Preliminery Ehs for Caustic Soda Plant

REPORT Preliminary Environmental, Health, and Safety Review (PEHSR)

Caustic Soda Plant – ICAD 1 Prepared for:

Al Ghaith Industries

Prepared by:

URS Corporation – Abu Dhabi 44130065 August 2011

Project Title:

Caustic Soda Plant – ICAD 1

Report Title:

Preliminary Environmental, Health, and Safety Review (PEHSR)

Project No:

44130065

Report Ref:

44130065-REP-001

Status:

Initial Issue

Client Contact Name:

Almamoon Al-Baadani

Client Company Name:

Al Ghaith Industries URS Corporation – Abu Dhabi

Issued By:

Document Production / Approval Record Issue No:

Name

Signature

Date

Position

Prepared by

David Monaghan

Air Quality Scientist

Checked and approved by

Andrew J Wilson

Principal Consultant

Document Revision Record Issue No

Date

Details of Revisions

1

?? August 2011

Draft PEHSR Issued

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LIMITATION URS has prepared this Report for the sole use of in accordance with the Agreement under which our services were performed. No other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by us. This Report may not be relied upon by any other party without the prior and express written agreement of URS. Unless otherwise stated in this Report, the assessments made assume that the sites and facilities will continue to be used for their current purpose without significant change. The conclusions and recommendations contained in this Report are based upon information provided by others and upon the assumption that all relevant information has been provided by those parties from whom it has been requested. Information obtained from third parties has not been independently verified by URS, unless otherwise stated in the Report.

COPYRIGHT © This Report is the copyright of URS Corporation Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited.

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CONTENTS Section 1. INTRODUCTION

Page No 18

1.1. 1.2. 1.3. 1.4.

Summary Error! Bookmark not defined. Need for Project 18 Policy and Standards 23 Scope 24

2.

PROJECT DESCRIPTION

2.1. 2.1.1. 2.1.2. 2.1.3. 2.1.4. 2.1.5. 2.1.6. 2.1.7. 2.1.8. 2.1.9. 2.1.10. 2.1.11. 2.1.12. 2.1.13. 2.1.14. 2.1.15. 2.1.16. 2.1.17. 2.1.18. 2.1.19. 2.1.20. 2.1.21. 2.1.22.

Overview 27 Unloading and Storage of Salt 39 Brine Purification Process 40 Electrolysis Process 44 Brine Dechlorination 46 Hydrogen Gas Processing 47 Chlorine Gas Cooling 47 Caustic Concentration & Flaking Plant 47 Sodium Hypochlorite Plant 49 Hydrochloric Acid Plant 51 Demineralized water system 52 Cooling water unit 52 Chilled water system 53 Compressed air system 53 Steam supply system 53 Control and instrumentation system 53 Bagging Unit 54 Transportation System 54 Facility Construction 54 Air Emissions Control 55 Wastewater Treatment and Management 58 Solid Waste Treatment and Management 59 Fire and Toxic Gas Release Prevention and Control

3.

ENVIRONMENTAL BASELINE CONDITIONS 62

3.1.1. 3.1.2. 3.1.3. 3.1.4. 3.1.5. 3.1.6. 3.1.7. 3.1.8. 3.1.9. 3.1.10.

General Environmental Setting 62 Seismicity 62 Regional Meteorology 63 Air Quality 63 Terrestrial Ecology 68 Marine Ecology68 Soil and Groundwater Baseline Assessments 68 Socio-economic Environment 69 Noise Quality 73 Archaeological, Paleontological and Cultural Heritage Baseline Conditions 73

4.

IDENTIFICATION OF POTENTIAL ENVIRONMENT, HEALTH, AND SAFETY HAZARDS AND IMPACTS 74

4.1.

Air Emissions 74

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27

60

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CONTENTS Section

Page No

Appendix A Figures Photographs

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1.

EXECUTIVE SUMMARY TBC

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2.

INTRODUCTION 2.1.

Project Title and Project Proponent The title of the proposed Project is the “Development of a Chlor-Alkali Plant at ICAD-1” termed throughout this document as “Chlor-Alkali Project”. The Project is being developed by Al Ghaith Industries (Al Ghaith). As the nominated proponents for this project, the name, address, telephone number, and fax number of Al Ghaith is shown below. Al Ghaith Industries - Abu Dhabi Almamoon Al-Baadani General Manager Al Ghaith Industries PVD Salt P.O.Box : 35119 1D1, Industrial City of Abu Dhabi (ICAD) Musaffah, ,Abu Dhabi, U.A.E. Tel : + 971 2 5502500 Fax : + 971 2 5502728 Email: [email protected]

2.2.

PER Consultants URS Corporation – Abu Dhabi (URS) has prepared this Preliminary Environment, Health and Safety Review (PEHSR) on behalf of the Project proponents, Al Ghaith. The PEHSR has been produced in accordance with the Environment Agency – Abu Dhabi (EAD) Technical Guidance Document for Preliminary Environmental Review (PER), and Zonescorp Code of Practise on Environmental Health & Safety Impact Assessment (EHS04). URS is an EAD-registered Class-A Environmental consultant. The name, address, telephone number, and fax number of URS are detailed below: URS Corporation – Abu Dhabi Mr Peter Mueller Country Manager - UAE 102 Al Dhafra Tower Istiqlal Street, PO Box 43855, Abu Dhabi, United Arab Emirates Tel: +971 2 634 3365 Fax: +971 2 634 3374 Email: [email protected] www.urscorp.eu

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This PEHSR was prepared by Mr. David Monaghan (Air Quality Scientist) and reviewed by Mr. Andrew J Wilson (Principal Consultant). In addition to the above-mentioned project team, URS have drawn upon other professional and technical staff in our Abu Dhabi office including: Dominic Adams (Senior Geologist), and Angela Nicholson (Environmental Scientist). We can provide additional resources, including US-based environmental and engineering professionals as requested. The primary contact within URS for the ChloroAlkali Project is: Mr. David Monaghan, Project Manager Email: [email protected] URS has extensive experience in undertaking large-scale, complex environment, health and safety impact assessments across a wide range of sectors and has a long history of providing innovative, cost-effective solutions to our clients’ engineering and environmental needs. URS has strong capabilities in the areas of: 

Air Quality Management;



Environmental compliance;



Soil and groundwater site assessments;



Soil and groundwater remediation;



Human health risk assessments;



Decontamination and decommissioning;



Geosciences and risk management;



Environmental Impact Assessment;



Health, Safety and Environmental Impact Assessment (HSEIA);



Hazardous waste management;



Noise and acoustic services; and



Regulatory and permitting affairs.

The project staff has extensive experience in providing Environmental Consulting services. Below are the individual team member’s fields of expertise. Mr. David Monaghan David Monaghan has six years experience as an Environmental Scientist specialising in Air Quality, Environmental Impact, and Quantitative Risk Assessment. David joined URS Corporation – Abu Dhabi in June 2011, after spending five years as an Environmental Scientist in the UK. David has expertise in characterising the air pollution impacts using

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dispersion modelling packages (such as AERMOD/ ADMS) in support of EIA/HSEIA work in the oil and gas, land development and heavy industry sectors. He is an experienced project manager and has lead various environmental assessments across a broad range of industrial activities for private and government organisations focusing on air quality monitoring/ modelling, environmental permitting and due diligence. Mr. Andrew J Wilson Andrew Wilson PhD PE - Dr. Wilson is a Senior Principal in the URS Abu Dhabi Office and has over 30 years of experience in the oil and gas, heat transfer, power, and pharmaceuticals from both industrial and academic perspectives. He has managed or directed a number of EIA activities encompassing Oil and Gas, Power, and Water projects in the UAE, Qatar, Azerbaijan, and Saudi Arabia. He has performed engineering studies and designs for fired heaters, water and wastewater treatment systems, and industrial hazardous and NORM waste treatment and disposal. He previously worked for Black & Veatch Consulting Engineers in the Power Division Chemical Engineering Department, responsible for the design of power plant water and wastewater treatment systems. He is very knowledgeable in the field of oil and gas facility and power plant design. Likewise, he is knowledgeable in the areas of project management, process engineering and modelling, design and operation of heat transfer equipment, industrial water/wastewater treatment and Carbon Capture and Storage (CCS). He has managed large EIA projects within the region and he is very familiar with the environmental licensing processes within the region. Mr. Dominic Adams Dominic Adams is a Senior Geologist in the URS Abu Dhabi office with over ten years experience as a consultant. During his career Dominic has gained extensive project management experience for a wide range of projects including environmental impact assessments (EIAs), geotechnical studies and contaminated land assessments for commercial and industrial developments in the UK, Italy, Qatar and the UAE. His responsibilities include project planning, design and coordination of field studies, and the preparation and review of EIA reports. Ms. Angela Nicholson Angela Nicholson is an Environmental Scientist in URS’ Abu Dhabi office. Angela has an interdisciplinary background in environmental sciences and has worked on a broad range of projects across UAE, wider Middle East, and the UK. During her career Angela has proven experience as a highly effective and organised project manager and coordinator for numerous projects as well as being responsible for preparing environmental and social impact assessment reports, managing field studies, and providing technical advice to clients in sectors including oil and gas sector, power generation, industrial, coastal defence, and port developments. Angela has previously worked on a diverse range of projects, including EIA, Appropriate Assessment, niche modelling, research and development, information dissemination, and social inclusion projects. During her career, Angela has fulfilled a number of roles

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including ecological surveyor, technical advisor, lead author, and project manager. She has worked with a variety of stakeholders and clients including government agencies, private companies, and non-governmental organizations in a variety of sectors, and also has a strong background in environmental and technical reporting and analysis.

2.3.

Project Description and Rationale URS is pleased to provide this PEHSR study for development of a Chlor-Alkali Plant (hereafter referred to as the ‘Project’) proposed to be established by Al Ghaith within the ICAD-1 area, Musaffah. The plant will produce Caustic Soda / Liquid (32% concentration), by-products-Chlorine gas and Hydrogen gas, Caustic Concentrate (50% NaOH), Caustic Flakes, Hydrochloric acid and Sodium Hypochlorite. Chlorine gas shall be processed through cooling. Sodium Hypochlorite shall be produced as a by product under Waste Air Dechlorination (environmental control measures). The main products and the planned production capacity of the proposed plant are as follows:

Product

Capacity per day

Capacity per year

HCl - 32% w/w solution

179 MT / Day

59,000 MT/Year

Caustic Soda -100%

70 MT/ Day

23,100 MT/Year

Sodium Hypochlorite 12%

70 MT/ Dat

23,100 MT/Year

This PEHSR study will focus on construction, commissioning and operation of the Project, and will culminate in the submission of this report to Zonescorp and EAD for review and approval.

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2.4.

Justification and Chronology for the Development of a PER By completing this PEHSR URS and Al Ghaith have been able to effectively assess the associated risks and provide a definite solution to all environmental, health and safety risks that are present in constructing and operating the Chlor-Alkali Plant. As such, a more detailed costly EIA is not necessary. The objectives of the PEHSR are specified in the relevant legislation and guidance outlined in Section 3. The PEHSR report demonstrates that in relation to the subject Project facility, site or activities: a. That all EHS hazards have been systematically identified in the Hazards & Effects Register (HER), inclusive of relevant risk classification (e.g. High, Medium and Low) or in accordance with principles that are compatible with those provided in Zonescorp CoP on EHS Risk Management (CoP EHS03). b. That all environmental impacts have been identified, suitably analysed and assessed for significance. It must be demonstrated that relevant control, mitigation and recovery measures are proposed (for projects), are implemented (for existing facilities or operations) or an implementation plan exists for implementation. c.

That all accident hazards have been identified and suitable control, mitigation and recovery measures are proposed (for projects) or are implemented (for existing facilities or operations). It must be demonstrated that operation can be achieved within the Zonescorp quantitative criteria for risk tolerability and compliance with “As Low As Reasonabliy Practicable” (ALARP) must be demonstrated in accordance with principles that are compatible with those provided in Zonescorp CoP on EHS Risk Management (CoP EHS03).

d. That all Occupational Health Risks have been systematically identified and suitable action to mitigate these risks and to protect employees from these risks have been or will be taken in accordance with Zonescorp CoP on EHS Risk Management (CoP EHS03). e. How all HSE risk - including that resulting from moderate and low risk hazards - will be managed and controlled by Al Ghaith or project/site/operations specific EHS Management Systems. Refer to Zonescorp CoP on EHS Management Systems (CoP EHS02). f.

That Emergency Response Plans (on-site and off-site where necessary) in relation to Major Accident Hazards have or will be prepared based on credible emergency scenarios, with the necessary stakeholder consultation. Refer to Zonescorp CoP on Crisis Management Plan (CoP FE05).

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In order to complete this PEHSR the following schedule has been followed. A project Gantt Chart is shown in Table 2- 1 -1.

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Kick Off Meeting –July 2011;



HAZID/ENVID –July 2011;



Development of Hazard Effects Register – August 2011;



Completion of PEHSR and submission to Al Ghaith – August 2011;



Submission of PEHSR to Zonescorp – August 2011; and



Submission of PEHSR to EAD – September 2011.

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Table 2-1-1 Project Schedule The following provides a proposed project schedule with best estimates provided for Al Ghaith, Zonescorp, and EAD review periods based on previous experience. Task

Sub-Task 1

2

3

4

5

6

7

8

9

Kick Off Meeting (1 day) HAZID/ENVID Workshop (2 days) HAZID/ ENVID Register

PEHSR Study Report

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Draft Spreadsheet to Al Ghaith Al Ghaith Review and Comment Draft Report Al Ghaith Review and Comment Final Draft Report ZonesCorp Review and Comment Final Report EAD Review and Comment Final Report (Issue 2 if necessary) EAD Approval

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10

11

Week 12 13

14

15

16

17

18

19

20

21

22

3.

LEGAL FRAMEWORK AND STANDARDS This section outlines the key environmental regulations in the UAE that will be considered both in terms of the scope and nature of the PEHSR, and in the overall construction and operation of the proposed Project.

3.1.

Specific Environmental Standards and Guidelines relevant to the Chloro-Alkali Project The Al Ghaith PEHSR will assess relevant factors against applicable EAD and Zonescorp guidance. In the absence of specific UAE criteria levels, applicable International Standards shall be applied. The following regulations and standards were followed whilst carrying out this study.

3.2.



Zonescorp CoP on EHS Management Framework (EHS 01);



Zonescorp CoP on EHS Management Systems (EHS 02);



Zonescorp CoP on EHS Risk Management (EHS 03);



Zonescorp CoP on EHS Impact Assessment (EHS 04);



Zonescorp CoP on Practise on Crisis Management Plan (FE 05);



EAD Technical Guidance Document for Preliminary Environmental Review (PER) (April 2010);



Abu Dhabi Emirate EHS Management System Manual;



Abu Dhabi Emirate Environmental Protection Policies (EEPPs); and



EAD Standard Operating Procedures for Permitting of New Projects and Activities in Abu Dhabi.

National Laws, Standards, and Guidelines The Ministry of Environment and Water (MOEW) is the Competent Authority responsible for implementing federal law in the UAE. The MOEW, formally the Federal Environmental Agency (FEA) established in 1993, is the principal environmental institution in the UAE. The MOEW develops environmental policies that are implemented and enforced as a minimum level of environmental due diligence by the various member Emirates within

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their area of jurisdiction. In Abu Dhabi, the competent environmental authority is Environmental Authority – Abu Dhabi (EAD). Principal federal environmental and social laws that are relevant to this Project include: 

Ministry of Labour and Social Affairs Federal Law No. (8) of 1980;



Ministry of Labour and Social Affairs Ministerial Order No. (32) of 1982;



Federal Law No. (7) of 1993 concerning the establishment of the FEA;



Federal Law No. (23) of 1999 Concerning exploitation, conservation, and development of living aquatic resources in the United Arab Emirates and its Executive Order issued by Ministerial Decree No. (302) of 2001.



Federal Law No. (24) of 1999 for the Protection and Development of the Environment and subsequent Decree No. (37) for 2001 “Executive Guidelines for Federal Law No 24 of 1999, concerning Environmental Protection & Development” prescribing regulations pertaining to the following systems: o

Impact Assessment of Projects;

o

Protection of the Marine Environment;

o

Handling of Hazardous Substances, Hazardous Wastes and Medical Wastes;

o

Protection of Air from Pollution.

o

Agricultural Pesticides, Agricultural Conditioners and Fertilizers; and

o

Protected Areas.



Federal Law No. (21) of 2005 for Waste Management in the Emirate of Abu Dhabi;



Federal Law No. (16) of 2005 concerning the reorganization of the Abu Dhabi Environment Agency, replacing Federal Law No. (4) of 1996 as amended by Law No. (1) for 1997, specifying EAD as the competent body for implementing federal environmental law; and



Federal Law No. (12) of 2006 for Air Pollution Protection.

Of these Federal Law No. (24) for 1999 provides the overarching framework for environmental considerations in the UAE. This law aims to achieve the following goals: 

Protection and conservation of the quality and natural balance of the environment.



Control of all forms of pollution and avoidance of any immediate or long-term harmful effects resulting from development.

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

Development of natural resources and conservation of biological diversity in the region and the exploitation of such resources with consideration of present and future generations (i.e. the principle of Inter-generational Equity).



Protection of society, human health and the health of other living creatures from activities and acts that are environmentally harmful or impede authorized use of the environmental setting.



Protection of the UAE environment from the harmful effects of activities undertaken outside the region of the UAE.



Compliance with international and regional conventions ratified or approved by the UAE regarding environmental protection, control of pollution and conservation of natural resources.

In addition to the requirements of Federal Law 24, a number of Executive Regulations deal with specific environmental areas, including: 

Regulation for the Environmental Effects of Installations. This regulation requires an EIA to be carried out for certain projects before an Environmental License to develop and operate the project is issued by the Competent Authority.



Regulation for the Protection of the Maritime Environment. This is concerned with the prevention of pollution of the marine environment from vessels, land based sources and offshore platforms.

Furthermore the Executive Guidelines for Federal Law No. (24) for 1999, Concerning Environmental Protection and Development, Decree No. (37) for 2001, states the requirement to have a permit for new projects through EAD, and also states that “when analyzing the expected environmental reactions, the following elements must be taken into consideration when conducting and EIA: A) Any environmental impact on the ecological system that might get affected by the project / activity. B) Any impact on an Area/Place/or building that has an archaeological, amusement, architectural, cultural, historical, scientific, or social values, or has other environmental characterizes that form a value for the existing or future generations”.

3.3.

Abu Dhabi Emirate and Local Laws, Standards and Guidelines EAD is the nominated authority for implementing Federal Environmental Law in Abu Dhabi in accordance with: 

Federal Law No. (24) (Article 4)



Abu Dhabi Local Law No. (4) for 1996 (as amended)

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

Executive Council Decision No. (37)

As such, EAD is the nominated authority for implementing laws including Federal Law No. (24) for 1999 and Decision No. 42 of 2009 Concerning the Environment, Health and Safety Management System in Abu Dhabi Emirate (“EHSMS Law”) The Competent Authority for this project, EAD, is responsible for the evaluation of the environmental impacts of the project and the issue of associated permits and licenses. EAD standards and guidelines of relevance to the Project which will be adhered to include: 

EAD Technical Guidance Document for Preliminary Environmental Review (PER) (April 2010).



Standard Operating Procedures for Permitting of New Projects and Activities in Abu Dhabi (SOP – PNPS-01, 2002).



EAD Guidelines for Submission of Baseline Environmental Data (November 2003).



Technical Guidance Document (TG-0003R). Standards and Limits for Pollution to Air and Marine Environments (July 2003).



EAD Guidelines – Format for the Submission of Environmental Impact Assessment Reports (December 2002).



EAD Geographic Information System Data Management System (July 2001).



EAD Guidance on Permitting of New Projects through Environmental Impact Assessment.

It should be noted that EAD has since issued updated standards and guidance The PEHSR will, however, be produced in line with the new guidelines in so far as is possible. The new guidelines include:

3.4.



Standard Operating Procedures for Permitting of Industrial Projects in Abu Dhabi (April 2010).



Technical Guidance Document for Environmental Impact Assessment (April 2010).



Abu Dhabi Environment, Health and Safety Management System (EHSMS) and associated Codes of Practice (CoP).

