Environmental Management Plan (EMP)
The EMP presented in this report is a framework EMP for maintaining the identified impacts to Low level. The mitigation measures for management of various environmental releases, and storage and handling of hazardous materials during the construction and operation phases are discussed in the report, and reproduced below in Table 1 and Table 2.
Table 1: Mitigation Measure for Construction Phase
AIR QUALITY MANAGEMENT |
Gaseous Emission |
- Standard construction equipment and vehicles will be procured and utilised.
- All equipment and vehicles will be periodically maintained and repaired in order to minimize emissions including engine tuning, filter cleaning etc.
- Vehicles and equipment that fail to meet emission limits and standards will not be operated / used until adequate servicing, testing and maintenance has been conducted. EPC contractor will maintain records of equipment maintenance and repairs.
- Equipment exhaust will be directed upwards wherever possible.
- Idling of vehicles and equipment will not be permitted. Where appropriate, electrically powered equipment will be used instead of gasoline or diesel powered equipment.
- All hazardous materials including chemicals, paints, cleaning agents, solvents and solvent containing products will be adequately sealed in labelled containers at the end of each day by the contractor. After sealing the materials, all containers will be stored in contained areas (i.e. 110 % containment).
- In case of onsite storage of fuel oil, fixed roof tanks or alternatively adequately designed fuel dispensing tankers will be provided.
- Tanks and fittings will be periodically inspected to eliminate leaks.
- Dedicated and enclosed painting booths and fabrication yards will be provided.
- Adequate PPEs will be provided to workers to reduce inhalation of toxic fumes.
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Dust Emission |
- Site clearing will be minimised. Removal of topsoil at any one time will be limited to that necessary to provide for construction.
- No deliberate burning of waste materials will be allowed.
- All vehicles carrying fine materials will be covered to avoid spillage and wind disturbance of materials. Covers will be maintained in good condition, free of any excessive tears.
- All vehicles will strictly adhere to speed limits on seal roads or access ways.
- EPC contractor will take precautions like water sprinkling of un-surfaced areas, excavations etc. to reduce the dust levels as required.
- EPC contractor will pave the access road to the site to minimise the amount of dust generated by truck movements entering and leaving the site.
- Progressive rehabilitation of disturbed areas will be carried out throughout the construction period where practicable.
- Height of the stockpiles will be maintained at a 2:1 slope, compacted as necessary, at designated areas only.
- Training of sub-contractors and employees will include dust reduction measures.
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TERRESTRIAL ECOLOGY |
- Top soil (8-10 cm) will be preserved and re-lay after backfilling of excavated area or use for landscaping in the project site.
- Wadi channel to be rehabilitated after its shifting and training.
- Creation of similar substrate to existing one in and around the wadi will be explored to enable re-colonisation of native vegetation including endemic species like E. hadramautica and C. Chascaniflorus.
- A green belt will be created along the southern fenceline of the proposed site.
- To the extent possible, native tree species should be planted along the trained wadi channel and in the green belt. Some tree species suggested for creation of green belt include - P. cineraria, A. tortilis, Ziziphus spina-christi, Z. leucodermis, Phoenix dactylifera etc. Planting of native species will not only enhance plant diversity but it will also enhance bird diversity by attracting frugivorous birds (birds feeding on fruits). It will also impart naturalness.
- Monitoring of invasive species Prosopis juliflora: P. juliflora recolonisation within the site boundaries should be monitored and its removal program should be undertaken at regular intervals.
- Off road driving will be strictly prohibited..
In addition to the above measures, the following measures will be considered, provided they are found to be physically and commercially feasible:
- Conservation of endemic species - individuals of E. hadramautica and C. chascaniflorus could be rescued and recovered before training of wadi channel and these could reintroduced after shifting and training of wadi channel and in the green belt once suitable substrate is created.
- Conservation of native vegetation: It is most likely that after creation of suitable substrate, native species of plants will colonize the disturbed area (i.e., the trained wadi channel). However one of the effective ways of ensuring colonization by native species is broadcasting of seeds, and planting of cuttings and transplantation small herbs and shrubs. This will involve collection of propagation material (seeds, cuttings, naked seedlings etc.) within site and from its immediate surrounding before shifting and training of wadi channel.
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NOISE QUALITY MANAGEMENT |
- Equipment that complies with the applicable noise standard will only be procured and used.
- Prior to commencement of particularly noisy operations, a procedure detailing the method of work, program, predicted noise levels and manufacturers specifications for equipment and machinery, will be developed by the EPC contractor.
- All noisy equipment will be with effective silencers and noise reducing insulation as practical.
