and as information becomes available about the Project and its potential nuclear and non-nuclear safety and environmental effects, the scope of the Bank's information requirements may be refined.

II - Nuclear Safety Requirements

The purpose of these regulations is to establish standards of safety that provide an acceptable level of measures for the protection of people, property and the environment from harmful effects of ionizing radiation that are associated with the handling, transport or storage of radioactive material. Where specific IAEA standards or guidelines are cited, the latest version in effect at the time of financing approval shall apply.

1: General Safety: Sponsors shall provide assurances that the nuclear facility will be designed and operated in accordance with measures for the protection of people and the environment from harmful effects of ionizing radiation These measures are set forth in current versions of the IAEA Safety Standards including SF-1 "Fundamental Safety Principles", (2006) as well as the relevant IAEA General Safety Requirements including GSR Part 1 "Governmental, Legal and Regulatory Framework for Safety, GS-R-3 "The Management System for Facilities and Activities", GSR Part 3 "Radiation Protection and the Safety of Radiation Sources" GSR Part 4 " Safety Assessment for Facilities and Activities" GSR Part 5 " Predisposal Management of Radioactive Waste", WS-R-5 "Decommissioning of Facilities and Activities Using Radioactive Material" and GS-R-2 "Preparedness and Response for a Nuclear or Radiological Emergency" and the relevant Specific Safety Requirements including NS-R-3 "Site Evaluation for Nuclear Installations", SSR 5 "Disposal of Radioactive Waste", SSR-6 "Regulations for the Safe Transport of Radioactive Material", supplemental safety guides, such as TS-G 1.1 " Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material", TS-G-1.3 "Radiation Protection Programs for the Transportation of Radioactive Material" TS-G-1.4 "The Management System for the Safe Transport of Radioactive Material" and host country regulations. In addition, the project shall address any post-Fukushima modifications or improvements applicable to the project, as recommended by the IAEA, regulatory authorities of the technology's country of origin, and host country governmental agencies, including the host country regulatory authorities.

2: Liability: The host country must have a regime acceptable to Ex-Im Bank governing liability for nuclear damage.

4: Local Regulatory Structure and Authority: The host country must have an established legal code addressing nuclear regulations and environmental protection. It must have an established nuclear regulatory authority capable of developing and implementing sound licensing and, as appropriate, re‑licensing procedures. The country's nuclear regulatory authority should have the independence and demonstrate the qualifications to oversee the siting, design, construction, commissioning, operation and decommissioning of the entire project to a level sufficient to ensure that all relevant safety measures and procedures are addressed and followed in accordance with IAEA's General Safety Requirements GSR Part 1 "Governmental, Legal and Regulatory Framework for Safety" (2010). Furthermore, the licensing process followed by the country's nuclear regulatory authority should follow the relevant General Safety Standards, relevant supplemental Safety Guides set forth by the IAEA Safety Guides, such as SSG-12 Licensing Process for Nuclear Installations (2010), GS-G-1.1 Organization and Staffing of the Regulatory Body for Nuclear Facilities (2002),GS-G-1.2 Review and Assessment of Nuclear Facilities by the Regulatory Body (2002), GS–G-1.3 "Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body" (2002) and GS-G-1.4 "Documentation for Use in Regulating Nuclear Facilities" (2002), GS-G-1.5 "Regulatory Control of Radiation Sources" (2004). Any IAEA reports on the status of the nuclear regulatory authority, such as an "Integrated Regulatory Review Service" (IRRS) assessment, shall be used to assist in the evaluation of the regulatory authority.

5: Site Selection and Evaluation Criteria: The site for a new facility should be in compliance with IAEA Safety Requirements NS-R-3 "Site Evaluation for Nuclear Installations" (2003) and the relevant IAEA Safety Guides issued by the IAEA.

6: Facility Design Criteria and Safe Transport of Radioactive Material Procedures: The facility shall be designed, supplied and installed in accordance with all applicable IAEA and local regulatory guidelines such as IAEA Safety Standards SF-1(2006) "Fundamental Safety Principles", General Safety Requirements GSR Part 4 (2009) "Safety Assessment for Facilities and Activities" and Supplemental Safety Guides. The transport and storage facilities should be designed to avoid any adverse health effects on plant operators and the public during both normal and abnormal operation. Site selection and facility design shall be in accordance with relevant host country regulatory authority and/or IAEA guidelines such as IAEA Safety Standards No. WS-R-2 "Predisposal Management of Radioactive Waste, including Decommissioning" SSR-6 "Regulations for the Safe Transport of Radioactive Material" All safety guidelines recommended by the host country regulatory authority and/or the IAEA shall be incorporated into the design of the project.

7: Facility Design and Construction Procedures: The construction and management of the plant must be in accordance with the fundamental principles set forth in IAEA documents. Design procedures should include provisions for Safety Analysis Reports (Preliminary and/or Final) or equivalent study undertaken in accordance with IAEA Safety Standards and Guides on Safety Assessment and subject to the approval of the regulatory authority. Information contained in these reports, including any completed sections or preliminary versions, should be made available to Ex‑Im Bank upon request.

Quality Assurance (QA) and Quality Control (QC) measures and procedures shall be followed by suppliers of all applicable plant components, equipment and systems. QA/QC measures must be instituted and followed by that country's suppliers of critical plant components. All equipment and components shall adhere to applicable fabrication codes recommended by the IAEA Safety Standards as set forth in its relevant General Safety Requirement (GS-R) series, its General Safety Guides GS-G- 3.1 "Application of the Management System for Facilities and Activities" GS-G-3.5 "The Management System for Nuclear Installations".The project's design and construction must be subject to the approval of the host country's regulatory authority.

8: Facility Operation Procedures: Operation of the plant will be subject to the issuance of an operating license by the host country's nuclear regulatory authority. There must be evidence that the project has adopted or will adopt sound operating plans, which address emergency procedures, evacuation programs and waste handling approved by the regulatory authority and in accordance with applicable IAEA Standardssuch as IAEA Specific Safety Requirements, and that there is (or will be) an adequate number of trained and qualified personnel licensed by the regulatory authority to operate the plant in a safe manner in accordance with the operating plan of the project.

11: Environmental Monitoring Facility: For storage facilities, an environmental monitoring station shall be installed at or near the facility to monitor the levels of radioactivity from the facility and any effects, of the facility on the environment and ecology of the surrounding region. The station shall submit regular reports showing the results of its monitoring activities to the regulatory authority and the country's environmental authority.

1. World Resources Institute and World Business Council for Sustainable Development, The Greenhouse Gas Protocol Initiative, link: http://www.ghgprotocol.org/standards

International Environmental and Social Guidelines

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ANNEX A