International Conventions, Treaties, and Protocols The UAE has signed and ratified (that is, placed into federal law) the following international protocols and agreements relevant to the S3 Project: 

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Convention on Biological diversity, 1992 (Biodiversity Protocol);

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

United Nation Framework Convention on Climate Change for the year 1992;



Kyoto Protocol, 1997;



Vienna Convention for the Protection of the Ozone Layer of 1985;



Montreal Protocol on Ozone Depleting Substances of 1987 and Montreal Amendments (London 1990, Copenhagen 1982, Montreal 1987, Beijing 1999);



United Nations Convention to Combat Desertification 1994;



Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Convention), 1972;



International Convention for the Prevention of Pollution of the Sea by Oil, 1954 and its amendments;



Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), 1973;



Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, 2002;



Convention on Persistent Organic Pollutants (POPs) 2001;



International convention on Civil Liability for Oil Pollution Damage (CLC) 1969;



International convention on the Establishment of an International Fund for Compensation for Oil Pollution Damage 1971; and



Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade (PIC Convention) 1998.

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4.

PROJECT DESCRIPTION 4.1.

Statement of Need Chlorine is essential to chemical industry; more than 85% of all pharmaceuticals and more than half the products marketed by the chemical industries are derivatives of Chlorine chemistry. Almost 1,500 of these products are used in different industrial and economic sectors such as health, agro-food, building, textiles, transport, leisure activities, cosmetics etc. With every tonne of Chlorine that is produced 1.1 tonnes of Caustic Soda are also made. More than half of the Caustic Soda manufactured is used in the chemical industry and the rest goes into products such as soap and textiles, or is used in water treatment, aluminium production and oil refining. The UAE government has established heavy industry in order to increase diversification of the economy. Foreign firms have been employed to provide expertise in planning, construction, management and marketing in return for minority shares in the companies. Oil revenues have funded the construction of plants and the development of infrastructure; natural gas has been used as a source of power and as feedstock. Petroleum and natural gas industries and their related manufacturing are the basis of the national economy in the UAE. A limited local production of Caustic Soda exists in Abu Dhabi, hence the requirement to develop a local manufacturing plant that will provide additional supply to the required industries.

4.2.

Project Location and Scale The Chlor-Alkali Plant will be located in Abu Dhabi Emirate approximately 20km southeast of Abu Dhabi City. The project site is located to within the Industrial City Abu Dhabi 1 (ICAD-1), which is part of the overall Musaffah Industrial Area. The Chlor-Alkali Plant will be located on a plot of 25000m2 of reclaimed industrial land. The coordinates for geographic site boundaries are as: North-West boundary:

Easting: 230522.306 Northing: 2649202.344

South-West boundary:

Easting: 230277.223 Northing: 2644508.749

North-East boundary:

Easting: 235215.915 Northing: 2648957.294

South-East boundary:

Easting: 234970.840 Northing: 2644263.659

Note: All coordinates are UTM Zone 40N, Datum WGS 84 The location of the proposed Chlor-Alkali Plant is shown in Error: Reference source not found and Error: Reference source not found. The plot and surrounding area up-filled and levelled, and includes minimal vegetation.

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Figure 4-1 Regional Location of ICAD-1

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Figure 4-2 Site Location

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4.3.

Project and Activity Description The proposed Chlor-Alkali Plant will produce hydrochloric acid (HCl), sodium hydroxide (caustic soda) and sodium hypochlorite (NaOCl) by electrolysis of brine/salt solution (sodium chloride) utilizing membrane cell technology. This technology is a proven, environmentally-safe electrolysis process. The main products and planned production capacity of the proposed chlor-alkali project is shown in Table 4 -2 below: Table 4-2: Main Products and the Planned Production Capacity

Product

Capacity /Day

Capacity / Year

HCl - 32% w/w solution)

179 MT / Day

59,000 MT/Year

Caustic Soda -100%

70 MT/ Day

23,100 MT/Year

Sodium Hypochlorite 12%

70 MT/ Dat

23,100 MT/Year

Approximately, 2.588 Tons/hour of Chlorine gas and 0.0729 Tons/hour of Hydrogen gas will also be produced as intermediate products during the electrolysis process. All chlorine and hydrogen gas produced will be fed back into the production process and converted to HCl and NaOCl, thus there will be no venting of chlorine or hydrogen during normal operations. The main raw material & chemicals consumed within the proposed project are presented in the following Error: Reference source not found. All consumption figures are based on per metric ton of caustic soda production (as 100%). Acids and chemical precipitants will be used to remove impurities in salt/brine and in the products. Chlorofluorocarbons (CFCs) or other ozone-depleting substances will not be utilized at the Chlor-Alkali Plant. The following ancillary materials will be used in various stages of the Chlor-Alkali industrial process:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Sodium carbonate (Na2CO3) will be used for precipitation of calcium ions as calcium carbonate (CaCO3);



Barium Carbonate will be used for precipitation of Sulphate ions as Barium Sulphate( BaSO4);



HCl will be used for pH adjustment of cells and also used for dechlorination of brine;

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

Sodium bisulfite (NaHSO3) will be used for dechlorination of brine and in the final stage to eliminate chlorine; and



Sodium hydroxide (NaOH) will be used for removal of magnesium and heavy metals.

The proposed project will comprise of a series of operations, as shown in Figure 4 -3.

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Figure 4-3 Flow Diagram of Chlor-Alkali Industrial Process

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The following are the major processes/operations involved in the project, and are described in the subsequent sections: 1. Unloading and Storage; 2. Brine Purification; 3. Electrolytic Process; 4. Brine Re-saturation and Dechlorination; 5. Chlorine Gas Processing - Cooling and Treatment; 6. Hydrogen Cooling; 7. Production of Hydrogen Chloride; 8. Production of Sodium Hypochlorite; 9. Caustic Solution Concentration (Flaking Unit); and 10. Caustic Solution Concentration (Flaking Unit). Other utilities and secondary operations, as listed below, will also be involved in the proposed Al Ghaith project plant. 1. Demineralized Water (DM) system; 2. Cooling Water System; 3. Chilled Water System; 4. Compressed Air System; 5. Steam Supply System (Boiler); 6. Control and Instrumentation System; 7. Bagging Unit; and 8. Transportation System. Following are the control measures included at the proposed Al Ghaith project plant. 1. Air Emissions Control; 2. Wastewater Treatment and Management; 3. Waste Treatment and Management; and 4. Fire and Toxic Gas Release Prevention and Control.

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4.3.1. Unloading and Storage of Salt Main raw materials will be transported via road from XXX(where??) to the proposed Chlor-Alkali Plant. The salt and other raw materials will be unloaded from trucks and will be moved to a dedicated storage area utilizing front-end loaders. This storage area will be provided with a concrete-lined pad and sheet-metal shading. It is expected that approximately 120 tons of salt will be brought to the Chlor-Alkali Plant on a daily basis. Details of the proposed storage facilities are provided in Table 4 -3 below. Table 4-3 Proposed Storage Facilities

SL No

1

Storage

Proposed capacity

Remarks

materials

and description

Remarks

50,000 Tons Covered

The storage areas for liquid chemical (caustic soda, HCl and NaOCl) above-ground storage tanks will have containment dikes to contain 110 percent capacity of its entire volume of tanks within the containment.

Salt

shed with wind protection 4 tanks x 300 m3

2

Caustic Soda (50%)

7 m diameter x 8 m height Mild steel 6 tanks x 150 m3

3

32% HCl

5.5 m diameter x 7 m height

4 tanks x 100 m3

The storage area will also be provided with recovery/ drainage system to transfer the liquid into other storage tank immediately.

4.5 m diameter x 6 m height

ANSI standards will be followed for construction of the storage tanks.

Rubber-lined from inside.

4

Sodium Hypochlorite

FRP or derakane-lined

5

PEHSR Chlor-Alkali Plant Al Ghaith Industries

The storage area will be of full reinforced concrete flooring with epoxy coating to avoid any ground contamination in case of spillages.

Caustic soda

5,000 m3

Flakes

Covered Shed

Paint used on the storage tanks will be epoxy paint with three different layers of special coating. MSDSs will be located at the storage facilities to guide personnel in case of spills.

Project Number 44130065 Page 21

4.3.2. Brine Purification Process Make-up brine for the process is prepared by dissolving crystal NaCl salt into the return brine from the membrane cell electrolysers, and is treated with chemicals so as to precipitate the impurities of raw salt. Feed to the electrolysers requires highly purified brine free of any metallic impurities. This is performed by pre coated filter and ion exchange resins under secondary brine purification facilities. The plant will have a recycled NaCl brine stream as well as depleted return brine stream as per process requirements. 4.3.2.1. Primary Brine Purification The return brine is fed to the salt saturator. This will be saturated with ‘make-up’ salt. Makeup crystal salt is continuously supplied to the saturator by salt feeder (pay-loader). Temperature of the return brine is controlled by return brine heater so as to maintain the saturated brine temperature within 60-65 °C. The clear saturated raw brine overflows from the feed compartment of the saturator to the clear brine compartment and fed to the reactor with the help of pumps. The density of brine is controlled automatically. Chemicals, such as caustic soda, barium carbonate and sodium carbonate shall be added to the saturated raw brine flow. Dissolved impurities of raw brine (Ca, Mg and SO 4) are concentrated as CaCO3, Mg (OH)2 & BaSO4 from the solution in the reactor. The excess OH - is maintained by help of automatic pH measurement & control. This suspension solution is sent to the center well of brine clarifier for sedimentation and removal of the solid impurities. Flocculent is also added to the stream of suspension solution. Clarified brine overflows from brine clarifier to clarified brine tank. Slurry from clarifier slurry pit and filter slurry pit is sent to sludge filter press to recover the brine in the slurry. Recovered brine is fed to return brine tank. The barium sludge obtained during processing shall be dried and stored in the impervious landfill inside the plant area. As such, the question of barium sludge disposal does not arise.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 22

Figure 4-4 Brine Clarifier The clarified brine from clarified brine tank is then filtered through primary brine filters packed with anthracite coal as filter media. Membrane type electrolysers need high quality brine free from metallic impurities for trouble free membrane cell electrolyser operation. Further purification of brine from the primary brine section is carried out in the secondary brine candle filtration and ion exchange resin adsorption system.

Figure 4-5 Anthracite Filters

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 23

4.3.2.2. Secondary Brine Purification System Candle filtration In the membrane cell based caustic / chlorine plant, the content of suspended solid in the filtered brine must be kept very-very low because suspended solids above a certain level will plug the ion exchange resin. Care is taken while designing a brine filtration system for smooth operation of the electrolyser. The system employed by Al Ghaith will have a carbon candles filtration system with automatic change over valves and sequence controller. The operating process of a candle filter consists of four stages: 1 – Preparation of Pre-coat The required quantity of the filtrate brine is filled into the filter. This step is performed immediately after the completion of washing step except the initial start. Alpha–cellulose of the required quantity is dosed into a pre-coat tank. When the “pre-coat tank dosage completion” button has been pushed and the required time has passed, filtered brine is filled into the pre-coat tank and agitation begins. 2 – Filtration When saturated brine passes through pre-coat layers formed on surface of filter elements from upstream to downstream, the fine impurities are trapped and removed. Body feed is automatically performed during recirculation and filtration process. 3 – Washing The impurities attached and alpha-cellulose on the surface of filter elements are removed and washed by flushing the clean brine through filter elements from inside to outside. By washing filter elements are restored back to original state before reuse. Immediately after completion of washing process (except initial start up) filtered brine of required quantity is filled into the brine filter. Alpha-cellulose of the required quantity is dosed into the precoat tank. After dosing of alpha-cellulose filtered brine is filled into the pre-coat tank and agitation is started. 4 – Pre-coat: Filtered brine mixed with alpha-cellulose is sent into the filter. Alpha-cellulose powder is attached evenly on the surface of filter elements and the pre-coat layers with alphacellulose are formed. The layers contribute to achieve a fine filtration quality by preventing filter elements from blinding, which gives higher washing efficiency of filter elements.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 24

Ion Exchange System Any traces of calcium and magnesium ion or other multivalent cations still present in the brine are harmful to the electrolyzer membrane. These are removed after chemical treatment and sedimentation in primary brine purification and further are removed by ionexchange resin as a secondary purification step. Al Ghaith plan to implement a 3-tower absorber merry-go-round type ion-exchange system. Ion exchange resin is filled into all the columns. Two columns are normally on line in series and while the third undergoes regeneration. After 16 hours the primary column is switched off-line for resin regeneration and the second column is elevated to primary position, while the regenerated column is switched into the position of secondary column. The resin in the off-line column, in which a large amount of multivalent cations have been absorbed, is regenerated by hydrochloric acid and caustic soda. As per cycle each column is regenerated after every 32 hours. As all the columns are connected through automatically operated valves, switching takes place automatically through the programmable logic controller.

Figure 4-6 Ion Exchange Resin Columns

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 25

Flow indication and control valves are installed in all the liquid lines connected to the ion exchange system in order to automatically control the flow rates. The resin regeneration process involves the following steps.

Washing with water (brine displacement)

Backwash with water

HCl regeneration

Washing with water

Caustic regeneration

Washing with water

Replacement of water with brine

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 26

4.3.3. Electrolysis Process The electrolysis section comprises of the membrane electrolyser and associated equipment. 4.3.3.1. Membrane Electrolyser The electrolyser assembly consists of a number of bi-polar type cell frames with a metal anode and the activated cathode, the ion-exchange membrane, filter press type units for mounting cell frames, sub-headers for feeding purified brine and catholyte, sub-headers for discharging electrolysis products, and hoses for connecting cell frames with subheaders. A highly purified brine solution will be fed to each electrolyser manifold and then distributed to each anode chamber where it then decomposes into chlorine and sodium ions. The brine flow rate to each electrolyser circuit will be monitored by a flow controller equipped with individual feed brine branch pipe.

Figure 4-7 Electrolyzer cell in operational reference plants (INEOS & AKCC) A two-phase process stream of depleted brine and wet chlorine gas overflows from each anode chamber and is separated at the collection manifold. The depleted brine will flow by gravity through the branch pipe and common header into the depleted brine tank, while the chlorine gas will be sent to chlorine gas processing section. Depleted brine will be pumped to depleted brine dechlorination system by level controller. Two hydrochloric acid additions have been considered for the brine recycling system in order to maintain a low oxygen concentration in the chlorine gas. One will be located at

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 27

the inlet of the depleted brine tank, while the other will be situated at the cell feed brine line. Two types of chlorine gas seal pots will be installed to protect the electrolysers from excessive pressure surging in process upset conditions: one for positive pressure relief and another for negative pressure. Chlorine gas header pressure in the cell room will be maintained by the pressure control of chlorine at cooler inlet. Recycled caustic will be fed to electrolyser manifold through a caustic heat exchanger and then distributed to each cathode chamber. The recycle caustic flow rate will be controlled by the flow controller installed in the caustic feed line.

Figure 4-8 Catholyte System A two-phase stream of caustic solution and wet hydrogen gas overflows from each cathode chamber and is separated at the collection manifold equipped with electrolyser. The caustic solution flows through the common header into the caustic recycle tank by gravity. Gas Processing Section The hydrogen gas pressure will be maintained by pressure control scheme. To prevent an excessive positive pressure, a hydrogen vent stack will be installed. This stack will also serve as a gas purge system during plant start up operations. After leaving the caustic recycle tank, the caustic solution will go directly to the product storage tank and the recycle caustic stream to the electrolyser. The caustic heat exchanger heats or cools the recycled caustic to maintain the electrolyser operating temperature at 85 to 90 °C. The electrolyser caustic strength will be monitored by the caustic density indicator, and normally kept at approximately 32 wt%. This is the optimum concentration for membrane performance by controlling the DM water feed quantity into the recycled caustic stream. During start-up, the caustic heat exchanger will warm the electrolyte in the electrolyser, accelerating to full current load attainment without excessive voltage. To detect

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 28

abnormalities of electrolyser, voltage and temperature monitoring systems have been included in the plant design.

4.3.4. Brine Dechlorination Depleted brine from depleted brine tank will be taken to a brine de-chlorination section to make return brine, which is free from chlorine. A typical brine de-chlorination section consists of packed tower where vacuum is maintained with the help of steam ejector. Chlorinated brine is sprayed at top of the column and liberated chlorine is sucked through a cooler. After cooling, it is sent to chlorine gas absorption section. Dosing of hydrochloric acid will be carried out in order to reduce the pH of brine up to the desired level before feeding it into the dechlorination tower. The brine stream will then be taken to the dechlorination tower to be treated again with NaOH in order to remove traces of chlorine left as the same is very harmful for the complete system. Dilute caustic will be fed to maintain the alkaline pH of return brine and to kill traces of Cl2 left in dechlorinated brine. Sodium sulphite reduces NaOCl, but not Cl 2 to chloride. Return brine will be regularly tested to detect the presence of free chlorine before this enters the return brine tank.

4.3.5. Hydrogen Gas Processing Hydrogen gas is generated during electrolysis at between 85 to 90 °C. The gas will be introduced to the hydrogen gas coolers first with cooling water and then with chilled water, where it will be cooled to approximately 18 °C. From hydrogen cooler gas, hydrogen gas will be taken to vent (during start-up) or to the HCl acid synthesis unit.

4.3.6. Chlorine Gas Cooling The chlorine gas cooling system is capable of providing gaseous chlorine. No provision has been made for liquefied chlorine production and storage. The chlorine gas cooling section comprises of chlorine gas coolers (primary & secondary) and a mist eliminator. Chlorine gas coming from the electrolyser at 90 °C will be saturated with water vapors and will contain traces of sodium chloride. The chlorine gas will be cooled to between 40 to 45 °C in the chlorine cooler with cooling water and then up to -20°C in the chilled water cooler. During cooling, large quantities of water vapors get condensed. The water vapor will be collected in the seal pot. Entrained water vapors and salt traces are removed in the mist eliminator. A small quantity of process water will be added in the chlorine line in order to dissolve entrained salt particles.

4.3.7. Caustic Concentration & Flaking Plant This section of the plant will have flexibility to operate on only 50% caustic soda production (Mode A) and flaking (Mode B) and production of both (Mode C). All the three are described below.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 29

4.3.7.1. Mode A - Evaporation only The 32% membrane cell liquor will be fed to the first stage falling film evaporator operating on product side under a vacuum. During a single pass, the caustic solution is evaporated to approximately 38%. The generated vapors are led via duct to a water cooled surface condenser where they are indirectly condensed. Inert gasses are sucked off by a watering vacuum pump. The 38% caustic solution discharged from the bottom part of the first stage evaporator by means of pump is heated to a temperature of 136 °C through heat exchange. During a single pass through the second stage falling film evaporator operating on product side at atmospheric pressure, the caustic solution is concentrated to 50%. The vapor generated within is used to heat the first effect evaporator. The second stage evaporator will be heated by steam. The steam condensate will be used to preheat the 38% solution and returns at battery limit. The vapor condensate will be collected in a Tank and leaves the plant at a temperature of approx. 73 0C. The 50% Caustic solution will be discharged from the bottom part of the second stage by means of pump (P-1201 A/B). It will be cooled down to 45 Chlor-Alkali Plant °C before being sent to Battery Limit through heat exchange. 4.3.7.2. Mode B - Concentration/ Flaking The 32% membrane cell liquor will be fed to the first stage falling film evaporator operating on product side under a vacuum of about 113 mbar abs. During a single pass through the evaporator, the caustic solution will be evaporated to approximately 46%. The generated vapors will be led via duct to a surface condenser, where they will be indirectly condensed by cooling water. Inert gases are sucked off by watering vacuum pump. The 46% caustic solution, which will be discharged from the bottom part of the first stage evaporator by means of pump, is heated to a temperature of 128 °C (typical value) through heat exchanger. During a single pass through the second stage falling film evaporator operating on product side at atmospheric pressure, the caustic solution will be concentrated to about 61%. The vapor generated will be used to heat the first effect evaporator along with the vapor coming from the concentration and flaking unit. The second stage evaporator will be heated by steam. The steam condensate will be used to preheat the 46% solution and returns at battery limit. The vapor condensate will be collected in a tank and will leave the plant at a temperature of approx. 74 °C. The 61% caustic solution from the evaporation will be fed to a specially designed falling film concentrator. During a single pass through this concentrator, the NaOH solution will be dehydrated from 61% up to about 98.5%. The concentrator operates on product side under atmospheric pressure and the generated vapor will be used to heat the first stage evaporator in the evaporation plant. The heat required for the concentration from 61% up to 98.5% is transferred by molten salt. The heat transfer salt is circulated by pump through natural gas fired heater, where

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 30

it is heated to approximately 430 °C. The flue gases pass through a combustion air preheater and are then vented through a stack into the atmosphere. The burner placed on top of the molten salt heater, is designed for operation with preheated combustion air. The highly concentrated caustic melt leaves the final concentrator through seal pot and is fed by gravity to a specially designed flaking machine, where it is processed into flakes at low temperature. The flakes are fed by gravity to a semi-automatic bagging scale. The bagging scale is of air tight design in order to avoid moisture pick-up of the hygroscopic flakes. The filled bag will be transported via a conveyor to the bag closing machine. The bag is a double walled bag with a PE inline and a PP woven outer bag. The PE inline is closed manually by a drill binder and the PP woven outer bag will be closed by a sewing machine. 4.3.7.3. Mode C - Evaporation and Concentration/ Flaking In this mode liquid caustic and flakes can be produced at the same time. The process description is, in principle, the same as for Mode B concentration and flaking. However, the process parameters are slightly different. The concentration after the first evaporation stage is about 40% NaOH. The concentration after the second evaporation stage is 50% NaOH. After the second evaporation stage the caustic flow is split into two streams, one feeding the final concentrator and the second one leading to the battery limit. The caustic going to the battery limit is passes through a set of two heat exchangers where the caustic is cooled down to a temperature of 45 °C. The concentration plant is working with the same principle as described under mode B except that the feed concentration is 50% instead of 61% NaOH. The plant is controlled by instruments to ensure fully automatic operation of the process. Operating personnel are required only at the bagging and bag closing station. However, start up and shut down of the plant requires some manual interactions.