- Work practices will be adopted to avoid continuous emissions (e.g. equipment will be switched off where possible).
- Where practical, noise emissions will be controlled by the erection of acoustic shielding.
- If elevated noise levels are encountered, the source of noise will be identified and alternative methods or additional control measures will be implemented.
- Speed limit will be imposed on the site to minimize noise emissions.
- Idling of vehicles and equipment will not be permitted. Where appropriate, electrically powered equipment will be used instead of gasoline or diesel powered equipment.
- Equipment and machinery will be properly maintained to minimize noise generation.
- EPC contractor will investigate noise complaints and excesses of any agreed maximum acceptable levels immediately.
- Regular noise monitoring will be performed at site and will take into account any requirement set by regulators.
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LAND & EROSION CONTROL |
- Temporary direction signs will be placed at appropriate locations and at approved routes for access road to work strip and other work sites.
- HSE personnel at site will adequately advise the workforce through toolbox meetings and awareness programs to strictly adhere to the demarcated area. Work supervisors will be responsible for their crew to follow such restrictions.
- Material will be covered using plastic sheeting to minimise wind erosion and storm water ingress into material.
- Waste generated at site will be classified as non-hazardous waste and hazardous waste. The waste streams will be separated into the appropriate categories and stored in authorised locations for appropriate disposal.
- Internal roads carrying medium traffic and light vehicles will be gravelled to suppress dust. Whenever required appropriate dust suppression work will be undertaken.
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NOISE QUALITY MANAGEMENT |
- For the construction of drainage lines, drain surface should be rock-lined to minimize erosion.
- Immediate re-vegetation (wherever needed) following completion of works.
- Area near the wadi will be protected / reinstated in such a way that there will be no obstruction to flow of water. Preventive measures will be in place to meet emergency flooding conditions.
- After the completion of construction work, the site will be handed over to the owner in a clean and tidy manner.
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SOIL & GROUNDWATER MANAGEMENT |
- An inventory will be maintained for all potentially hazardous materials and chemicals as per manufacturer’s instructions and MSDS.
- All chemical and fuel storage will be provided with adequate containment / bunded area. Bulk Fuel will be placed in stable and contained area, lined with suitable impermeable material with a capacity of 110% of storage fuel.
- Waste skips will be closed at all times (except during emptying/collection).
- All storage areas will be inspected regularly for cracks, holes, etc.
- Onsite fuelling, vehicle or equipment washing, and maintenance will not be allowed.
- Waste management activities will be monitored to ensure no cross-contamination takes place;
- Spill kits will be made available onsite and at appropriate locations especially near bulk storage locations.
- Release of any liquid materials that can potentially infiltrate and contaminate groundwater will be prevented.
- Personnel will be trained on emergency and spill response, containment, material handling and storage procedures.
- Hydro-test water will be reused to the extent possible for multiple hydro-tests. If the used hydro-test water quality does complies with the land discharge standards prescribed in RD 115/2001 and MD 145/93, then the water may be discharged on land (sacrificial discharge, greenbelt development, dust suppression, etc.). In case of noncompliance, the hydro-test water will be collected in a lined evaporation pit.
- Sanitary wastewater from camps and offices will be collected in holding tanks for further treatment at the nearest STP in Salalah.
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WATER MANAGEMENT |
- Activity based water requirement plan will be prepared, identifying potential opportunities for minimizing water consumption. Actual consumption of water will be monitored and recorded on a monthly basis.
- Relevant water quality parameters especially for drinking purpose will be monitored on a regular basis.
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WASTE MANAGEMENT |
The purpose of this control measures are to provide effective methods for storage, collection, handling, transportation, recycling/reuse and disposal of solid wastes during the operation phase of the proposed project. The objective of the control measures are:
- To describe how the wastes materials will be managed, handled, recorded and disposed of within the applicable requirements / regulations.
- To provide guidance for the waste material management to protect human health and to minimize the impact on the receiving environment.
- To control the amount of waste generated by reducing waste at source through good operating practices and implementation of waste reduction principles. and
- To give guidance and disposal of wastes in a safe manner through hierarchical application of reuse, recycling,
recovery, treatment and final disposal in approved disposal sites.
The most important step in the whole waste management process is to assess the hazardous nature. This basic information is required to decide the appropriate waste management practices for a specific waste, and to determine its principal disposal options. Hazardous waste is defined as any waste having hazardous properties that is harmful or toxic to human health/life and/or the environment.
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Non-Hazardous Waste |
- Suitable storage areas (adequately designed and sized to protect from rains, to prevent any run offs, and to secure from any unauthorized access) will be provided for segregated collection of wastes.