4.3.8. Sodium Hypochlorite Plant It is mandatory to install Waste Air Dechlorination (WAD) in the Chlor-Alkali Plant in order to comply with the requirements of the applicable environmental legislation. During start up and shut down of the plant, chlorine from the cell house is sent to the sodium hypochlorite plant. In case of any leakage or excess pressure in the process, chlorine will be sucked by the WAD section. The waste chlorine header will be connected to all vulnerable points where there is a chance of any chlorine leakage including vents and seal pots. The sodium hypochlorite plant consists of the following sections

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Chlorine Suction System;



1st Stage Absorption System;

Project Number 44130065 Page 31



2nd stage Absorption System; and



Chlorine Suction System.

Chlorine gas from chlorine section as well as any leaked chlorine is sucked into the plant through a suction blower. This blower handles only unabsorbed air and water vapors. 1st stage absorption The 1st stage absorption system shall consist of caustic circulation tank, circulation pump, chilled water PHE and packed column absorber. The 1 st absorber will face concentrated chlorine. The maximum chlorine will get absorbed at this stage. Diluted caustic will be circulated in the absorber from caustic circulation tank and pumped for absorption of chlorine from passing through chilled water PHE to remove the heat of reaction. When the batch is ready the same is transferred to sodium hypochlorite storage tank and fresh diluted caustic is taken from polishing tower / 2nd absorber tank. The reaction in the sodium hypochlorite plant can be summarized as below: 2 NaOH + Cl2 →NaOCl + NaCl + H2O Normally to get a stable product, 10 to 20 gpl of excess alkali is maintained in the product and before transferring it is ensured that available chlorine is 150 gpl. 2nd Stage Absorption System Since some chlorine will escape from 1 st absorber the 2nd stage absorption system will be installed to absorb the remaining chlorine from waste air. Additionally, this system will consist of one packed absorber with one circulation tank, circulation pumps and plate heat exchanger. The 2nd stage system consists of:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Chlorine Suction System;



Caustic Dilution and Over Head Tank;



1st Stage Absorption System; and



2nd stage Absorption System.

Project Number 44130065 Page 32

Figure 4-9 2nd Stage Absorption System

4.3.9. Hydrochloric Acid Plant 4.3.9.1. Principle of Operation HCL is produced as a gas from the combustion of hydrogen and chlorine gases, then absorbed into water and cooled. The combustion process is controlled to provide ultimate safety. During the combustion process, chlorine and hydrogen react in equal volume to produce HCl gas.

H2 (Gas)

+

Cl2 (Gas)

→

2HCl (Gas)

This exothermic reaction generates a flame temperature of around 2,500°C, and a heat load of approximately 1,000 kCal / kg of HCl when producing a cooled 33% aqueous phase of HCl. The combustion process is operated with a slight excess of H 2 over stoichiometric conditions operating the system with this excess of H 2 ensures the complete Combustion of chlorine gas, thus preventing it from escaping into atmosphere and producing a pure hydrochloric acid. 4.3.9.2. Synthesis Unit The heart of the process is synthesis unit (or integrated burner absorber), constructed of impregnated graphite materials encased in a water-cooled shell. The functions / process steps of the synthesis unit include:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Combustion;



Gas cooling;

Project Number 44130065 Page 33



Absorption; and



Solution cooling.

Hydrogen and chlorine gas enter the top of the synthesis unit and are burnt into a specific burner designed to ensure the complete combustion. The burner consists of special tubes fitted inside which are easily removable for maintenance. The addition of absorption water to the HCl gas is carried out at the top of the unit. The gases and absorption water are then cooled down in vertical channels at counter current of service side cooling water circuit. The wetted parts of unit are of the selected material to avoid any corrosion. At the bottom outlet of absorber, the HCl solution is separated from the gas which is processed in a tail gas tower scrubber to recover the remaining non-absorbed HCl gas. The synthesis unit is normally operated close to atmospheric pressure, but it is protected against over pressurization with a rupture disc. At the bottom of assembly, and vented to a sump pot beneath the synthesis unit. 4.3.9.3. Tail Gas Tower: The purpose of the tail gas tower is to absorb or to scrub the gases coming from the bottom of absorber. The gas components are mainly inert with some burnt hydrogen and a little unabsorbed HCl. The absorption water enters the top of the tail gas tower through a distributor and flows downwards over a packing as the gases flow upwards to be exhausted to atmosphere. During this operation, the remaining HCl will be absorbed. 4.3.9.4. Safety: The overall control philosophy of the HCl synthesis system design is “fail-safe”, which is defined by opening contacts under abnormal conditions. The following safety interlocks are provided to either prevent the system from being started or to cause the system to shut down & the purge itself.

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Flame failure;



Low cooling water flow;



Low absorption water flow;



Safety disc breakage;



Very high level in buffer tank;



Low N2 gas pressure while purging the unit during startup; and



Low instrument air pressure gauges.

Project Number 44130065 Page 34

During operation, if either of the above events occurs, the synthesis unit shuts itself down that a purge with nitrogen can be carried out.

4.3.10. Demineralized water system The process raw water will be DM by means of ion exchange treatment. The DM water production unit consists of cationic and anionic exchangers, a degasser (to reduce the CO2 before feeding the anionic exchanger), and a chemical dosing system for resin regeneration. The resin regeneration will be performed with diluted solutions of hydrochloric acid and sodium hydroxide. This unit will be designed to be operated automatically by means of a Programmable Logic Controller (PLC). The effluent from the DM unit will be mainly water with traces of acid and will be directed to wastewater neutralization pit.

Cooling water unit A closed-circuit cooling water unit will be installed at the proposed plant and will consist of induced draft type cooling towers. The warm cooling water will be dispersed uniformly over the entire cooling area by a distribution system. The air used for cooling will be drawn up by fans located on the top of the cooling tower. The cooled water will be collected in a water basin beneath the tower. The collected cooled water will be pumped to various process units in plant, collected back in the cooling water basin and pumped back to the cooling tower. The cooling water will be treated with chemicals in order to prevent metal corrosion, scale formation, and biological fouling, and thus help in increasing system operating efficiency and the composition of the bleed-off sent to drain.

4.3.11. Chilled water system A chilling unit will be installed at the plant to produce chilled water. The chilling unit will include a vapor absorption system to avoid the use of any Ozone-depleting refrigerant. The chilled water will be used at various stages of the process stream.

4.3.12. Compressed air system The air compression unit will consist of two compressors (operational and stand-by) for the supply of 100% of the compressed air demand for plant and instrument air. Even though the membrane plant will be operated continuously, variations of instrument air requirement can occur. The instrument air vessel will compensate these variations and allow smooth operation of air system. The compressed air system will also include a dryer which will consist of two units that can be used alternatively as an absorber chamber or in case of regeneration as desorber chamber.

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In addition, the dry air system will be used for air blanketing (through various inlets) the caustic flakes, starting from the hoppers up to the bagging area, in order to prevent the flakes from absorbing the moisture.

4.3.13. Steam supply system A natural-gas fired boiler complete with a low-No x burner, a combustion air fan, and an automatic control (for safety operation) will be installed at the plant to generate steam.

4.3.14. Control and instrumentation system The plant will be equipped with a central control system enabling an automatic operation of main process units and checking the critical parameters (temperatures, feed rate, liquid levels, etc). These parameters are monitored with pre-alarms and sensors. Interlocks will also be provided for personal safety and material protection. In addition, local control panels will be provided at the burner system, spraying areas and at the bagging units. Details of proposed online monitoring system are provided below in Table 4 -4. Table 4-4: Proposed Online Monitoring System Type

Description

Chlorine and hydrogen sensors

Caustic Plant – how many???

Meters Voltage monitoring equipment

Process control equipment

pH meter, ORP Conductivity Cell House All the process parameters (temperature, pressure, flow etc) Analyzers are linked with an Automated DCS with safety trip logics

4.3.15. Bagging Unit A bagging unit will be installed to weigh and automatically fill the caustic flakes into bags. The system will consist of an electronic weighing scale and a fully automatic fill and sealtype packaging machine, and will be operational 16 hours per day.

4.3.16. Transportation System Transportation of main raw materials from ICAD 1 to the proposed plant will be via road. In addition, finished products will be transported via road for distribution within the UAE and beyond. Standard Operating Procedures (SOP) will be prepared to ensure the following:

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Project Number 44130065 Page 36



Transportation is carried out safely in compliance all applicable EAD rules/regulations and international conventions;



Materials to be transported are within allowable weight and volume limits;



No leakage/spillage of the materials from the vehicles occurs during transportation and loading/unloading; and



Vehicle operators/drivers follow applicable UAE traffic laws/regulations.

4.3.17. Facility Construction The following major activities are expected to occur as part of the project construction effort: 

Piping and underground piping works;



Civil works;



Construction works and installation of pre-fabricated structural steel and pipe racks;



Building construction works and equipment machinery erection;



Pre-fabrication of piping spools and piping erection, testing and flushing systems in all areas;



HP equipment and piping erection, and listing, flushing and pre-commissioning;



Electrical works and instrument erection;



Instrument calibration and loop checks;



Insulation and painting works; and



Mechanical completion, testing and pre-commissioning.

4.3.18. Air Emissions Control In general the air emission sources within the project are very small and emission rates are minimal. Most of the point source emissions at the proposed plant will be from the following:  Construction phase impacts due to emissions of criteria air contaminants from mobile non-road sources (i.e., construction equipment and vehicles);

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Construction phase impacts due to emissions of dust due to digging, piling and other earth work;



Stack for Hydrochloric acid furnace (HCl vapors and Cl 2 gas);

Project Number 44130065 Page 37



Stack for Sodium hypochlorite tower (Cl2 gas);



Stack for natural-gas fired boiler (SPM, NOx, SOx, CH4, CO2);



Stack for Flaking Unit (SPM, NOx, SOx, CH4, CO2).

The primary source of air contaminants during the construction phase will be the various internal combustion engines used at the construction site, which will include both nonroad construction equipment and some on-road vehicles. These mobile sources will emit carbon monoxide (CO), volatile organic compounds (VOCs), nitrogen oxides (NO x) and sulfur dioxide (SO2) into the atmosphere. The operating horsepower of the equipment was estimated as the average horsepower for a specific type of equipment utilizing the USEPA non-road emission factors. Furthermore, since the specific number and type of equipment to be used onsite at any given time has not yet been finalized, a conservative estimate of the type and number of construction equipment to be used has been assumed. The corresponding NEVES emission factors are presented in Table 4 -5 below. The maximum monthly and daily estimated emissions during the construction period are summarized in Table 4 -6.

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Table 4-5: Construction Equipment - Air Emission Factors. Expected Construction Equipment

hp

CO (g/bhp-hr)

VOCs (g/bhp-hr)

NOx (g/bhp-hr)

SO2 (g/bhp-hr)

Plate Compactors

8

3.1

0.83

9.3

0.93

Rollers

99

3.1

0.82

9.3

1

Excavators

143

5.2

0.71

10.75

0.93

Cranes

194

4.2

1.29

10.3

0.93

Off-Highway Trucks

489

2.8

0.86

9.6

0.87

Tractors/Loaders/Backhoes

77

6.8

1.43

10.1

0.93

Dumpers/Tenders

23

2.8

0.86

9.6

0.89

Generators < 50 hp

22

5

1.22

8

0.93

Air Compressors < 50 hp

37

5

1.22

8

0.93

4x4 Use (Petrol Fuel)*

N/A

2.06

0.04

0.14

0.40

4x4 Use (Diesel Fuel)*

N/A

0.61

0.15

0.2

0.40

Bus*

N/A

1.56

0.49

3.93

0.40

500 KVA Generators

50

5.0

1.22

8.0

0.93

Air Compressors

50

5.0

1.22

8.0

0.93

Table 4-6: Construction Emissions Estimates. Construction Period (days/month) Length of working days (hrs/day) Expected Construction Equipment hp Plate Compactors 8

26 10 Qty 1

Estimated Peak Construction Emissions CO VOCs NOx SO2 (kg/month) (kg/month) (kg/month) (kg/month) 6.0 1.6 17.9 1.8

Rollers

99

1

6.0

1.6

17.9

1.8

Excavators

143

1

4.0

1.1

11.9

1.2

Cranes

194

2

4.8

1.3

14.3

1.44

Off-Highway Trucks

489

1

3.0

0.8

8.9

0.9

Tractors/Loaders/Backhoes

77

2

11.9

3.2

35.7

3.6

Dumpers/Tenders

23

1

6.0

1.6

17.9

1.8

Generators < 50 hp

22

3

11.9

3.2

35.7

3.6

Air Compressors < 50 hp

37

2

23.8

6.4

71.4

7.2

4x4 Use (Petrol Fuelled)

***

10

59.5

16.0

178.5

18

4x4 Use (Diesel Fuelled)

***

5

59.5

16.0

178.5

18

Bus *** Total Estimated Emissions (kg/month) Estimated Emissions (kg/day)

5

6.0 202

1.6 54

17.9 606

1.8 61

7.8

2.1

23.3

2.4

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 39

The movement of soils during construction activities will be anticipated to lead to the generation of airborne dust. The occurrence and significance of dust generated by earthmoving operations will be difficult to estimate accurately, and depends upon meteorological and ground conditions at the time and location of the earthwork. Very small quantities of CO 2 emissions are released during the purification of brine with sodium carbonate. It is estimated that 10 grams of carbon dioxide are released per ton of caustic soda production. Fugitive CO2 emissions are also likely from the chlorine destruction unit and handling. During loading of caustic and NaOCl, fugitive emissions are not anticipated. However, fugitive emissions are likely during HCl loading.

Control measures to minimize air emissions

PEHSR Chlor-Alkali Plant Al Ghaith Industries



The depleted brine from the electrolysis section, containing free chlorine, will be de-chlorinated in a brine de-chlorination tank where most of the free chlorine will be stripped out by vacuum and the stripped chlorine gas will be sent to the main chlorine gas header. The de-chlorinated brine leaving the de-chlorination tank will be allowed to react with sodium bisulfite solution at a pH of 9-9.5 for further removal of chlorine;



All chlorine-containing waste gas streams will be directed to the chlorine absorption unit. The chlorine absorption unit will be designed with a treatment capacity sufficient to absorb the full cell-room production to prevent emissions of chlorine gas in the event of emergencies and/or irregular plant operation until the plant can be shut down. The chlorine absorption unit design will enable the plant to lower the chlorine content in the emitted gas to less than 1.72 ppmv (5 mg/Nm3) in the worst-case scenario compared to EADs permissible limits of 20 ppmv. In addition, the emitted HCl vapor will be less than 6.70 ppmv (10 mg/Nm3) in the worst-case scenario compared to US EPA’s permissible limits of 12 ppmv;



The steam boiler and the flaking unit will include low No x burners to effectively reduce Nox emissions to meet the EAD permissible limit of 55 mg/Nm3. SOx emissions will be below the MoE’s permissible limit of 500 mg/Nm3;



Regular annual inspection of boiler and flaking unit will be conducted to avoid any excess carbon dioxide release; and



A scrubbing unit with 95% efficiency will be provided to control fugitive emissions during HCl loading.

Project Number 44130065 Page 40

4.3.19. Wastewater Treatment and Management Wastewater sources Waste water generated at the plant will originate from various operations as listed below: 

During regeneration of the ion-exchange resins (employed during secondary brine purification process), wastewater containing trace amounts of dissolved metals (nickel, zinc, iron, copper) will be generated;



During purification of the brine, high concentration of chloride, chlorates, and oxidants may accumulate. Chlorates may also form as by-products during electrolysis. Due to the recycling of the brine, the following components may build-up; o

Sulfate ions may often have a negative effect on the electrolysis process (damages the anode coating). Bleeding of the brine treatment system will be conducted periodically to reduce the levels of sodium sulfate and/or sodium chlorate in the cells. Wastewater will be generated as result of bleeding of the circuit.

o

Chlorinated hydrocarbons may be formed in a reaction between organic contaminants in the electrolyzer and free oxidants. Releases of chlorinated hydrocarbons will normally be very low (approximately 20 kg/year), typically 0.03-1.16 grams per ton of chlorine produced.



Wastewater resulting from wash-outs of unit components, exhaust air scrubber, and floors;



Wastewater generated as a result of caustic evaporation; and



Sanitary wastewater generated during construction and operational phases. Based on internationally accepted standard of 0.25 m 3 of sanitary wastewater generated per person per day, the construction sanitary wastewater for estimated 500 workers will be 125 m3/day, and the operational sanitary wastewater for 45 employees will be 12 m3/day.

As mentioned earlier, with the exception of blowdown water, the proposed plant will not have any wastewater discharge from the cooling water unit.

Control measures to minimize effluent 

Recycling of brine (removing impurities) by ion-exchange resin unit. Subsequent regeneration of resins will be accomplished by using caustic soda and acid washing;



Using spent acid to control pH in process and wastewater streams;

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

Removal of precipitated salts from the brine through decantation/clarification and filtration;



Minimizing the discharge of chlorate to water by applying acid conditions in the anolyte (pH 1-2). Also, chlorate destruction in the brine circuit will be conducted to remove chlorate before purging;



Removal of brine filtration sludge by flushing with a weak HCl solution. The acid will cause the precipitate to dissolve and the resultant solution will be discharged with the liquid effluent to the onsite wastewater treatment plant; and



Recycling of water, wherever possible, utilizing Reverse Osmosis (RO) unit.

4.3.20. Solid Waste Treatment and Management Solid wastes generated at the Chlor-Alkali Plant during the brine purification will consist of used materials such as pre-coat and feed material made of cellulose. The pre-coat filter sludge from the brine softener will consist mainly of alpha-cellulose, contaminated with iron hydroxide and silica. Spent membranes and gaskets from membrane cells will be other waste streams remaining after their service life. The solid waste generated at the proposed plant will be managed as per a Waste Management Plan (WMP). On a general level, waste will be stored in a dedicated area and will be disposed following relevant EAD regulations.

4.3.21. Fire and Toxic Gas Release Prevention and Control The equipment configuration at the proposed plant will conform to best practices for modern Chlor-Alkali plants. Due to vulnerability of fire and toxic gases in any Chlor-Alkali plant (direct and indirect), the following effective preventive and control measures will be taken at the proposed Al Ghaith plant to minimize fire or other hazards and consequential damages:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Installation of fire detection and alarm system;



Installation of hydrant system;



Installation of automatically activated high velocity sprinkler system;



Placement of portable fire extinguishers;



Tie-up of hydrogen gas generated in the cell room to the gas header;



Use of "intrinsically safe" electrical equipment in the selected plant areas;

Project Number 44130065 Page 42



4.4.

A little amount of hydrogen gas will be vented to the atmosphere during upset conditions through safety release valves. Venting system will be so designed that concentration level of hydrogen in air will be always less than 1% with following auxiliary equipment: o

Flame arrestor in the vent line;

o

Flame sensor near vent point;

o

Automatic purging of steam in the vent pipe (interlock with flame sensor will be provided);

o

Stack height will be designed as per the standard guidelines.



Installation of chlorine absorption unit designed with a treatment capacity sufficient to absorb the full cell-room production in the event of emergencies;



Installation of chlorine and hydrogen gas detectors in the electrolysis cell room;



Implementation of Waste Air Dechlorination (WAD) in the sodium hypo plant for neutralizing quantity of waste gas arising out of electrolyzer’s operation. This system, utilizing double-stage scrubbing mechanism, will be designed to neutralize all chlorine produced at full capacity for 15 minutes;



The composition of the vent stream that will be vented from chlorine absorption unit and WAD during the normal operation will be as follows: 

Air saturated with water: 99.9999%



Chlorine gas: 0.0000045%



HCl: Nil



Entire equipment will be backed-up by emergency power generator set;



Operation of control and instrumentation system enabling an automatic operation of the unit by controlling the important process parameters such as temperature, feed rate and liquid levels, monitoring the critical parameters with pre-alarms, and interlocks for personal safety and material protection; and



Transportation of the raw materials and finished goods (in and out of the plant, respectively) will be conducted safely and will be in compliance with applicable UAE rules and regulations and international conventions.

Project Status and Schedule

4.4.1. Current Status The Chlor-Alkali Project is currently within the development phase. The current status of project implementation up to October 2011 includes the following: 

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Submission of initial draft PEHSR to Al Ghaith for comment 20 August 2011;

Project Number 44130065 Page 43

 

Submission of initial draft PEHSR to Zonescorp on 27 August 2011; And….

4.4.2. Project Schedule The current project schedule, including planned components and phases, is presented within Annex XX.

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5.

ENVIRONMENT, IMPACTS, MITIGATION AND MONITORING 5.1.

Air Quality

5.1.1. Description of the Environment 5.1.1.1.

Regional Climate and Meteorology

The climate of the region is bi-seasonal, characterised by high temperatures and low rainfall. The summers (May to October) are distinctly hot, with daytime temperatures regularly exceeding 40°C. Rainfall occurs occasionally during the summer, but is generally restricted to the cooler winter months (November to April) when temperatures can drop to 4°C in some areas (usually inland) at night. Seasonal fluctuations in temperatures are less well pronounced along the coast, where they are buffered by the maritime influence. Annual rainfall amounts vary according to location, but precipitation generally decreases from north-east to southwest along the UAE. Coastal areas such as Abu Dhabi receive about 80 mm of rain annually. Fog occurs on 31 days or an average of 106 hours per year near the coast. Also near the coast fog is more frequent in winter (76 days on average) than in summer to (48 days on average). Fog incidence can last from half an hour to 10 hours, depending on the time of formation and the weather conditions. Humidity peaks in July and August at over 90%, and decreases through October, with the least occurring from November through to April. The humidity over the cooler months can fall to 10-20%. The weather during much of the year is dominated by a ridge of high pressure extending southwards into central Saudi Arabia with lower pressure over the eastern Gulf. The result of this is the prevailing winds from the north and north western quadrants, known by their Arabic name ‘shamal’, meaning ‘north’. Shamals occur mainly during the cooler months, however they can also occur during the hot season, typically June and July. Along the western coastal plain, sea breezes tend to dominate with light south southeasterlies at night being replaced by moderate northwesterly winds during daytime. A strong northerly shamal is usually preceded in the UAE by strong southerly winds, raising desert sands and reducing visibility. The shift to northerly winds may be quite sudden and can be accompanied by rain, thunderstorms, or dust storms. 5.1.1.2.

Ambient Air Quality

The main source of air pollutants in Musaffah is traffic in addition to different industrial activities, all contributing to emissions from small workshops and larger industrial processes in the area.

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Modelled Air Quality Computer modelling was used by EAD to assess impacts of emissions from stacks and traffic on ambient air quality in different areas. Impacts of each source was be modelled separately, thus allowing the identification of its contribution to the observed pattern. The simulation model used produced hourly averages and maxima, 6-months averages and maxima, and yearly averages and maxima. NO2 The air pollution dispersion calculations show that inside the Abu Dhabi city, due to emission conditions and prevailing wind, traffic is the main contributor to impact of nitrogen oxides. The proposed one-hour air quality guideline for NO 2 (200 μg/m3) is exceeded inside Abu Dhabi city with the emissions from traffic alone (Error: Reference source not found), but not in Musaffah. However, point sources like power plants will give increased impact downwind in prevailing wind directions. Their contribution, added to the contribution from traffic, can lead to exceedance of the proposed air quality guidelines in areas outside the city centre (Error: Reference source not found) where these guidelines were not exceeded with the contribution from traffic alone. Again, the present one-hour air quality guideline for NO2 is not exceeded in Musaffah.

Figure 5-10 1-hour average NO2 concentrations (μg/m3) from traffic emissions in Abu Dhabi city (EAD, 2007)

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Figure 5-11 Maximum 1-hour average NO2 concentrations (μg/m3) from traffic and industrial emissions in Abu Dhabi city (EAD, 2007)

PEHSR Chlor-Alkali Plant Al Ghaith Industries

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SO2 The maximum 1-hour SO2 concentrations in Abu Dhabi city and surroundings does not exceed the one-hour air quality guideline for SO 2 (350 μg/m3), but it reaches a maximum of 250 μg/m3 in MIA (Error: Reference source not found). In the centre of Abu Dhabi city the maximum 1-hour SO2 concentrations are between 100 and 125 μg/m 3.

Figure 5-12 Maximum 1-hour average SO2 concentration (μg/m3) from traffic and industrial emissions in Abu Dhabi city (EAD, 2007)

Additionally, air quality in MIA was also measured in 2008 by a mobile laboratory over a 10-day period during the summer months. The mean measured values were averaged  to 1 hour, 8 hour, 24 hour and/or 1 year values for the parameters for which applicable EAD Ambient Air Quality Standards (AAQS) exist. Neither the measurements nor the calculated averaged values (Error: Reference source not found) exhibited exceedances of the EAD AAQS parameters, except PM 10. For PM10, the 10-day measured value mean and the calculated averaged value both exceeded the respective EAD AAQS. This can be attributed to the emissions from industrial activity with in MIA as well as the naturally high levels of PM10 occurring in the region due to its sandy top land profile (EAD, 2007).



This averaging was carried out using an in-house calculation method. The averaged values were derived from the 10-day measured mean value.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

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Table 5-7 Ambient Air Quality in Musaffah 10-day Measured Values (g/m3) Parameter Mean

Minimum

Maximum

NOX NO

83.7 20.2

4.5 0

446.4 120.9

NO2

52.8

3.3

120.2

SO2

14.7

1.9

67.2

H2 S

9.7

2.6

24.3

CO

0.6

0.1

1.5

O3

41.4

0

126.3

PM10

135

28

572

Calculated Averaged Value (compared to Mean)

Averaging Period

EAD AAQS

N/A

N/A

N/A

158.0 83.7 44.0 23.3 7.2 N/A 1.8 1.2 123.9 81.7 214.0

1 hour 24 hour 1 hour 24 hour 1 year N/A 1 hour 8 hour 1 hour 8 hour 24 hour

400 150 350 150 60 N/A 30,000 10,000 200 120 150

(g/m3)

More recently, the ADNOC carried out continuous air quality monitoring employing a mobile air quality monitoring station (trailer) positioned at the ESNAAD MIA site between 11 May, 2009 and 27 September, 2009. The parameters monitored were: SO 2, NO2, O3, CO, PM10, NMHC, CH4 and H2S. Details of the monitoring methodology and reporting are available in the Ambient Air Quality Monitoring at ESNAAD report produced by Nahla Medical Supplies (Nahla Medical Supplies, 2009). In summary, the monitoring results demonstrated that NO 2 1 hour and 24 hour averaged concentrations, SO2 1 hour and 24 hour averaged concentrations, and CO 1 hour and 8 hour averaged concentrations were in compliance with their applicable corresponding Ambient Air Quality Standards (AAQS). For O3, the 1 hour averaged concentration was in compliance with the applicable corresponding AAQS. The 8 hour averaged concentration, however, exceeded the applicable corresponding AAQS 9, 6, 2 and 2 times in May, June, July and August 2009 respectively. For PM10, 24 hour averaged concentration exceeded the applicable corresponding ADNOC AAQS 3, 21, 22, 18 and 6 times in May, June, July and August 2009 respectively. According to the survey report (Nahla Medical Supplies, 2009), these exceedances can be attributed to a dust haze episode occurring over the Middle East during the monitoring period.

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5.1.2. Environmental Impact Prediction and Evaluation 5.1.2.1.

Emissions from Operation of Fuel-Consuming Vehicles and Equipment

Construction During the construction period, operation of vehicles and construction equipment with internal combustion engines will lead to exhaust emissions of combustion products including NO2, SO2, CO and PM10. Small amounts of volatile organic carbon compounds (VOC) may also be emitted from unburned fuel in the equipment engine exhausts or other fugitive emission sources such as fuel pipe fittings. The air emissions inventory for all construction activities is presented in Table 4-4 and 45, in Section 4.3.18. Due to the industrial nature of the Project area and existing operational emission sources in adjacent industrial plants, incremental additions to the existing pollutant concentrations from construction activities will be relatively small, transient, and restricted to the immediate vicinity of the work site (i.e. within approximately 500 meters downwind of the construction activity). It is to be noted that levels of particulate matter (PM 10) in the air are already high in the region due to the surrounding desert environment, existing soil disturbance, and winds. Based on the above information, it is considered that the overall environmental impact to air quality in the Project area for this aspect due to construction activities is of low risk. Probability

Consequence

Significant

Rare

Minor

Low Risk

Operation This section presents the air quality impact assessment from potential air quality impacts associated with normal operations of the proposed Chlor-Alkali Plant. The air quality impacts have been assessed in terms of predicted changes to air quality in the vicinity of the proposed plant. Atmospheric emissions will be generated through the operation of gas-fired plant equipment, boiler, and flaking unit within the plant site. The Chlor-Alkali Plant process design will utilize low-NOx burners for its single steam boiler and flaking unit that will comply with EAD equipment-specific emission standards. The air emissions inventory for all construction activities is presented in Table 4-4 and 4-5, in Section 4.3.18. Most of the emission sources are not expected to have high criteria or GHG emissions. The GHG emissions from these stacks will be mostly CO 2 and negligible quantities of Methane during certain phases of the process cycle. The process will also be equipped for hydrogen venting during emergencies. These venting events will be of very brief duration and are not expected to have any significant impact on the air quality.

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The primary criteria air contaminants of interest for the Chlor-Alkali Plant project are NOx and SO2, both of which are combustion derived. The proposed Chlor-Alkali Plant will emit an overall total of 5 tons NO x/year and 32 tons SO2/year. Since the proposed project will combust only natural gas, the resultant impact from CO and PM 10 will be minimal. Due to the nominal magnitude of the NO x and SO2 emissions from the Chlor-Alkali Plant, air quality dispersion modeling was not performed. The balance of the criteria pollutant (i.e., CO, VOC and particulates) emissions are typically not under consideration for air quality modeling. Based on the above information, it is considered that the overall environmental impact to air quality in the Project area for this aspect due to construction activities is of moderate risk. Probability

Consequence

Significant

Likely

Minor

Moderate Risk

Decommissioning At the end of lifecycle of the Chlor-Alkali Plant, it is assumed all the assets of the site will be decommissioned and the site will be restored, so far as is possible, to its original condition. It is also assumed, therefore, that the foundations of the plant will also be removed. The impacts to air from operation of fuel consuming vehicles and equipment are likely to be very similar to those of the construction phase. Therefore, it is considered that the overall environmental impact to air quality in the Project area for this aspect due to decommissioning activities is of low risk.

5.1.2.2.

Probability

Consequence

Significant

Rare

Minor

Low Risk

Emissions from Accidental Events

Construction Accidental liquid or solid fuelled fires during construction activities would lead to deterioration of ambient air quality. These fire(s) can be caused due to the presence of an ignition source in the vicinity of the fuel storage tanks or an electrical short-circuit taking place in the equipments’ internal or external wiring connections. Such a situation would lead to emission of typical combustion products such as CO, NO x, SO2 etc. In addition to this, ignition of any flammable maintenance-related chemicals within the site temporary facilities or site, as well as occupation of the site offices by construction personnel poses a risk to ambient air quality due to a fire occurring within these buildings. Potential causal factors for this could include human accidents involving ignition sources

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such as cigarettes as well as environmental factors such as build-up of high temperatures within the chemicals storage area due to high ambient temperatures. Such a situation would lead to emission of typical combustion products. It is to be noted, however, that air quality impacts from any of the afore-mentioned events would be short-term in nature i.e. only present until the fire is extinguished or the fuel runs out. Therefore, it is considered that the overall environmental impact to air quality in the Project area for this aspect due to construction activities is of low risk. Probability

Consequence

Significant

Rare

Minor

Low Risk

Operation Accidental chlorine gas release impacts generally associated with chlor-alkali industrial facilities are unlikely to occur during the operation of Chlor-Alkali Plant based on the proposed preventive and control measures. The common causes of chlorine gas release at chor-alkali facilities are listed below. These causes are ranked in the order of severity of the leak and the hazard posed by its occurrence. 1. Fire 2. Flexible connection failure 3. Fusible plug corrosion 4. Accidents caused by carelessness and ignorance 5. Valve packing failure 6. Gasket failure 7. Piping failure 8. Equipment failure 9. Physical damage of containers in collision accidents 10. Container failure 11. Chlorine pressure gauge failure

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The USEPA has determined that chlorine is not a persistent pollutant, in that it photolyzes rapidly to hydrochloric acid (HCl), a much less toxic substance, following the release. Chlorine, as a powerful oxidizer, attacks the lungs, causing inflammation (pneumonitis) and fluid accumulation (pulmonary edema), and is intensely irritating to the eyes; prolonged and/or acute exposure may be fatal. Table 5 -8 below summarizes typical symptoms of exposure to various concentrations of chlorine. Table 5-8: Summary of Chlorine Health Effects Concentration (ppm in air)

Health Effects

1-3 ppm

Mild mucous membrane irritation

5-15 ppm

Upper respiratory tract irritation

30 ppm

Immediate chest pain, vomiting, shortness of breath (dsypnea) and cough

40-60 ppm

Inflammation of lung tissues (toxic pneumonitis) and fluid accumulation (pulmonary edema)

430 ppm

Death within 30 minutes

1,000 ppm

Death within a few minutes

The Emergency Response Planning Guideline Level 2 (ERPG-2) value for chlorine gas is 3 ppm, which is set as end point concentrations for chlorine gas plume during emergency response. ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual’s ability to take protective action. The American Industrial Hygiene Association (AIHA) publishes ERPG levels for various chemicals (http://www.aiha.org/Committees/documents/erpglevels.pdf.). If an EPRG-2 value has been published, the Emergency Response Guideline uses this number for setting the Protective Action Distance (PAD). If an ERPG-2 value has not been established, the PAD is set at 0.01 x Lethal Concentration (LC) 50. The other useful exposure limits for chlorine are presented below in Table 5 -9.

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Table 5-9: Other Useful Exposure Limits for Chlorine Standard Setting Body

Permissible Exposure, (ppm)

Description

National Institute of Occupational Safety and Health (NIOSH)

0.5

Recommended Limit (REL)

American Conference of Governmental Industrial Hygienist (ACGIH)

0.5

Threshold Limit Value (TLV) – Time Weighted Average (TWA)

UK Health and Safety Executive (HSE)

0.5

Long-term exposure limit (8 hour), OEL

USEPA

0.5

Environmental air limit

Occupational Safety and Health Administration (OSHA)

1.0

Permissible Exposure Limit (PEL)

NIOSH

1.0

Short Term Exposure Limit (STEL)

ACGIH

1.0

STEL

UK HSE

1.0

STEL, OEL

NIOSH

10

Immediately Dangerous to Life or Health (IDLH)

Exposure

Therefore, it is considered that the overall environmental impact to air quality in the Project area for this aspect due to operational activities is of moderate risk. Probability

Consequence

Significant

Rare

Major

Moderate Risk

Decommissioning At the end of the lifecycle of the Chlor-Alkali Plant, it is assumed all the assets of the site will be decommissioned and the site will be restored, so far as is possible, to its original condition. It is also assumed, therefore, that the foundations of the plant will also be removed. The impacts to air from accidental events occurring are likely to be very similar to those of the construction phase, especially due to the similar equipments that will be used during

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both phases, as well as movement of flammable substances off site. In the events of a fire occurring due to an accident during the decommissioning activities, typical combustion products will be emitted. Similar to the construction phase, it is expected that air quality impacts from any of the afore-mentioned events would only occur until the fire is extinguished. Therefore, it is considered that the overall environmental impact to air quality in the Project area for this aspect due to decommissioning activities is of low risk.

5.1.2.3.

Probability

Consequence

Significant

Rare

Minor

Low Risk

Emissions of Greenhouse Gases

The Greenhouse Gas Protocol developed and issued by the World Resources Institute and the World Business Council for Sustainable Development (WRI/WBCSD) defines different sources of greenhouse gas emissions into a series of categories or “scopes”. These definitions, as described below, have been used to determine the scope and sources of emissions to be considered for the carbon footprint of the proposed Al Ghaith Chlor-Alkali Plant: Scope 1 Direct Emissions – these are defined as GHG emissions from sources the reporting company owns or controls including the following examples: 

Generation of electricity, heat, or steam. These emissions result from combustion of fuels in stationary sources, e.g., boilers, furnaces, turbines.



Physical or chemical processing. Most of these emissions result from manufacture or processing of chemicals and materials, e.g., cement, aluminum, adipic acid, ammonia manufacture, and waste processing.



Transportation of materials, products, waste, and employees. These emissions result from the combustion of fuels in company owned/controlled mobile combustion sources (e.g., trucks, trains, ships, airplanes, buses, and cars).



Fugitive emissions. These emissions result from intentional or unintentional releases, e.g., equipment leaks from joints, seals, packing, and gaskets; methane emissions from coal mines and venting; hydrofluorocarbon (HFC) emissions during the use of refrigeration and air conditioning equipment; and methane leakages from gas transport.

Scope 2 Indirect Emissions – these are defined as GHG emissions from the generation of purchased electricity that is consumed in a company’s owned or controlled equipment or operations. Scope 3 Other Indirect Emissions – these are defined as indirect GHG emissions that do not fall within Scope 2.

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Some of these activities will be included under scope 1 if the pertinent emission sources are owned or controlled by the company (e.g., if the transportation of products is done in vehicles owned or controlled by the company). GHG emissions from the Chlor-Alkali Plant will consist primarily of nominal quantities of CO2. CO2 emissions from normal operation of the natural gas fired units (boiler and flaking unit) were estimated using USEPA AP-42 emission factors, and are provided in Table 4 -5 and Table 4 -6. These estimates amount to a total of only 5521 t/year of CO 2. This proportion is expected to be significantly lower based on future estimates of national CO2 emissions when the Chlor-Alkali Plant is operational. Fugitive emission of CO2 is likely during the purification of brine with sodium carbonate, and it is estimated that 10 gm of carbon dioxide is released per ton of caustic soda production. Fugitive CO2 emission is also likely from the chlorine destruction unit and handling. It is considered that the overall environmental impact to air quality in the Project area for this aspect due to construction, operation and decommissioning is of low risk.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Significant

Likely

Insignificant

Low Risk

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5.1.3. Mitigation Measures 5.1.3.1.

Potential Mitigation Measures

Phase

Consequence

Impact Description

Probability

Score

Risk

Applicable Environmental Standard / Limits

Potential Mitigation

Adopt traffic routing to maximise travel on paved roads wherever possible. Minor

Construction

Rare

Enforce speed restrictions Low

Ensure minimization of double-handling Ensure wet suppression of unpaved routes

Enforce speed restrictions

Operation

Minor

Ensure minimization of double-handling Likely

Emissions from Operation of Fuel-Consuming Vehicles and Plant Equipment

Ensure regular maintenance of construction machinery and vehicles to ensure efficient operation

Low

Ensure regular maintenance of construction machinery and vehicles to ensure efficient operation

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Minor

Decommissioning

Rare

Regular maintenance of the GTs according to manufacturer specifications to limit potential for nondesign emissions due to malfunction

Low

Same as for the Construction Phase

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EAD Ambient Air Quality Standards for the Emirate of Abu Dhabi WHO Air Quality Guidelines 2005 IFC EHS Guidelines on Air Emissions and Ambient Air Quality 2007

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Construction, operation and decommissioning

Consequence Insignificant

Emissions of Greenhouse Gases

Phase

Likely

Impact Description

Probability

Score

Risk

Low

Applicable Environmental Standard / Limits

Potential Mitigation

Ensure valves on refrigerant gas cylinders are normally kept shut Use of alternate refrigerants that do not have a GHG impact.