- Sizing of such areas will be in accordance with the expected waste quantities and the frequency of disposal.
- The waste containers holding the waste material will be suitably labelled for easy identification of material.
- Applicable approvals will be obtained from the authorities in order to dispose the solid wastes.
- Metal scrap, wood scrap, empty containers of non-hazardous materials, packing materials, etc., will be collected, segregated and recycled to scrap dealers as feasible and the non-recyclable waste will be disposed of to an approved municipal dumpsites.
- Non-hazardous wastes will not be mixed with hazardous wastes at any time. Non-hazardous wastes suspected to be contaminated with hazardous wastes will be treated as hazardous wastes.
- Only the approved transporters will be engaged for waste transport.
- Waste manifests will be maintained as per the requirement of the regulators.
- Training, tool box talks and posters will be placed across the site for adequate waste management, awareness and communication.
- Waste monitoring will take place onsite on a regular basis to ensure that adequate waste management is implemented.
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Hazardous Waste |
- Suitable storage area (adequately designed to protect from rains and to prevent any run offs) with impervious flooring, bunds, roof and spill collection facilities as appropriate will be provided for collection and segregated storage of hazardous wastes.
- The sizing of such areas will be in accordance with the expected waste quantities and the frequency of recycling/disposal.
- The waste skips/containers holding the waste material will be properly labelled indicating the material, hazardous nature, etc.
- Contaminated soil generated due to accidental spills will be stored in a dyked and sheltered area with impervious flooring and cover to minimise blowing away by wind, run off and infiltration;
- Any spills/leaks from the waste containers onto land will be immediately remediated to minimise the potential to soil and groundwater contamination.
- Hazardous wastes will not be mixed with non-hazardous wastes at any time. Non-hazardous wastes suspected to be contaminated with hazardous wastes will be considered as hazardous wastes.
- Potential opportunities for recycle/reuse will be considered for wastes as feasible. Potential for returning to the suppliers to be explored for wastes such as unused chemicals, empty containers of hazardous materials, etc.
- Suitable PPEs will be used by workers handling hazardous wastes.
- Waste manifests for hazardous wastes will be maintained as per the requirement of the regulators.
- Only approved transporters to be used for transportation of hazardous waste materials.
- Waste monitoring will take place onsite on a regular basis to ensure that adequate waste management is implemented.
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Chemical Material |
- Items listed in the MECA banned category of chemicals will not be used.
- No chemicals and substances will be purchased unless the MSDS has been evaluated and pre-screened.
- Chemicals will be pre-screened according to the following criteria: lowest toxicity, lowest bioaccumulation potential and highest biodegradation.
- Before receiving a hazardous material, information on proper handling, storage and disposal of the material contained in MSDS must be forwarded by the supplier.
- The MSDS shall again be reviewed prior to use.
- Chemicals that can be purchased locally shall be requested on an as needed basis to avoid unnecessary storage.
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Compressed Gas Cylinder |
- Protective caps will be placed over the cylinder valves when not in use or when being transported.
- Compressed gas cylinders will be kept away from heat, fire, molten metal, or electrical lines, and not transported by mobile cranes unless a special carrier is used.
- Compressed gas cylinders will be stored in upright position. If stored outside a covered area, then well ventilated areas will be provided.
- Liquid compressed gas cylinders will never be used in a horizontal position, as the liquid may be forced out through the hose causing a fire hazard or explosion.
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Table 2: Mitigation Measures for Operation Phase
AIR QUALITY MANAGEMENT |
- Air emissions from point sources will meet all the national and international standards identified in Chapter 2 of this report.
- Adequate stack heights will be ensured for proper dispersion of pollutants and compliance with applicable regulations.
- PEMS will be installed on the flares to ensure compliance of the emissions with standard limits prescribed for primary pollutants in MD 118/2004 (PEMS will be used in the plant since continuous emission monitoring system (CEMS) cannot be used for flares, and there are no other combustion sources apart from the flares in the Ammonia Plant).
- Engineering control measures will be incorporated in the design for eliminating potential upset scenarios.
- Appropriate operating / storage conditions will be maintained in order to minimise emergency releases through flaring.
- Detailed 'Emergency Response Plan (ERP)' will be prepared, including procedures to reduce the upset conditions to the shortest period practicable.
- Number of fittings will be optimized to reduce the fugitive emissions.
- Ammonia storage tank will be equipped with refrigeration system and dedicated backup flare system to mitigate any chance of ammonia emissions.