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Not Applicable

Phase

Consequence

Impact Description

Probability

Score

Risk

Construction

Minor

Ensure appropriate internal wiring is utilised in construction machinery and it is run according to the manufacturer’s specifications as well as regularly inspected and maintained.

Rare

Emissions from Accidental Events

Applicable Environmental Standard / Limits

Potential Mitigation

Low

Prepare a project emergency response plan addressing appropriate emergency procedures to be followed in case of a fire occurring during construction works. Ensure appropriate temporary storage of chemicals on site in cognizance of their flammable nature and in accordance with industry best practices. Enforce an indoor no-smoking policy and train relevant employees in fire safety to minimise occurrence of human-induced fires.

Major

Operation

Rare

Procedural safeguards such as operating procedures and training will be required as good management practices. Moderate

Enforce a no-smoking zone around the back-up fuel storage tanks to minimise the potential for fuel ignition

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Minor

Decommissioning

Rare

Enforce site emergency response requirements in the event of a fire occurring, to facilitate putting it off at the earliest possible

Low

Same as for the Construction phase

Project Number 44130065 Page 59

EAD Ambient Air Quality Standards for the Emirate of Abu Dhabi WHO Air Quality Guidelines 2005 IFC EHS Guidelines on Air Emissions and Ambient Air Quality 2007

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Project Number 44130065 Page 60

5.1.3.2.

Selected Mitigation Measures

Emissions from Operation of Fuel-Consuming Vehicles and Equipment Construction The overall potential for significant adverse impacts from construction-generated dust is considered to be unlikely due to the following reasons:  Project construction activities will mostly involve native soils as per the Soil Baseline Assessment conducted at the project site;  Dust and fugitive emissions are controlled through the application of the following measures:  Regular inspection and dust suppression (misting) of stockpiles where necessary (including wind shielding, storage away from site boundaries, and restricted height of stockpiles);  Provisions for wheel washing and wet suppression during loading of wagons / vehicles in instances of potential high dust environments;  Covering vehicles carrying dry spoils and other wastes;  Restricting vehicle speeds on access roads and other unpaved areas of the site. A maximum speed of 20 km per hour will be strictly enforced over all unimproved surfaces within the construction zones;  Equipment exhausts will be directed vertically upwards where possible and stationery equipment will be sited as far from sensitive receptors and inhabited buildings as is feasible;  Wherever possible plant and equipment engines will not operate for long periods if the equipment is not in use. When feasible, electrically powered equipment will be used instead of petrol or diesel, including welding machines, pressure washers, air compressors, etc.;  Unpaved roads will be routinely misted with water during dry periods and according to weather conditions; and  No onsite burning or incineration of waste materials will be allowed within the construction zones. Operations The steam boiler and the flaking unit will include low NOx burners to effectively reduce NOx emissions to meet EAD permissible limit of 55 mg/N m3. The SOx emissions will be below the MoE’s permissible limit of 500 mg/Nm3. Entire chlorine gas from the electrolysis section will be will be sent to the main chlorine gas header in the HCl synthesis unit. Chlorine-containing waste gas streams will be diverted to the chlorine absorption unit where it will be absorbed by diluted caustic in the

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scrubber to produce sodium hypochlorite. The chlorine absorption unit will be designed with a treatment capacity sufficient to absorb the full cell-room production in the event of emergencies. The chlorine absorption unit will lower the chlorine content in the emitted gas during operation to less than 1.72 ppmv (5 mg/Nm3) in the worst-case scenario compared to 20 ppmv of USEPA’s permissible limits - Maximum Achievable Control Technology (MACT). In addition, the emitted HCl vapour will be less than 6.70 ppmv (10 mg/N m3) in the worstcase scenario compared to 12 ppmv of USEPA’s permissible limits (MACT). All of the hydrogen gas produced during electrolysis of salt in the production will be used onsite as chemical feedstock for production of HCl in the HCl synthesis unit. The hydrogen gas will be safely handled in the production of HCl by providing an emergency vent in the process line. The entire vent system will be designed to include a flame sensor and a steam and nitrogen purging mechanisms. In addition, the process safety relief valves will be connected to vent system, and during process upset, these safety relief valves will be activated for venting the hydrogen gas to avoid unsafe conditions. The Chlor-Alkali Plant will also install hydrogen gas holder in the system to minimize the process upsets and to reduce venting. During loading of caustic and NaOCl, fugitive emissions are not anticipated. However, fugitive emissions are likely during HCl loading. A small scrubbing unit with an efficiency of 95% will be provided to control these fugitive emissions during HCl loading. Expected HCl concentration at the loading area will be less than 0.033ppm (0.05 mg/m 3) and the HCl concentration in the scrubber outlet during loading operation will be approximately 0.17 ppm (0.25 mg/m3). In summary, the air emissions under normal operations for the Al Ghaith Chlor-Alkali project are not expected to have any significant impact. Decommissioning Same as for the Construction phase above. Emissions of Greenhouse Gases Construction, Operation and Decommissioning The EPC Site Environmental Manager and/or EPC Maintenance Manager will encourage implementation of good construction practices with respect to handling GHG containing materials such as refrigerants, as mentioned in Section Error: Reference source not found. This will be to ensure that fugitive emissions from improperly closed storage containers are prevented. This would typically involve ensuring that safety valves on refrigerant gas containing cylinders are only opened when they are in use and otherwise kept normally shut to reduce the potential for fugitive emissions.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

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However, the best form of mitigation would be to utilize alternate refrigerant gas that does not have a GHG impact. Emissions from Accidental Events Construction The EPC Site Environmental Manager will ensure that appropriate internal wiring is utilised in construction machinery and it is run according to the manufacturer’s specifications in order to reduce the potential for a fire occurring due to a short-circuit and therefore the resulting combustion emissions. Additionally, it will also be ensured that the machinery is regularly inspected and maintained in order to reduce the potential for nondesign performance of the equipment and therefore resulting higher direct exhaust emissions. The EPC Site Environmental Manager will also ensure that flammable chemicals on site are temporarily stored in accordance with the manufacturer’s and MSDS requirements, in order to reduce the potential for an accidental fire occurring. As a further fire preventative measure, the EPC Site Environmental Manager will also enforce an indoor no-smoking policy within the site buildings (i.e. offices) to reduce the potential for human-induced fires occurring. Relevant employees will also be trained in the measures to be followed in case a fire breaks out so that it can be controlled soon after break-out and the risk to employees’ health reduced. The EPC Site Environmental Manager will also prepare a project emergency response strategy/plan addressing appropriate emergency procedures to be followed in case of a fire occurring during construction works. Again, this will ensure that a fire can be controlled soon after it breaks out and the risk of deterioration of ambient air quality and employees’ health is reduced. Operation The potential for accidental release of chlorine gas poses a risk in chlor-alkali plants, and that can be addressed on several levels requiring mitigation/control measures and emergency response programs. A quantitative risk assessment (QRA) will be performed at the Al Ghaith plant subsequent to commissioning of the plant to further assess the accidental chlorine release hazards. The caustic scrubber, with an overall operating efficiency of at least 95%, will be the primary chlorine gas control device. As discussed earlier regarding the control measures, entire chlorine gas produced will be sent to the main chlorine gas header in the HCl synthesis unit. Moreover, chlorine-containing waste gas streams from the HCl synthesis unit will be diverted to the chlorine absorption unit (hypo unit) where the gas will be absorbed by diluted caustic in a double-staged scrubber to produce sodium hypochlorite. The chlorine absorption unit will be designed with a treatment capacity sufficient to absorb the full cell-room production in the event of emergencies.

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Excess chlorine vented to the scrubber can deplete the active scrubbing material and cause over-chlorination of the scrubber. This will result in release of toxic chlorine gas. Therefore, active safeguards will be incorporated within scrubbing mechanism to avoid over-chlorination. Following active safeguards will be included in the scrubbers to prevent over-chlorination: 

Emergency and automatic shut-off of chlorine upon high Oxidation-Reduction Potential (ORP) alarms. ORP will track the concentration of caustic in the scrubber liquid;



Automatic or remote caustic injection to interrupt decomposition reaction; and



Use of contactors in the scrubbers to maintain slight vacuum on the chlorine vent lines to reduce leaks to atmosphere.

In addition, procedural safeguards such as operating procedures and training will be required as good management practices. Moreover, published guidance on scrubber should provide specific information on the composition, quantity and duration of emission expected during over-chlorination incidents. The emergency response measures to be undertaken in an event of accidental chlorine gas release are included in the Plant Disaster Management Plan (DMP). As discussed in the plan, the initial isolation distance will extend equally in all directions from the release, even upwind. When the gas is released at the ground level, the gas may travel upwind due to natural turbulence created by the wind. Also, studies have shown, under windless, night time conditions, the toxic dense gas spread out in all directions from the source near the ground. As expected, the bulk of toxic gas or vapour plume will be carried downwind. To assure that the plans are well organized for any contingency, the plant has adequate resources to plan for emergency response. Decommissioning Same as for Construction phase. 5.1.3.3.

Mitigation Measures to Address Cumulative Impacts

No cumulative impacts are expected as a result of this project. 5.1.3.4. Residual Impacts There are no significant residual impacts expected as a result of this project.

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5.1.4. Monitoring Program 5.1.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

Emissions from Operation of Fuel-Consuming Vehicles and Plant Equipment Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Site traffic using paved roads

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Maintenance of site vehicles and construction machinery

Monthly

EPC Site Environmental Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Site traffic following speed restrictions

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Site traffic following speed restrictions Construction Wet suppression of unpaved roads

Operation

Double-handling of vehicles minimized

Maintenance of site vehicles and plant machinery

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Monthly

Al Ghaith Environmental Manager

Project Number 44130065 Page 65

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Project Phase

Monitoring Activity

Frequency

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Site traffic using paved roads

Daily

Site traffic following speed restrictions

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Monthly

Al Ghaith Environmental Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Wet suppression of unpaved roads

Maintenance of site vehicles and construction machinery

Al Ghaith Industries

Reporting

Al Ghaith Environmental Manager

Decommissioning

PEHSR Chlor-Alkali Plant

Responsibility

Project Number 44130065 Page 66

Emissions of Greenhouse Gases Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Construction

Shutting off safety valves on refrigerant gas containing cylinders

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Quarterly

Al Ghaith Operations Manager

Quarterly Environmental Report to EAD

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Frequency

Responsibility

Reporting

Weekly

EPC Site Maintenance Coordinator

Weekly Field Maintenance Report

Monthly

EPC Site Environmental Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Flammable chemicals appropriately stored

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Indoor no-smoking policy enforced

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Gas boiler stacks emissions:

Operation

- Concentrations of CO2

Decommissioning

Shutting off safety valves on refrigerant gas containing cylinders

Emissions from Accidental Events Project Phase Construction

Monitoring Activity Appropriate internal wiring utilized in construction machinery

Maintenance of site vehicles and construction machinery

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 67

Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Quarterly

EPC Site Environmental Manager

Quarterly Environmental Audit Report

Daily

Al Ghaith Environmental Manager

N/A

Once

Al Ghaith Health and Safety Manager / Al Ghaith Executive Management

Process / Operational Procedure Documentation

Quarterly

Al Ghaith Environmental Manager

Quarterly Environmental Audit Report

Weekly

EPC Site Maintenance Coordinator

Weekly Field Maintenance Report

Monthly

EPC Site Environmental Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Flammable chemicals appropriately stored

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Indoor no-smoking policy enforced

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Fire response procedure documented and relevant employees trained in it Controlled Access of plant personnel/visitors to site

Operation

Appropriate Plant Disaster Management Plan implemented

Fire response procedure documented and relevant employees trained in it Appropriate internal wiring utilised in contraction machinery

Maintenance of site vehicles and construction machinery Decommissioning

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 68

Project Phase

Monitoring Activity Fire response procedure documented and relevant employees trained in it

Frequency

Responsibility

Reporting

Quarterly

EPC Site Environmental Manager

Quarterly Environmental Audit Report

Monitoring programs suggested in Sections Error: Reference source not found will minimise the impact as far as considered practical, with commitment to these measures provided in Section 7 ‘Statement of Commitments’ of the EIA. These measures will also be reflected in the EPC Contractor’s Project Construction Environmental Management Plan (CEMP) and the Al Ghaith Industries Operations Environmental Management Plan (OEMP). Compliance monitoring carried out as part of implementation of the afore-mentioned documentation (e.g. periodic inspections, audits) will assess for compliance of monitoring with the specified mitigation measures. 5.1.4.2. Monitoring Program for Cumulative Impacts The monitoring program presented in Section 5.1.4.1 is designed to help address both non-cumulative and cumulative impacts. No additional monitoring is planned to deal with cumulative impacts specifically. 5.1.4.3. Monitoring Program for Residual Impacts The monitoring program presented in Section 5.1.4.1 is designed to help evaluate residual impacts. No additional monitoring is planned to deal with residual impacts specifically.

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5.2.

Marine Water

5.2.1. Description of Environment The coast of the UAE forms the southern margin of the Arabian Gulf. EAD (2007) describes the main coastal and marine habitats of Abu Dhabi as seagrass beds, salt marshes, coral and mangrove communities. The Project site is a highly disturbed area. Historically the site would have consisted of sheltered tidal flats consisting of fine-grained sediments, mostly sand and mud. It may have supported mangrove and intertidal communities. Common species found in these environments are crabs, shrimps, gastropods, bivalves, polychaetes, foraminifera and fish. Now the marine environment adjacent to the site is a well defined, dredged boating channel and is likely to contain a low diversity of species. Water depths are relatively shallow and contain a microbial mat type ecosystem. In the restricted lagoons, tidal movement tends to be at right angles to the coast. During low tide extensive parts of channels are exposed and evaporation of the intertidal waters results in increased salinities. The Project site is located in the centre of the MIA, approximately 1.2 km away from the coast. Due to the distance from any marine water, any consideration of impacts is not necessary. There are no information gaps and no baseline survey or mitigation will be required for this aspect. Impacts to local water bodies will be considered in the soil and groundwater section.

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5.3.

Waste Management

5.3.1. Description of Environment The UAE generates some of the highest volumes of waste per capita in the world. About 6 million tonnes of waste is produced in the Emirate of Abu Dhabi annually. The Al Ghaith Project will generate solid waste, liquid waste and hazardous waste streams during construction, operations and decommissioning of the plant which will add to the Emirate’s waste management requirements. Federal Law No. (24) of 1999, Article (52) states that all parties and/or individuals involved in construction and/or demolition activities where waste can be generated, must undertake all necessary precautions to prevent the dispersion of the generated waste to the surrounding environment, including safe storage and transportation of such waste. EAD has recently released a Code of Practice AD EHSMS CoP 16 Waste Management which outlines the responsibilities for waste management. Additional information is contained with the IFC’s EHS Guidelines for Thermal Power Plants. Particular requirements for waste generators are stated within Law No. (21) of 2005 for the Emirate of Abu Dhabi as follows: 

Reduce the generated waste by means of implementing the regulations, methods, techniques and alternatives approved in the Emirate for classifying, sorting, reusing or recycling waste.



Classify the generated waste to hazardous and non-hazardous waste as indicated in the approved relevant guidelines.



In case of contract with the private sector for transporting, storage, treatment or disposal of waste, the following must be carried out by Environmental Service Providers permitted by the Competent Authority.

Waste generated from the Project will be managed using a lifecycle approach, which takes into account the HSE risks associated with storage, handling and disposal. The guiding philosophy is to ensure where possible waste is reduced, reused or recycled. This is achieved through a process of identifying the waste; maintaining an inventory; characterising the wastes; segregation; and then looking for ways to minimise waste generation. Certain plastics, metals, glass, paper products, waste oil, and organic material will be recycled wherever possible. The Abu Dhabi Municipality is responsible for municipal solid waste treatment and disposal in the Emirate. There are approximately ten operational landfill sites within the Emirate. The largest is the Al Dhafra landfill which is approximately 60 km south west of Abu Dhabi city. It is expected this landfill will receive the majority of solid wastes generated by the Chlor-Alkali Project. Recycling centres at the Al Dhafra landfill include construction waste and a proposed tyre recycling facility. The Abu Dhabi Municipality has also planned a composting facility, a new sanitary landfill, and an inert waste landfill area beside the existing landfill at the Al Dhafra site. There are additional plans for five

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Project Number 44130065 Page 71

transfer stations for solid waste in the Western Region on the sites of existing landfills; a new sanitary landfill beside the site of the existing landfill of Ruwais; a green waste composting facility at the Ruwais site; upgrade of the green waste composting facilities at Liwa and Ghayathi, and improved transportation systems for waste between the different sites. Liquid wastes from Al Ghaith are planned to be treated at the 300,000-cubic-metre-a-day (cm/d) Al-Wathba wastewater treatment plant in Abu Dhabi or the 65,000-cm/d Al-Saad wastewater treatment plant in Al-Ain. Hazardous wastes will be removed by the appointed Environmental Service Provider for treatment and disposed at approved Municipality sites. Solid hazardous wastes are mostly disposed to landfill however a specialised plant to treat 15,000 tonnes of hazardous waste has been proposed by the Centre of Waste Management Abu Dhabi for Al Dhafra, about 12km from the current landfill site. Medical waste will be treated within Musaffah and then removed to Al Dhafra landfill for disposal. In Abu Dhabi there are currently only two private companies that collect, transfer and treat medical waste by non-incineration techniques. Hazardous liquid industrial wastes will be treated on site before being either discharged into a sewerage network through consent with Abu Dhabi Sewerage Services Company (ADSSC) or given to an appointed Environmental Service Provider for treatment and disposal.

5.3.2. Environmental Impact Prediction and Evaluation 5.3.2.1.

Solid Waste

Construction The Al Ghaith Project will generate approximately 50 m 3/week of solid waste during the construction phase. This may comprise of scrap metal, timber, rocks, plastic, insulation and packing material used for transport of materials; used lubricating oils, solvents and cleaners from the maintenance of construction equipment; paint; and other wastes. These could potentially impact the soil and groundwater. Solid waste management on site will be described in detail in the CEMP and be done in accordance with AD EHSMS CoP 16 Waste Management. Given the control measures in place the magnitude of impacts from solid waste during construction is considered to be local to the project site. Waste arising from construction operations will occur but will be limited to a finite time period. The consequence of disposing this waste from site will be insignificant. Overall, the risk posed by effectively managed waste disposal will be low.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Likely

Insignificant

Low

Project Number 44130065 Page 72

Operation Solid wastes generated at the Chlor-Alkali Plant during the brine purification will consist of used materials such as pre-coat and feed material made of cellulose. The pre-coat filter sludge from the brine softener will consist mainly of alpha-cellulose, contaminated with iron hydroxide and silica. During operation of sludge filtration, Chlor-Alkali Plant is expected to produce approximately 475 tons of brine sludge waste /year. The sludge filtration system will consist of: 

Sludge receiving tank



Sludge filter



Sludge conveyer



Sludge container for disposal



Filtrate tank



Associated pumps

Brine sludge (based on analysis of sludge cake) will consists of: 

Barium sulphate (BaSO4)



Magnesium hydroxide (Mg(OH)2)



Calcium chloride (CaCl2)



Sodium chloride (NaCl)



Sodium Sulphate (Na2SO4)



Insoluble materials and trace metals (copper, iron, nickel, zinc)

Spent membranes and gaskets from membrane cells will be other waste streams remaining after their service life. Solid waste management on site will be done in accordance with AD EHSMS CoP 16 Waste Management. Waste from site will require frequent disposal, however the consequence of disposing this waste from site will be insignificant. Overall, the risk posed by effectively managed waste disposal will be moderate. Probability

Consequence

Risk

Frequent

Insignificant

Moderate

Decommissioning Decommissioning of the Al Ghaith Plant is expected to create a significant quantity of solid waste, and waste water. Solid waste management on site will be described in detail in the DEMP and be done in accordance with AD EHSMS CoP 16 Waste Management.

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Given the control measures in place the magnitude of impacts from solid waste during construction is considered to be local to the project site. Waste arising from construction operations will occur but will be limited to a finite time period. The consequence of disposing this waste from site will be insignificant. Overall, the risk posed by effectively managed waste disposal will be low.

5.3.2.2.

Probability

Consequence

Risk

Likely

Insignificant

Low

Liquid Waste

Construction It is expected that the Al Ghaith Project construction workers (approximately 500 workers) will be housed within existing worker camp/camps located in the MIA labour camp area, and as a result, approximately 62,500 litres of sanitary wastewater will be generated per day. Aqueous commissioning wastewater will be generated (the bulk being approximately 300 m 3) – during hydro-testing; although it should be noted that hydro-testing will take place infrequently) during the commissioning process. Liquid waste management on site will be described in detail in the CEMP and be done in accordance with AD EHSMS CoP 16 Waste Management. Liquid waste arising from construction operations will occur but will be limited to a finite time period. The consequence of disposing this waste from site will be insignificant. Overall, the environmental risk posed as a result of liquid waste management during the construction phase will be low. Probability

Consequence

Risk

Likely

Insignificant

Low

Operation It is expected that 8 m3/hour of wastewater will be generated intermittently during normal process by the Chlor-Alkali Plant. Minimal amount of wastewater is also expected to be generated via rainwater/stormwater runoff (approximately 12 liters/hour – discontinuously). i.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Waste water generated at the plant will originate from various operations as listed below: 

During regeneration of the ion-exchange resins (employed during secondary brine purification process), wastewater containing trace amounts of dissolved metals (nickel, zinc, iron, copper) will be generated;



During purification of the brine, high concentration of chloride, chlorates, and oxidants may accumulate. Chlorates may also form as by-products during

Project Number 44130065 Page 74

electrolysis. Due to the recycling of the brine, the following components may build-up; o

Sulfate ions may often have a negative effect on the electrolysis process (damages the anode coating). Bleeding of the brine treatment system will be conducted periodically to reduce the levels of sodium sulfate and/or sodium chlorate in the cells. Wastewater will be generated as result of bleeding of the circuit.

o

Chlorinated hydrocarbons may be formed in a reaction between organic contaminants in the electrolyzer and free oxidants. Releases of chlorinated hydrocarbons will normally be very low (approximately 20 kg/year), typically 0.03-1.16 grams per ton of chlorine produced.



Wastewater resulting from wash-outs of unit components, exhaust air scrubber, and floors; and



Wastewater generated as a result of caustic evaporation.

As mentioned earlier, with the exception of blowdown water, the cooling water unit at the proposed plant will not have any wastewater discharge. ii.

iii.

Control measures to minimize effluent : 

Recycling of brine (removing impurities) by ion-exchange resin unit. Subsequent regeneration of resins will be accomplished by using caustic soda and acid washing;



Using spent acid to control pH in process and wastewater streams;



Removal of precipitated salts from the brine through decantation/clarification and filtration;



Minimizing the discharge of chlorate to water by applying acid conditions in the anolyte (pH 1-2). Also, chlorate destruction in the brine circuit will be conducted to remove chlorate before purging;



Removal of brine filtration sludge by flushing with a weak HCl solution. The acid will cause the precipitate to dissolve and the resultant solution will be discharged with the liquid effluent to the onsite wastewater treatment plant; and



Recycling of water, wherever possible, utilizing Reverse Osmosis (RO) unit.

Treatment of waste water from the proposed plant:

Al Ghaith plans to install a wastewater treatment plant (WWTP) onsite to treat the wastewater generated. The treated effluent will be re-used in the plant as process water and also as irrigation water for the green belt. The effluent from each process/utility area will be collected in trench drains, from where the effluent will be diverted to the collection pit and further to the onsite combined WWTP. Al Ghaith’s WWTP will have a 100 m 3 tank with dual-compartments for neutralization and storage of the wastewater streams.

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The combined WWTP will include: 

Neutralization pit for pH adjustment (addition of acids and alkalis);



Removal of residual chlorine with the addition of sodium bi-sulphite;



Filtration consisting of dual-media sand and cartridge filters;



RO filtration; and



RO permeate recirculation.

The non-recyclable effluent with high Total Dissolved solids (TDS) and RO reject water from the wastewater treatment plant will be disposed off in MIA Waste Management Centre as per the current discharge practices from EAD. It is expected that up to forty five (45) new staff will be required for the Chlor-Alkali Plant (total for both shifts). This will result in generation of approximately less than 12 m 3/day of sanitary water (based on 0.25 m 3/day sanitary wastewater generated per person and the fact that a person will be within the Chlor-Alkali Plant for a few hours per day). Liquid waste management on site will be managed in accordance with AD EHSMS CoP 16 Waste Management. Liquid waste arising from operations will over regularly over a time period of 20 to 30 years. The consequence of disposing this waste from site will be insignificant. Overall, the risk posed by effectively managed waste disposal will be moderate. Probability

Consequence

Risk

Frequent

Insignificant

Moderate

Decommissioning Decommissioning of the Al Ghaith facilities could potentially create a significant quantity of wastewater (if decontamination is required). As mentioned above, a decommissioning plan will be prepared which will also include and provide measures to manage and adequately dispose of wastewater generated during decommissioning. The project will keep its existing wastewater treatment plant in service and decommission it last, whereby the wastewater generated can be treated, thus helping to potentially reduce the impacts. Liquid waste management on site will be described in detail in the DEMP and be done in accordance with AD EHSMS CoP 16 Waste Management. Liquid waste arising from decommissioning operations will occur but will be limited to a finite time period. The consequence of disposing this waste from site will be insignificant. Overall, the environmental risk posed as a result of liquid waste management during the construction phase will be low. Probability

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Consequence

Risk

Project Number 44130065 Page 76

Likely

5.3.2.3.

Insignificant

Low

Hazardous Waste

The Al Ghaith Plant is not expected to generate hazardous waste; in case it does generate this, then this can be disposed off at the local Hazardous Waste Management facility. Other facilities within MIA will also be generating wastes, but it is expected that the MIA WMF (for regular and hazardous waste) will be able to meet the demands thus helping mitigate the cumulative impacts arising due to waste generation. Hazardous waste management on site will be described in detail during each project phase and will be managed in accordance with AD EHSMS CoP 16 Waste Management. Only designated, trained personnel will have access to the storage area. A spill response plan will be in place and staff will be trained in handling hazardous waste and spill response procedures. Spill kits will be easily accessible around the site during construction. Given the control measures in place the magnitude of impacts from hazardous waste is considered to be local in nature. Overall, it is considered the impact as a result of solid and liquid hazardous waste management during the construction, operation and decommissioning phases will be low.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Possible

Insignificant

Low

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5.3.3. Mitigation Measures Potential Mitigation Measures

Operation

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Frequent

Construction

Likely

Solid Waste

Consequence Insignificant

Phase

Insignificant

Impact Description

Probability

Score

Environmental Risk

5.3.3.1.

Applicable Environmental Standard / Limits

Potential Mitigation

CEMP to include solid waste management. Reduce, reuse, recycling of wastes where possible. Low

Low

Dedicated solid waste storage area on site. Storage area to have hard standing base and appropriate drainage. Segregate wastes where feasible. Inventory maintained for wastes on site.

Project Number 44130065 Page 78

AD EHSMS CoP 16 Waste Management

Environmental Risk

Consequence

Decommissioning

Insignificant

Phase

Probability

Impact Description

Likely

Score

Moderate

Applicable Environmental Standard / Limits

Potential Mitigation

Waste transfer notes used for Environmental Service Providers. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. Good site housekeeping.

Construction

Insignificant

Liquid Waste

Likely

Covering of soil stock piles. Low

CEMP include liquid management. Colour to coded skips andwaste rubbish bins around site. Monitoring andfor treatment of allstorage effluentareas. discharges to the Clear signage solid waste marine environment to ensure that they meet ADWEA’s Training of staff in waste management permissible discharge limits set for this procedures. project. Materialswater ordered a hydrotesting. “as needs basis”. Potable usedonfor Preparation of arecycling decommissioning Reduce, reuse, of wasteswaste wheremanagement possible. plan. Dedicated liquid waste storage area on site.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 79

AD EHSMS CoP 16 Waste Management

Operation

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Environmental Risk

Consequence Insignificant

Phase

Frequent

Impact Description

Probability

Score

Moderate

Applicable Environmental Standard / Limits

Potential Mitigation

Liquid wastes stored in good quality, sealed and labelled drums. Incompatible liquid wastes stored separately. Storage area to have hard standing base and appropriate drainage.

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Environmental Risk

Consequence

Decommissioning

Insignificant

Phase

Probability

Impact Description

Likely

Score

Low

Applicable Environmental Standard / Limits

Potential Mitigation

Segregate wastes where feasible. Inventory maintained for wastes on site. Waste transfer notes used for Environmental Service Providers. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. Good site housekeeping. Clear signage for liquid waste storage areas. Training of staff in waste management procedures. Chemicals ordered on a “as needs basis”. Spill response plan and appropriate staff spill response training in place.

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Environmental Risk

Phase

Consequence

Impact Description

Probability

Score

Applicable Environmental Standard / Limits

Potential Mitigation

CEMP to include hazardous waste management. Dedicated hazardous waste storage area on site. Hazardous liquid wastes stored in good quality, sealed and labelled drums. Incompatible hazardous wastes stored separately. Storage area to have hard standing base and appropriate drainage.

Construction, operations and decommissioning

Minor

Hazardous Waste

Possible

Storage area only to be accessible to approved and trained staff. Segregate hazardous wastes where feasible. Moderate

Inventory maintained for wastes on site. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. Clear signage for hazardous waste storage areas. Chemicals ordered on a “as needs basis”. Spill response plan and appropriate staff spill response training in place. Spill kits easily accessible on site. Preparation of a decommissioning waste management plan.

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AD EHSMS CoP 16 Waste Management

PEHSR Chlor-Alkali Plant Al Ghaith Industries

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5.3.3.2.

Selected Mitigation Measures

Final solid, liquid and hazardous waste mitigation measures will be presented in the CEMP. It is planned that all mitigation measures presented in Section 5.3.3.1 will be implemented as per best practice outlined in EAD Code of Practice AD EHSMS CoP 16 Waste Management. 5.3.3.3.

Mitigation Measures to Address Cumulative Impacts

The mitigation measures presented in Section 5.3.3.1 are designed to help address both non-cumulative and cumulative impacts. No additional mitigation measures are planned to deal with cumulative impacts specifically. 5.3.3.4.

Residual Impacts

Residual impacts associated with all waste management practises will be reduced to low with the implementation of selected mitigation. Impacts will not be removed there will continue to be the potential for accidental impacts from spills and leaks as well as the ongoing impacts from solid waste and controlled effluent discharges. Therefore, scores as presented in Section Error: Reference source not found remain applicable.

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5.3.4. Monitoring Program 5.3.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

Waste type

Measurements

Solid waste

Quantities and types of solid waste stored on site

Daily

Liquid waste

Quantities and types of liquid waste stored on site

Daily

Hazardous waste

Quantities and types of hazardous waste stored on site

Daily

Process water discharge

Water quality testing against ADWEA’s permissible discharge limits set for this project

Monthly

Waste water treatment plant discharge

Water quality testing against ADWEA’s permissible discharge limits set for this project

Monthly

Stormwater discharge

Water quality testing against ADWEA’s permissible discharge limits set for this project

Monthly

Sewage treatment plant discharge

Water quality testing against ADWEA’s permissible discharge limits set for this project

Monthly

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Frequency

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Responsibility Al Ghaith Environmental Manager Al Ghaith Environmental Manager Al Ghaith Environmental Manager Al Ghaith Environmental Manager Al Ghaith Environmental Manager Al Ghaith Environmental Manager Shared Facilities Environmental Officer

5.3.4.2. Monitoring Program for Cumulative Impacts The monitoring program presented in Section 5.3.4.1 is designed to help address both non-cumulative and cumulative impacts. No additional monitoring is planned to deal with cumulative impacts specifically. 5.3.4.3. Monitoring Program for Residual Impacts The monitoring program presented in Section 5.3.4.1 is designed to help evaluate residual impacts. No additional monitoring is planned to deal with residual impacts specifically.

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5.4.

Geology, Seismicity, Soil and Groundwater

5.4.1. Description of the Environment 5.4.1.1.

General Geology

The Arabian Peninsula has a variety of environments, including sand and rock desert, sabkha, and mountains. The UAE occupies a north-east corner of the Arabian Peninsula, and is characterised by the Hajar Mountains running parallel to the east coast and south into Oman along the UAE boarder, vast sand desserts stretching from the plains by the mountains south to the Empty Quarter bordering Saudi Arabia, and coastal Sabkha flats. The coastline is also characterised by a number of offshore islands. The Project site is located on to the south of Abu Dhabi Island. Bedrock in the area is recorded to comprise interbedded variable beds of clastic and carbonate sandstones, gypsiferous mudstone, siltstone, gypsum, limestones, and conglomerates which are mostly Pleistocene or recent in age. Superficial deposits in the area are generally considered to comprise predominantly sand dunes, wind-blown (aeolian) deposits and evaporite deposits interbedded with marine sands and silts. Sabkha deposits are also common along the coastline of the UAE and are generally encountered in the typically flat foreshore zone, where groundwater levels are at or near the surface. The regional geological setting of the Project site is indicated in Figure XXX. 5.4.1.2.

Seismicity

EAD (2008) describes the main tectonic province in Abu Dhabi as a passive plate margin (intracratonic) which is dominated by large, gentle folds of various shapes and size related to differential regional subsidence or uplift along the deep-seated basement faults. Abu Dhabi Emirate is located in the northeast Rub Al Khali basin. The boundaries of this basin are controlled by faults of different ages. Several left-lateral wrench faults have been identified. Around Abu Dhabi a NE-SW fold alignment is dominant (the Jarn Yaphour trend) with a system of faults running parallel to this trend. On the Arabian Shield of the UAE mainland maximum predicted magnitudes are 5.0 – 5.5 (Richter). In general, the Arabian plate is considered to be relatively stable and there is a low risk of a large earthquake occurring in the vicinity of the site. While it remains a low risk, it should be noted that where very loose, water bearing silty fine soils are present on site there is a potential risk of liquefaction under earthquake loading. Liquefaction of fine soils can result in excessive settlement of structures founded above such material. The Al Ghaith Chlor-Alkali Plant site area comprises an upfilled platform of imported material.

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Figure 1-13

Figure 1-14

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Seismic events (plotted dots) within the Southern Arabian Gulf since 1990. Plate boundaries are shown in yellow

Ground acceleration (m/s) with 10% probability of exceedance in 50 years

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5.4.1.3.

Soil and Groundwater

The Project site borders a tidal channel and has a low gradient coastal profile. According to EAD (2008) historically the landscape consisted of wide and extensive intertidal cyanobacterial mats and evaporative flats. The tidal flat sediments and evaporites are flanked by stranded high energy beach ridges and reworked late Holocene Aeolian and outwash fans. The Holocene sediments accumulate on Neogene sedimentary rocks consisting of a sequence of marls, sandstones, limestones and evaporates. Banked up against the Neogene rocks and covering them are Quaternary carbonates. The sedimentary rocks were deposited during the last major glacial eustatic low stand in the Arabian Gulf. These largely Aeolian sands line the inner margins of the present day salt flats or sabkhas, and their surface often lies close to the present water table. They underlie much of the Holocene carbonate/evaporate complex. Since development of the MIA the site has been up-filled and levelled which has changed the nature of the site. The original coastal sabkha characteristics can generally be observed after drilling below two meters below ground level. The up-fill is likely to have been a mix of dredge spoil and imported soil from nearby borrow pits, consisting of carbonaceous materials and silicates. The site is no longer influenced by tidal inundation. It will however experience occasional heavy rainfall from storm events. Due to its close proximity to the channel the water table will largely mirror the average seawater level. Water levels are therefore likely to be two or three meters below ground level and experience some mixing with the seawater. Due to the high salinity of the groundwater it is not used for any potable, irrigation or industrial use. It is not known whether there are any monitoring wells on site. The site has been used for general material storage up until now and there is no known contamination of soil or groundwater on site.

5.4.2. Environmental Impact Prediction and Evaluation The proposed development is within an industrial site. The top soil at the site has been removed, so there will be no new impact with regard to the loss or deterioration of soil as a result of this project. As natural groundwater quality in MIA is saline and it is not suitable for domestic or industrial use, the main concern is that groundwater could provide a pathway for contaminants to move away from their source, and possibly into the marine environment. Groundwater occurs at a shallow depth beneath the site, and the soil profile above the water table has a high hydraulic conductivity, which makes it easy for liquids to move from surface to the water table. Thus the groundwater at this site is particularly vulnerable to contamination from surface or underground sources.

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5.4.2.1.

Contamination of Soils and Groundwater

Construction During construction, there is a risk of spills of fuel and oil from construction equipment and temporary storage tanks. Other substances, such as paints, coating and cleaning products may be used on site, and there is a potential of spills onto the ground, resulting in the contamination of soil and groundwater. These potential impacts should be managed through the use of environmental management plan for the construction phase (CEMP). Storage and disposal areas should be clearly segregated and designed to prevent spills from reaching the ground. Other potential impacts relate to construction phase wastewater. The operation and maintenance of temporary washing areas and toilets should be well managed to prevent the accidental discharge of wastewater onto the ground. The construction wastewater will be collected in a concrete-lined pit, neutralized, filtered and will be reused. Similar potential impacts and management measures apply for the commissioning and start-up phases. In addition, wastewater will be generated due to hydrotesting, cleaning, boil-out and chemical washing of lines, vessels and tanks. A commissioning phase management plan should be developed and followed to prevent the discharge of any effluents and chemicals to the ground. It is considered that the construction impacts relating to soil contamination will be restricted to the site and immediate surrounding areas. The impacts are considered to be temporary (as they will occur during the construction period of the project only) and reversible as long as appropriate clean up operations are carried out allowing excavation and removal of contaminated soils. The impacts could potentially be cumulative if contamination of soils occurs associated with the construction of plant on adjacent industrial facilities. Overall the environmental impact associated with soil contamination during construction is low risk.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Rare

Minor

Low

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Operation The solvents and other chemicals proposed to be used in the process pose a risk of contamination of the soil and groundwater if they are not handled and stored cautiously. Moreover, spills of HCl and sodium hypochlorite might release large amount of acid fumes and chlorine gas, respectively. Any impacts are considered to be reversible through appropriate remediation works. The impacts could potentially be cumulative if contamination of soils occurs associated with the operation of the adjacent plant. Overall the environmental risk associated with soil and groundwater contamination during operation is moderate. Probability

Consequence

Risk

Likely

Minor

Moderate

Decommissioning During decommissioning of the plant there will be the potential for contamination of site soils and groundwater as a result of the planned activities of dismantling and demolition of plant structures and equipment. Details of the decommissioning plan are not available at the time of writing, therefore it is assumed that decommissioning will comprise the removal of all site structures above ground level. Contamination of soil and groundwater could potentially occur as a result of: spillage of residual fluids, oils and chemicals within plant equipment during dismantling; spills and leaks of waste materials stored on site; inappropriate handling of waste materials. A decommissioning phase management plan should be developed and followed to prevent the discharge of any effluents and chemicals to the ground. It is considered that the decommissioning impacts relating to soil contamination will be restricted to the site and immediate surrounding areas. The impacts are considered to be temporary (as they will occur during the period of decommissioning only) and reversible as long as appropriate clean up operations are carried out allowing excavation and removal of contaminated soils and groundwater. The impacts could potentially be cumulative if contamination occurs on adjacent industrial facilities at the during the same period of decommissioning. Overall the environmental impact associated with soil contamination during construction is low risk.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Rare

Minor

Low

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5.4.3. Mitigation Measures 5.4.3.1.

Potential Mitigation Measures

Construction

Consequence

Contamination of Soil and Groundwater

Minor

Phase

Probability

Impact Description

Rare

Score

Significance

Low

Applicable Environmental Standard / Limits

Potential Mitigation

Fuel, oil and chemical storage facilities to include 110% secondary containment. Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities. Provision of spill kits in all vehicles. Waste storage in designated sealed hardstanding area with appropriate spill clean up and containment facilities. Development of a CEMP and monitoring plan. Emergency shut down and spill response procedures for a hazardous waste spill will be required to be developed and implemented by the EPC contractor. Regular inspections of plant and equipment. The EPC contractor will encourage workers to report all spills using a ‘no blame’ culture. If inadvertent leakage or spillage of hydrocarbons occurs, EPC Contractor will implement spill response measures to contain and excavate any contaminated soil present.