- Regular monitoring and maintenance of all equipment, generators, and flares will occur as part of the environmental monitoring plan. This would ensure that any emission excess is noticed, and then mitigation measures are put in place until the appropriate criteria are met. Mitigation could include process shut down.
- Besides point source monitoring, regular ambient air quality monitoring will be carried out in specific locations (selected in accordance with the dispersion model).
- Dry gas compressor seals will be used where there is proven experience in their operation.
- Tanks and elevated structures will be fitted with warning lights to comply with air and safety navigation regulations, if required.
- Appropriate engineering control procedure will be adopted to detect the leaks in the liquid ammonia export line from the Ammonia Plant to POS. The mechanism and the technology for such control are presented in Appendix 7 of this report.
- Regular maintenance will be scheduled for equipment and vehicles as per the manufacturer condition.
- Operators will be trained on the environmental requirements.
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NOISE QUALITY MANAGEMENT |
- Regular maintenance of equipment in accordance with manufacturer's instructions will be carried out to reduce the risk of increased noise emissions from worn or poorly maintained parts.
- Equipment with noise levels not more than 85 dB(A) at 1 m distance from them will only be used.
- Noise mapping will be undertaken to delineate the high noise areas. Noise mapping will be updated annually.
- High noise warning signs to be displayed in areas where noise level is likely to exceed 85 dB(A).
- Personnel working in the vicinity of noise source having noise level higher than 85 dB(A) will be provided with ear protective equipment. Use of such PPEs will be made mandatory in high noise areas.
- In areas where excessive noise may occur, noise countermeasures will be considered, such as insulation as practical.
- A regular program for noise monitoring (along the site boundary) will be carried out to ensure that the public noise limit is not exceeded.
- Pipe acoustic insulation will be applied, where excessive piping noise is expected. Where insulation is provided, pipe supports will include vibration isolation pads.
- Compressors and generators will be fitted with acoustic enclosures with low noise ventilation systems, fire and gas detection and fire extinguishing systems, as practical.
- Large pump sets will be fitted with "dog house" style acoustic enclosures, if necessary. Standard pumps and motors will meet the required noise levels.
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MARINE WATER MANAGEMENT |
- Cooling tower blowdown stream will be monitored prior to discharge into the Methanol Plant sweater outfall system in order to ensure compliance with applicable marine discharge standards stipulated in MD 159/2005.
- Effective operation and maintenance for bio-fouling control will be practiced.
- Overdosing of toxic chemicals will be avoided.
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WATER & WASTEWATER MANAGEMENT |
- Activity based water requirement plan will be prepared, identifying potential opportunities for minimizing water consumption. Actual consumption of water will be monitored and recorded on a monthly basis.
- Relevant water quality parameters especially for drinking purpose will be monitored on a regular basis.
- Release of any liquid materials that can potentially infiltrate and contaminate groundwater will be prevented.
- Adequate control of any subsurface pipelines (such as freshwater, sewage, etc.) will be ensured in order to prevent any accidental or potential leakage locally.
- A check-up and prompt reporting system will be followed to ensure the concrete structures in the facility are intact and to allow quick intervention in case of need.
- Regular site inspection system will be implemented that includes spill control and pollution prevention procedures for handling and storage of chemicals.
- The presence of readily available emergency spill response kits will be ensured to secure immediate intervention in case of need.
- All personnel operating on the site will have personal protective equipment ready and available for immediate use in case of emergency in order to reduce impacts to human health.
- Strict application of a labelling system (including all needed data of contents, including hazardous or potentially contaminative components) will be followed to identify the containers.
- Condensate blow-down from the ASU, process boiler system and cooling water system will be steam-stripped to remove any ammonia. The stripped vapour will be flared. The liquids will be passed through the effluent treatment system of the Methanol Plant and then used for irrigating the green belt.
- Wastewater from drainage of liquid NH3 bearing vessels, pumps and piping systems will be collected in a collection tank tied to the flare system. The liquid ammonia in the collection tank will be vaporised by low pressure steam.
- A portable water scrubbing system will be provided for the wastewater during depressurization of the product pipeline.
- Water used for clean-up of spills, washings, fire events, etc. from process and utility areas Will be appropriately treated to comply with standards specified in RD 115/2001 and MD 145/93 and then discharged.
- Storm water from the plant area will be routed to the storm water drainage network such that it does not come in contact with contaminated water stream or area.
- Domestic wastewater from the Ammonia Plant will be routed to the Methanol Plant effluent treatment plant.
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WASTE MANAGEMENT PLAN - Same as the measures during construction phase (refer Table 1). |
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