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EHSMS CoP 12 – Water Quality and CoP 13 - Land Management version 1.2 July 2009 -

Phase

Consequence

Impact Description

Probability

Score

Significance

Applicable Environmental Standard / Limits

Potential Mitigation

EPC contractor to develop OEMP and environmental monitoring plan. Appropriate protocols will be established for the transfer and disposal of contaminated fuel, oil and soil in accordance with Municipality requirements in the Waste Management Plan.

Minor

Operation

Likely

Fuel, oil and chemical storage facilities to include 110% secondary containment.

Moderate

Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities. Regular inspections of plant and equipment. If any inadvertent leakage or spillage of hydrocarbons occurs, the operator will implement spill response measures to contain and excavate any contaminated soil present. Chemical Management, Waste Management, Emergency and Spill Response plans will be established for the site. All contaminated wastewater will be treated to within appropriate discharge limits prior to disposal.

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EHSMS CoP 12 – Water Quality and CoP 13 - Land Management version 1.2 July 2009 -

Decommissioning

Consequence

Minor

Phase

Rare

Impact Description

Probability

Score

Significance

Low

Applicable Environmental Standard / Limits

Potential Mitigation

It is anticipated that activities and impacts, and hence mitigation measures for decommissioning will mirror the construction phase.

EHSMS CoP 12 – Water Quality and CoP 13 - Land Management version 1.2 July 2009 -

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5.4.3.2.

Selected Mitigation Measures

Contamination of Soil and Groundwater Construction During construction there will be a potential for soil and groundwater contamination from planned activities. Mitigation measures considered to be appropriate for this project comprise the following: 1. Secondary containment (i.e. drip pans or concrete containment) will be provided for fuel and chemical storage tanks such that containment is designed for a minimum of 110% of the total volume of the largest storage tank 2. Fuel and chemical storage tanks will be located at a designated position and appropriate clear signage and barrier protection from vehicular movements. 3. All hard-standing and bunds will be inspected on a regular basis and cracks reported and repaired. 4. All temporary fuel storage tanks will be double-walled containers. 5. Acid wash waste, if applicable, during commissioning will be fully contained and removed from site by authorised waste management contractors. 6. Refuelling will be undertaken in designated areas following set procedures, to be set out in the CEMP. 7. Vehicles operating on site will undergo routine maintenance and regular inspection to minimise the potential for leakage of oil and other fluids. 8. A regular equipment and tank inspection and repair program will be developed on site. 9. Emergency shut down and spill response procedures for a hazardous waste spill will be required to be developed and implemented by the EPC contractor. 10. The EPC contractor will encourage workers to report all spills using a ‘no blame’ culture. 11. If any inadvertent leakage or spillage of hydrocarbons occurs, the EPC Contractor will implement spill response measures to contain and excavate any contaminated soil present. 12. Chemical Management, Waste Management, Emergency and Spill Response plans will be established for the site. 13. Appropriate protocols will be established for the transfer and disposal of contaminated fuel, oil and soil in accordance with Municipality requirements in the Waste Management Plan.

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14. Construction activities will not be scheduled when there is a significant potential for rainfall and torrential run offs. 15. Adequate dust suppression, erosion and sedimentation controls will be established as part of the CEMP, and appropriate soil conservation measures taken including limiting the disturbed area. 16. Wherever possible use will be made of approved recycling facilities within the UAE. 17. Temporary sewage units will be regularly inspected, maintained and emptied by authorised waste management contractors. 18. All contaminated wastewater will be treated to within appropriate discharge limits prior to disposal. 19. Treated sanitary wastewater will be treated to within appropriate discharge limits prior to release to soakaways. These measures when followed properly as part of a rigorous CEMP are considered appropriate to mitigate against the potential for soil and groundwater contamination. Operation During operation of the plant there will be a potential for soil and groundwater contamination from planned activities. Mitigation measures considered to be appropriate for this project comprise the following: 1. EPC contractor to develop OEMP including an environmental monitoring plan. 2. Appropriate protocols will be established for the transfer and disposal of contaminated fuel, oil and soil in accordance with Municipality requirements in the Waste Management Plan. 3. Fuel, oil and chemical storage facilities to include 110% secondary containment. 4. Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities. 5. If any inadvertent leakage or spillage of hydrocarbons occurs, the operator will implement spill response measures to contain and excavate any contaminated soil present. 6. Chemical Management, Waste Management, Emergency and Spill Response plans will be established for the site. 7. All contaminated wastewater will be treated to within appropriate discharge limits prior to disposal. 8. Routine and regular documented inspections of the chemical/oil/fuel storage facilities and waste storage areas.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

plant

including

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9. Immediate excavation and removal of any contaminated soil to the designated waste facility. These measures when followed properly as part of a rigorous OEMP will largely mitigate against the potential for soil and groundwater contamination. However due to the presence of plant and buildings associated with the facility on site there remains a potential for soil and groundwater contamination to occur which cannot be identified by visual assessment. Decommissioning A decommissioning strategy has not yet been developed for this project. Potential mitigation measures as identified within 5.4.3.2 will be considered further prior to the decommissioning phase and selected mitigation measures, implementation methods and responsibilities detailed within the Decommissioning Environmental Management Plan. For the purpose of this assessment, it is assumed the decommissioning mitigation measures will mirror those as applied during the construction phase. 5.4.3.3. Mitigation Measures to Address Cumulative Impacts The cumulative impacts identified are those that will impact soil and groundwater quality from the combined operation of the current Project (Construction, Operation and Decommissioning phases) and the existing potential releases to the terrestrial environment from sources in the surrounding area where the Project is located. With respect to the cumulative impacts identified for all construction phase aspects, these will exist only for the time the construction activities are in progress, therefore as long as the selected mitigation measures for these aspects detailed in Section 5.4.3.2 are adhered to, no additional mitigation measures are required to address any cumulative impact. With respect to the cumulative impacts identified for all operation phase aspects, leaks and spillages from operation of the plant can be controlled and minimised by implementing the selected mitigation measures for these aspects detailed in Section 5.4.3.2. Assuming that the neighbouring facilities comply with the relevant mitigation measures addressing their potential operational impacts to soil and groundwater, it is envisaged that no additional mitigation measures are required to address the cumulative impact of all the all industrial facilities within the vicinity of the proposed Al Ghaith ChlorAlkali Plant. Cumulative impacts during decommissioning will be similar to that for the construction phase and will occur over a similarly limited timescale.

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5.4.3.4. Residual Impacts Contamination of Soil and Groundwater With the implementation of all of the mitigation measures identified in Section 5.4.3.2, the majority of potential contaminative impacts to soil will be largely removed. There still remains a potential for contamination of soils as a result of the Project however, and therefore the residual risk associated with this is considered to be low.

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5.5.

Marine Ecology

5.5.1. Description of the Environment The coast of the UAE forms the southern margin of the Arabian Gulf. EAD (2007) describes the main coastal and marine habitats of Abu Dhabi as seagrass beds, salt marshes, coral and mangrove communities. The Project site is a highly disturbed area. Historically the site would have consisted of sheltered tidal flats consisting of fine-grained sediments, mostly sand and mud. It may have supported mangrove and intertidal communities. Common species found in these environments are crabs, shrimps, gastropods, bivalves, polychaetes, foraminifera and fish. Now the marine environment adjacent to the site is a well defined, dredged boating channel and is likely to contain a low diversity of species. Water depths are relatively shallow and contain a microbial mat type ecosystem. In the restricted lagoons, tidal movement tends to be at right angles to the coast. During low tide extensive parts of channels are exposed and evaporation of the intertidal waters results in increased salinities. The Project site is located in the centre of the MIA, approximately 1.2 km away from the coast. Due to the distance from any marine water, any consideration of impacts is not necessary. There are no information gaps and no baseline survey or mitigation will be required for this aspect. Impacts to local water bodies will be considered in the soil and groundwater section.

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5.6.

Terrestrial Ecology

5.6.1. Description of the Environment URS has conducted a site-walkover survey of the Project site. The physical appearance of the site is consistent with that of reclaimed and pre-disturbed (cleared) land. The site is largely devoid of flora and fauna. Given the site comprises reclaimed marine dredge spoil, it does not contain any sites of designated terrestrial ecological importance and therefore is not considered to be of any ecological value. This project, therefore, is not expected to have any impact on the terrestrial ecology of the project area and its vicinity.

5.6.2. Environmental Impact Prediction and Evaluation 5.6.2.1.

Loss of Habitat, Flora and Fauna

Construction Information gathered during the site walkover indicated that the ecological diversity and abundance is very low. The site is considered to be of little conservation interest. This is likely due to the reclaimed and levelled nature of the site. In all likelihood the flora and fauna associated with the site will be lost during construction activities. Removal of terrestrial habitats will be permanent and irreversible within the footprint of the plant and transportation routes for the duration of the construction phase of the Project and also for the operational phase. Habitat removal on the site will, however, be of rare probability and insignificant consequence due to the low diversity and abundance of common species on site. Overall, the environmental impact associated with this removal of habitat is considered of low environmental risk. Probability

Consequence

Risk

Rare

Insignificant

Low

Operation The footprint of the works established during the construction phase will remain during the operational phase. Removal of terrestrial habitats will be permanent and irreversible for the duration of the operational phase of the Project. Should any future maintenance or extensions be planned for the site, potential for the removal of additional habitats should be assessed at this time. Habitat removal on the site will, however, be of rare probability and insignificant consequence due to the low diversity and abundance of common species on site. Overall, the environmental impact associated with this removal of habitat is considered of low environmental risk.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Rare

Insignificant

Low

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Decommissioning The footprint of the works established during the construction and operation phases will be removed during the decommissioning phase. At this point there is no decommissioning plan in place and it is not known if the site shall be used for another purpose or returned, in so far as is possible, to its original state. As shown by the evidence of ecological succession on the site since previous filling/levelling activities, it is reasonable to assume that species recolonisation will occur if the site is cleared and restored. Therefore, assuming this case, the impacts will be temporary and reversible. Overall, the environmental impact associated with this activity is considered of low environmental risk.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Rare

Insignificant

Low

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5.6.3. Mitigations Measures 5.6.3.1. Potential Mitigation Measures

Consequence

Environmental Risk

Construction Insignificant

Loss of habitat / Disturbance to Flora and Fauna

Phase

Rare

Impact Description

Probability

Score

Vegetation clearing confined to that necessary for the establishment of the plant. Low

Insignificant

Rare

Operation

Insignificant

Rare Al Ghaith Industries

Management strategies implemented to protect remaining native vegetation communities by controlling the occurrence and spread of weeds and minimising the impact of soil erosion/sedimentation.

-

No specific measures are identified to mitigate the loss of native habitat on site. Low

Decommissioning

PEHSR Chlor-Alkali Plant

Applicable Environmental Standard / Limits

Potential Mitigation

Planting of vegetation (local species including flowering plants, shrubs and trees) to provide ‘green’ areas within plant fence line will provide habitat for species including insects and birds on site. Such areas would also be visually appealing.

-

Site returned, in so far as is possible, to an original state. Low

Management strategies implemented to protect remaining native vegetation communities by controlling the occurrence and spread of weeds and minimising the impact of soil erosion/sedimentation.

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-

5.6.3.2.

Selected Mitigation Measures

Loss of Habitat Construction The impact of loss / disturbance will be realised during the construction phase. As such: 1. Clearing of vegetation will be confined to that necessary for the establishment of the plant. Areas for clearance will be established with the EPC Site Environmental Manager before works. 2. Management strategies will be implemented to protect any remaining native vegetation communities by controlling the occurrence and spread of weeds and minimising the impact of soil erosion/sedimentation. This will include general good housekeeping on site and assessment during the daily site inspection by the EPC Site Environmental Manager. These measures will not fully mitigate the loss of the present habitats as this impact is unavoidable due to the footprint of the plant facilities. These measures will, however, reduce the impact from loss of habitat as far as possible. Operation No specific measures have been identified to mitigate the loss of native habitat on site. However: 1. Planting vegetation composed of local species, preferably coastal, within the available space will provide ‘green’ areas. Such landscaping within the plant fence line will provide some habitat/shelter for species including insects and birds on site, and though not directly mitigating for the impact, will provide areas of some limited value. Such areas would also be visually appealing, particularly if instated in administration or office areas. Basic landscaped areas also cost relatively little to instate and maintain. It should be noted that the impact of habitat loss will be realised during the construction phase and that the operational phase will not further increase this impact. In addition, landscaping mitigation will only provide alternate habitat and limited compensation and will not provide any habitat recreation. Responsibility for landscaping during the operational phase will be with the Al Ghaith Plant Environmental Manager. This activity will be a continual activity, likely falling within the plant maintenance schedule. Decommissioning A decommissioning strategy has not yet been developed for this project. Potential mitigation measures as identified within Section Error: Reference source not found will be considered further prior to the decommissioning phase and selected mitigation measures,

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implementation methods and responsibilities detailed within the Decommissioning Environmental Management Plan For the purpose of this assessment, it is assumed the decommissioning mitigation measures will mirror those as applied during the construction phase. 5.6.3.3.

Mitigation Measures to Address Cumulative Impacts

No cumulative impact was identified, therefore no mitigation is suggested. 5.6.3.4.

Residual Impacts

Loss of Habitat With the implementation of the mitigation as selected in Section 5.9.3.2, the impact will remain low as loss of habitat is unavoidable. Scores as identified in Section 5.9.2 remain applicable. Disturbance to Flora and Fauna No potential mitigation measures have been identified for any project phase due to the fact the site contains a low density and abundance of species and is of low conservation interest. As such, the scores as attributed in Section 5.9.2 remain, and the overall impact on flora and fauna is still considered to be low.

5.6.4. Monitoring Program 5.6.4.1. Monitoring Program for Compliance with Selected Mitigation Measures Monitoring for compliance with selected mitigation measures during the construction phase shall be undertaken by the EPC Site Environmental Manager during daily inspections and shall be recorded within the Field HSE Report and the weekly Environmental Inspection Checklist. No potential mitigation measures have been identified for any other project phase due to the fact the site contains a low density and abundance of species and is of low conservation interest. As such, the scores as attributed in Section 5.9.2 remain, and the overall impact on flora and fauna is still considered to be low. 5.6.4.2. Monitoring Program for Cumulative Impacts No cumulative impacts were identified for any project phase; therefore no monitoring of cumulative impacts is suggested. 5.6.4.3. Monitoring Program for Residual Impacts The effects of the construction, operation, and decommissioning phases of this project on terrestrial ecology are unlikely extend past the site boundaries. As the site has been established as of low biological diversity and abundance, it is thought that the monitoring of residual impacts throughout the lifecycle of the project is excessive and economically unnecessary. The pre-construction survey will include ecological records of the site and

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act as the standard if site restoration activities commence during decommissioning. A post-decommissioning survey will be undertaken to establish the success of the site reclamation if applicable.

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5.7.

Noise

5.7.1. Description of Environment The Project site is located within a larger industrial zone and the background noise environment is dominated by the associated activities, including road traffic, marine vessels and fork-lift trucks.

5.7.2. Environmental Impact Prediction and Mitigation 5.7.2.1.

Emissions from Operation of Vehicles and Temporary Equipment

Construction Operation of light and heavy vehicles and construction equipment (such as those for piling) on site will lead to generation of noise in their vicinity. However, due to the transient nature of these construction works as well as the existing industrial nature of the wider area in which the Project is located, the overall incremental increase in noise levels due to these activities is likely to be minor. Keeping the above in view, it is considered that the overall environmental impact to noise levels in the Project area for this aspect due to construction activities is of low significance. Probability

Consequence

Risk

Likely

Insignificant

Low

Operation It is envisaged that during operation of the Chloro-Alkali plant, only light vehicles will operate within the confines of the plant, with heavy vehicles or temporary constructionrelated equipment employed very rarely for certain maintenance work, as needed. This coupled with the transient and infrequent nature of light vehicular traffic and constructionrelated equipment operation render the overall incremental increase in noise levels due to these activities as minor. Keeping the above in view, it is considered that the overall environmental impact to noise levels in the Project area for this aspect due to operation activities is of low significance. Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning Similar to the Project construction phase, operation of light and heavy vehicles and construction equipment on site during decommissioning and demolition works will lead to generation of noise in their vicinity. However, due to the transient nature of these

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activities as well as the existing industrial nature of the wider area in which the Project is located, the overall incremental increase in noise levels due to these activities is likely to be minor. Keeping the above in view, it is considered that the overall environmental impact to noise levels in the Project area for this aspect due to decommissioning activities is of low significance. Probability

Consequence

Risk

Likely

Insignificant

Low

5.7.2.2. Emissions from Operation of Chlor-Alkali Plant Construction Not applicable. Operation The major sources of noise emissions during operation of the plant will be the key process equipment such as the gas boiler and associated process equipment. It is worth taking note that with respect to ambient noise levels in the wider area where the Project is located, the incremental noise levels generated by operation of the plant are expected to be insignificant due to the location of the plant within MIA / ICAD-1. This is due to the fact that the existing cumulative noise levels in the area will be contributed to by neighbouring industrial processes and steelworks. With all plant operational, there is a potential exceedance of the work area noise limit within the gas boiler and associated process equipment buildings. The project requires that in order to minimise noise exposure on personnel undertaking maintenance work within these buildings the use of removable acoustic screens is required. Hearing protection is recommended in areas where noise levels exceed 85 dB(A) and should be considered mandatory in areas that exceed 90 dB(A). These areas require demarcating with hearing protection signs, particular at the entrances to the buildings noted above. As noise from the operation of the Chlor-Alkali Plant will be ongoing the probability of elevated noise levels occurring is frequent. However, taking into account the location of the plant within the greater MIA the environmental consequence is deemed to be insignificant, and therefore environmental risk will be moderate.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Frequent

Insignificant

Moderate

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5.7.3. Mitigations Measures 5.7.3.1. Potential Mitigation Measures

Construction

Consequence Insignificant

Emissions from Operation of Vehicles and Temporary Equipment

Phase

Likely

Impact Description

Probability

Score

Environmental Risk

Low

Applicable Environmental Standard / Limits

Potential Mitigation

Enforce speed restrictions Equipment used on an intermittent basis to be shut down between work periods or throttled down to a minimum All noisy activities such as piling to be carried out during the day Acoustic covers installed on engines, if applicable, and kept closed when engines in use or idling Ensure regular maintenance of temporary equipment and vehicles to ensure efficient operation as per specifications

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EAD Noise Allowable Limits

Phase

Consequence

Impact Description

Probability

Score

Environmental Risk

Applicable Environmental Standard / Limits

Potential Mitigation

Insignificant

Operation

Likely

Enforce speed restrictions Equipment used on an intermittent basis to be shut down between work periods or throttled down to a minimum Low

All noisy activities such as piling to be carried out during the day

Construction

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Insignificant

Decommissioning

Likely

Ensure regular maintenance of temporary equipment and vehicles to ensure efficient operation as per specifications

Low

No impact

Same as for the Construction Phase

Not applicable

EAD Noise Allowable Limits

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Phase

Consequence

Impact Description

Probability

Score

Environmental Risk

Applicable Environmental Standard / Limits

Potential Mitigation

Installation of plant equipment that is designed to adhere to the Project noise requirements/philosophy

Emissions from Operation of Chlor-Alkali Plant

Al Ghaith Industries

Moderate

Where noise levels could potentially exceed 90 dB(A) hearing protection should be worn and acoustic shielding in the design of noisy equipments or near to them should be incorporated in the plant layout It is recommended that low noise valves are used where practicable to minimise noise emissions during emergency situations and to protect any worker at a position close to these

Decommissioning

PEHSR Chlor-Alkali Plant

Insignificant

Operation

Frequent

Ensure regular maintenance of plant equipment to ensure efficient operation as per specifications

No impact

Not applicable

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5.7.3.2.

Selected Mitigation Measures

Upon review of the potential mitigation measures in Section 5.7.3.1, appropriate and feasible measures will be selected for enforcement on site and their implementation frequency decided. Details on the suggested mitigation measures are provided hereunder. Emissions from Operation of Vehicles and Temporary Equipment Construction The EPC Site Environmental Manager will enforce speed restrictions on site traffic and ensure that equipment used on an intermittent basis (such as bulldozers or idling cars) will be shut down or throttled down to a minimum to cut down on unnecessary noise emissions. Moreover, any known noisy activities such as piling will be scheduled such that they occur during daylight hours in order to minimise potential disturbance to humans as well as fauna during the night time when they are more sensitive to changes in noise levels. The EPC Site Environmental Manager will also ensure that all known noisy construction equipment (such as hand tools or air compressors) have acoustic covers installed on their noisy parts (e.g. engines), which are kept closed at all times. The EPC Maintenance Manager will also ensure that all construction machinery and vehicles operational on site are maintained according to a set schedule as per the manufacturer’s specifications so that they are in good working condition at all times and consequently non-design noise emissions are minimised. Operation Same as for the Construction phase above. Decommissioning Same as for the Construction phase above. Emissions from Operation of Chlor-Alkali Plant Construction Not applicable. Operation Since the potential mitigation measures concern the design of the plant facilities, the EPC Contractor in coordination with the Project Proponent will select the appropriate mitigation measures to be implemented in order to reduce noise emissions from operation of the plant. These measures are detailed hereunder.

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Plant equipment will be selected and installed that has been designed to adhere to the Project noise philosophy as well as local regulations to minimise the potential for exceedance of noise limits during normal operation of the plant. The Chlor-Alkali Plant Operations Manager also will ensure that all plant equipment are regularly maintained to manufacturer specifications in order to reduce the potential for non-design performance of the equipment that can result in higher noise emissions from equipments. It is recommended that low noise valves are used where practicable to minimise noise emissions during emergency situations and to protect any worker at a position close to these valves. Decommissioning Not applicable. 5.7.3.3. Mitigation Measures to Address Cumulative Impacts The cumulative impacts identified are those that will impact ambient air quality from the combined operation of the current Project (Construction, Operation and Decommissioning phases) and the existing noise emissions sources in the wider area where the Project is located. With respect to the cumulative impacts identified for all construction phase aspects, these will be transient in nature since they will exist only for the time the construction activities are in progress, therefore as long as the selected mitigation measures for these aspects detailed in Section 5.7.3.31 are adhered to, no additional mitigation measures are required to address their cumulative impact. With respect to the cumulative impacts identified for all operation phase aspects, on the current Project the noise emissions from operation of the Chlor-Alkali plant are the only ones that can be controlled and minimised by implementing the selected mitigation measures for these aspects detailed in Section 5.7.3.31. Assuming that the noise emissions contributing facilities above are complying with the relevant mitigation measures addressing their operational emissions, it is envisaged that no additional mitigation measures are required to address the cumulative impact of all the facilities including the Al Ghaith Chlor-Alkali Plant. 5.7.3.4. Residual Impacts After application of the mitigation measures discussed in Section 5.7.3.2, the residual impact for all the aspects during all three Project phases will remain unchanged from the assessments provided in Section Error: Reference source not found.

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5.7.4. Monitoring Program 5.7.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

Emissions from Operation of Vehicles and Temporary Equipment Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Site traffic following speed restrictions

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Noisy activities not conducted at night, as far as practicable

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Appropriate acoustic covers installed on noisy equipment

Daily

EPC Site Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Maintenance of site vehicles and construction machinery

Monthly

EPC Site Environmental Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Site traffic following speed restrictions

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Equipment/vehicles used on intermittent basis shut down or throttled down to minimum when not in use

Daily

Equipment/vehicles used on intermittent basis shut down or throttled down to minimum when not in use Construction

Operation

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

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Project Phase

Decommissioning

Monitoring Activity

Frequency

Noisy activities not conducted at night, as far as practicable

Daily

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Maintenance of site vehicles and plant machinery

Monthly

Al Ghaith Operations Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

Site traffic following speed restrictions

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Equipment/vehicles used on intermittent basis shut down or throttled down to minimum when not in use

Daily

Noisy activities not conducted at night, as far as practicable

Daily

Maintenance of site vehicles and plant machinery

Al Ghaith Industries

Reporting

Al Ghaith Environmental Manager

Appropriate acoustic covers installed on noisy equipment

Appropriate acoustic covers installed on noisy equipment

PEHSR Chlor-Alkali Plant

Responsibility Al Ghaith Environmental Manager

Al Ghaith Environmental Manager Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist Daily Field HSE Report, Weekly Environmental Inspection Checklist

Daily

Al Ghaith Environmental Manager

Daily Field HSE Report, Weekly Environmental Inspection Checklist

Monthly

Al Ghaith Operations Manager

Weekly Environmental Inspection Checklist, Quarterly Environmental Audit Report

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Emissions from Operation of Chlor-Alkali Plant Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Construction

N/A

N/A

N/A

N/A

Plant equipment adhering to noise philosophy

Once

EPC Engineering Contractor

Plant Description Documentation

Maintenance of plant equipment

As per manufacturer specifications, Plant Maintenance Philosophy

Al Ghaith Operations Manager

Plant Maintenance Checklist

N/A

N/A

N/A

N/A

Operation

Decommissioning

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Monitoring programs suggested in Sections Error: Reference source not found will minimise the impact as far as considered practical, with commitment to these measures provided in Section 7 ‘Statement of Commitments’ of the PEHSR. These measures will also be reflected in the EPC Contractor’s Project Construction Environmental Management Plan (CEMP) and the Al Ghaith’s Operations Environmental Management Plan (OEMP). Compliance monitoring carried out as part of implementation of the aforementioned documentation (e.g. periodic inspections, audits) will assess for compliance of monitoring with the specified mitigation measures. 5.7.4.2. Monitoring Program for Cumulative Impacts As stated in Section 5.7.3.3, since the cumulative impacts from construction of the plant will be transient and controlled by implementation of the selected mitigation measures detailed in Section 5.7.3.2, no additional monitoring program is required to address them other than the Project monitoring mentioned in Section Error: Reference source not found. The same applies to the decommissioning stage of the Project. 5.7.4.3. Monitoring Program for Residual Impacts As stated in Section 5.7.3.4, since no residual impacts have been identified after application of the selected mitigation measures and their associated monitoring detailed in Section Error: Reference source not found, no such additional monitoring is required.

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5.8.

Traffic The impact associated with additional traffic on the roads around ICAD-1, MIA and the wider emirate of Abu Dhabi introduced by the construction of the Chlor-Alkali Plant will not be measureable and as such is deemed to be an insignificant factor in this PEHSR. As such, the environmental impact resulting from traffic will not be considered.

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5.9.

Socio-Economic

5.9.1. Description of the Environment A review of socio-economic impacts from the Project is a key component of any environmental assessments carried out. Socio- economic impact assessment in the UAE is an emerging field for which standard procedures and assessment methods are not yet fully developed. The socio-economic baseline was established by means of a desk based study. The information was collated from publicly available resources. Nevertheless, limited information regarding site specific socio- economic indicators are available in the public domain, socio-economic data provided in this section is largely generic in nature. 5.9.1.1. UAE The UAE is made up of seven emirates, namely Abu Dhabi, Dubai, Sharjah, Ajman, Fujairah, Ras al-Khaimah, and Umm al-Quwain. Abu Dhabi is the largest Emirate in terms of area, covering 81.2% of the UAE’s 32,000 square miles (State of the Environment - Abu Dhabi 2007). Population The total population of the UAE in 2008 was 4.5 million and is expected to reach 8.5 million by 2050 (UNPF, 2008). In a census conducted in 2005 by the UAE Ministry of Economy the percentage of nationals to the total population was 22%, with expatriates thus accounting for 78% (United Arab Emirates Ministry of Economy, 2006). The projected average population growth rate for the period 2005 to 2010 is 2.9%, significantly higher than those of other GCC countries. Error: Reference source not found displays the total population of each Emirate in 2005, including male to female ratios. Abu Dhabi has the highest population of the UAE although it is only marginally greater than the Emirate of Dubai.

Figure 5-1-15 Total population of each UAE Emirate and their respective male to female ratios in 2005 (United Arab Emirates Ministry of Economy, 2006)

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Age Distribution The age structure of the population in the UAE is detailed in Figure 5- 1 -16. The peak population within the UAE as a whole lies within the 25 to 40 age range, with a peak at 30-34 years. The population is weighted heavily in favour of expatriate men between the ages of 20 to 55 (United Arab Emirates Ministry of Economy, 2006).

Figure 5-1-16 UAE population by age group (United Arab Emirates Ministry of Economy, 2006) Economy The UAE economy has prospered in recent years with the country ranked 56th out of 180 countries worldwide in its contribution to the global GDP in 2007. Within the GCC, the UAE ranked second to Saudi Arabia in its contribution according to the classification of the International Monetary Fund in 2007 (Abu Dhabi Economic and Social Report, 2008).

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5.9.1.2.

Musaffah Industrial Area

MIA is situated southeast of Abu Dhabi Island. southern part of MIA. See Figure 4 -2.

The Project area is located on the

Population Total estimated residential population of Musaffah is approximately 151,000 (Municipality of Abu Dhabi City Website, 2009). The detailed demographics of the residential population and total worker population in MIA are not available in public domain. On the east of MIA, lies a residential area, which is primarily intended for accommodation of workers employed in MIA. In addition, the residing population mostly comprises of migrant male expatriate workers, typical of the general demographic of the MIA, with few UAE nationals. Age Distribution The predominant male bias is expected to be even more pronounced in this area since the majority of the population are male expatriates, working predominately on projects of an industrial nature. No age structure data is available for the Musaffah Area however the age structure is considered to be typical of the UAE, in favour of expatriate men between the ages of 20 to 55. Nearby Sensitive Receptors Bul Syayeef Marine Protected Area (MPA) lies to the west of MIA, separated by an approximately 500 m wide navigational channel. Bul Syayeef was declared as a Marine Protected Area by EAD in 2007. 5.9.1.3.

Al Ghaith Chlor-Alkali Plant Site and Proposed Project Area

Land Use The land use around the site consists of heavy industries and logistics, with XXX to the east, XXX to the west and proposed XXX plant to the south. A naval school lies 1 km to the southeast of the site on the Musaffah South Channel’s southern bank. Economic Impacts The AED XXX million / billion project will help relieve the increasing demands for caustic and chlorine within the Emirate. The long term economic benefits both to the national, regional and local community will be significant. Population No additional manpower shall be contracted. Local labour in Musaffah shall be utilized for this development.

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Nearby Sensitive Receptors The nearest sensitive receptor to the proposed Project site is the Musaffah labour accommodation area, which is approximately 1.5 km north. The larger Musaffah Residential Area is situated approximately 7.5 km east of the site. Storage facilities are currently located within the Project area. Land usage of the surrounding area and the nearest sensitive receptors are illustrated in Figure XXXX.

5.9.2. Environmental Impact Prediction and Evaluation 5.9.2.1.

Land Use and Community Impacts

Construction There are no requirements to displace local residents through this project as the site is designated for industrial purposes. There is very little public activity around the site. Equipment and materials needed for the construction of the plant will be transported along existing roads to the site. In general, impacts on land use during construction are expected to be low as development is in accordance with regional plans and in an area designated for such works. Probability

Consequence

Risk

Likely

Insignificant

Low

Operation The Chlor-Alkali plant will operate within the boundaries of the MIA / ICAD-1, and as such there is considered to be no impact on land use of the area. There is likely to be an insignificant increase in environmental impact of the plant through air. Air quality impacts are unlikely to affect the general community due to low volume of emissions and dispersion. The impacts from the operation on the land use and community are anticipated to be low. Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning The operational life cycle of the Chlor-Alkali Plant is likely to be 20 years or more. Typically Chlor-alkali plants are upgraded and retrofitted over time to extend their operational life cycle and meet ever more stringent environmental guidelines. Even when the plant does become redundant it is likely the site will still be used for industrial purposes due to the land zoning. So it is unlikely that full decommissioning and restoration of the site will be required for many years. If decommissioning is eventually

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required a decommissioning plan will need to be developed to ensure that the installations can be removed to minimise the risk of pollution. Decommissioning will involve dismantling of equipment and installations in reverse order to that of construction and is likely to be a quicker process. Any contaminated soil will be treated as hazardous waste and removed from site. Comprehensive analysis of the soil and groundwater will be necessary to ensure there is no contamination prior to any transfer of ownership. All material will need to be removed from site and recycled where possible or disposed to landfill. The site will need to be re-contoured and landscaped prior to any transfer of ownership. As such, the impacts from the operation on the land use and community are anticipated to be low. Probability

Consequence

Risk

Likely

Insignificant

Low

5.9.2.2.

Social Impacts

Construction During construction the project will require up to an estimated 100 workers on site. Most workers will be expatriate male labourers who will most likely be accommodated in worker camps within MIA. The influx will not change the demographic gender and ethnic dynamics of the population. The impacts from the construction on the social aspects are anticipated to be low. Probability

Consequence

Risk

Likely

Insignificant

Low

Operation During operation the impacts on employment are less significant than during construction. However, those who are employed will have longer term job security and are more likely to bring their family and integrate in the community. They will require a higher standard of housing and facilities such as shops, entertainment, a school, and a hospital. They are also more likely to interact with the local Emiratis. It is estimated that the operational workforce will be around 100 people. Including families the number of people that will be added to the community is significant and is likely to help develop the area. The impacts from plant operation on the social aspects are anticipated to be low. Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning

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During decommissioning the number of workers on site will increase. There may be a short term benefit to the community through employment opportunities. But once the plant is dissembled and removed the social benefits will be gone. The roughly 100 people working on-site permanently will no longer be required. So unless the land can be used for some other purpose which helps employee local people the social impacts will be negative. It is entirely likely that when the Chlor-Alkali Plant is decommissioned in the future a new plant may take its place or other industry will move in. Alternatively in 20 years time if the population of the area continues to expand this land with ocean views may become valuable for residential purposes as has happened in many other parts of the world.

5.9.2.3.

Probability

Consequence

Risk

Likely

Insignificant

Low

Economic Impacts

Construction The total estimated expenditure for construction and operation of the project is USD xxxx mil.. A large proportion of this expense will be early on in the construction phase when the major components will be purchased and up to approximately XXX workers will be on site. While the major system units will be imported other construction materials such as concrete and steel rebar will be sourced locally. While there is likely to be a beneficial multiplier effect from the money spent on this project, which will spread through the economy, it may not be as high as in other places as expatriate workers typically save a high proportion of their salaries to send home. As they stay in fully catered camps they are not likely to spend large sums of money in the local shops. Workers are also not taxed on their incomes. Therefore a large proportion of money may move offshore. However, for every direct job created by the project there will be supporting indirect jobs created. A project like this is only likely to benefit the economy. There is potential for inflationary pressure as a result of this project due to the shortage of certain building materials locally and already strong demand for these products. The added people involved in the project will also increase demand for foodstuffs and other supplies. However, the overall impacts are not likely be significant or long term as once operational the numbers of people on site will be relatively minor.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Likely

Insignificant

Low

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Operation The economic benefits of the new plant are large. Abu Dhabi is growing at a fast rate in terms of population and new developments. This has put a significant strain on the energy infrastructure of the Emirate. Without the development of new industry the Emirate’s growth would slow. The construction of the Chlor-Alkali Plant is important to the future of Abu Dhabi, and the oil and gas industry in particular. As such, the operation of the plant is of major positive impact, and therefore low risk. Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning Decommissioning will have obvious negative impacts on the economy. Approximately 50 people will be out of work and the Chlor-alkali production will no longer be available which will increase the overall caustic and chlorine for consumers in Abu Dhabi. While there may be some employment opportunities during the decommissioning process these will be short term.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Probability

Consequence

Risk

Likely

Minor

Moderate

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5.9.3. Mitigation Measures 5.9.3.1.

Potential Mitigation Measures

Consequence Insignificant

Low

Insignificant

Low

Operation

Likely

Decommissioning

Construction Likely

Social

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Applicable Environmental Standard / Limits

Potential Mitigation

No mitigation identified

-

Maintain as an industrial zone and avoid any new residential or other recreational activities around the site.

-

Prepare decommissioning plan for site.

Insignificant

Construction

Environmental Risk

Low

Insignificant

Land Use

Probability

Phase

Likely

Impact Description

Likely

Score

Low

Ensure the site is tested and restored to original condition, where possible.

-

Allow for re-contouring and landscaping of site.

No mitigation identified

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-

Probability

Consequence

Likely

Insignificant

Low

Insignificant

Low

Insignificant

Phase

Likely

Impact Description

Likely

Score

Low

Environmental Risk

Applicable Environmental Standard / Limits

Potential Mitigation

Decommissioning

Construction

Operation

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Likely

Economic

Insignificant

Operation Provide adequate assistance and facilities to allow permanent workers to integrate in the local community.

-

Allow new high value development on the site to provide replacement employment opportunities.

-

No mitigation identified

-

Low

No mitigation identified

-

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Consequence Minor

Phase

Probability

Impact Description

Likely

Score

Environmental Risk

Applicable Environmental Standard / Limits

Potential Mitigation

Decommissioning

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Moderate

Allow new high value development on the site to provide replacement employment opportunities.

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-

5.9.3.2.

Selected Mitigation Measures

As the socio-economic benefits of the project are primarily beneficial mitigation measures have not been identified for most aspects of the project. The only mitigation measure that has been selected as an ultimate requirement of the project is: 1. A decommissioning plan for the site is produced. The decommissioning plan will be the responsibility of the Operations Manager prior to any decommissioning activities commencing and will need to consider issues such as waste handling and disposal, site investigations, and restoration of the site. This plan will need to be approved through EAD. Note that other environmental mitigation measures including traffic management that will benefit the community are addressed in separate sections. 5.9.3.3.

Mitigation Measures to Address Cumulative Impacts

No mitigation measures have been identified to address cumulative impacts as such socio-economic impacts are all of major positive benefit. 5.9.3.4.

Residual Impacts

As only one mitigation measure has been selected, and this is a mandatory requirement of the project, the residual impacts will remain unchanged. They are all considered Low with the exception of the operational impacts on the social and economic factors, which remain of major positive benefit.

5.9.4. Monitoring Program 5.9.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

No monitoring program is considered necessary at this stage of the Project. When the site is eventually decommissioned post closure monitoring is recommended to ensure the fitness of the land for the intended future use. This shall be determined within the decommissioning plan. 5.9.4.2.

Monitoring Program for Cumulative Impacts

No monitoring program is considered necessary to deal with cumulative impacts. 5.9.4.3.

Monitoring Program for Residual Impacts

No monitoring program is considered necessary to deal with residual impacts.

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5.10. Impacts, Mitigation and Monitoring Summary 5.10.1. Mitigated Impacts Table 5-10 Summary of Environmental Impacts, Mitigation and Monitoring

Emissions from operation of fuel consuming vehicles and equipment

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Phase

Signific ance

Low

Air Quality

Impact

Construction

Receptor

Mitigation

Monitoring

The EPC Site Environmental Manager will ensure that all site light and heavy vehicles and construction machinery traffic used paved/gatch roads wherever possible and traffic on unpaved roads is limited to reduce generation of particulate dust emissions. For the same reason, speed restrictions will also be imposed on site traffic, traffic will be planned and managed to reduce double trips, and unpaved routes will be sprinkled with water as required to dampen down the soil. Moreover, the EPC Site Environmental Manager will also ensure that all construction machinery and vehicles operational on site are maintained according to a set schedule as per the manufacturer’s specifications so that they are in good working condition at all times and consequently non-design exhaust emissions are minimised.

Responsible Party

Daily monitoring of site traffic using paved roads – to be reported in daily field HSE report and weekly Environmental Checklist. Daily monitoring of site traffic following speed restrictions – to be reported in daily field HSE report and weekly Environmental Checklist. Daily monitoring of wet suppression of site unpaved roads – to be reported in daily field HSE report and weekly Environmental Checklist. Monthly maintenance reporting on site vehicles and construction machinery – to be reported in weekly Environmental Checklist and quarterly Environmental Audit Report.

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EPC Site Environmental Manager

Low

Combustion and Fugitive Emissions from Operation of AL GHAITH Plant

No Impact

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Operation

Emissions from operation of fuel consuming vehicles and equipment

Air Quality

Emissions from operation of fuel consuming vehicles and equipment

Decommissioning

Signific ance

Construction

Phase

Air Quality

Impact

Air Quality

Receptor

Mitigation

Monitoring

The Al Ghaith Plant Environmental Manager will ensure that speed restrictions and minimization of double-handling are ensured on all light and heavy vehicles travelling within the plant during operations, in order to reduce the generation of exhaust.

Daily monitoring of site traffic following speed restrictions – to be reported in daily field HSE report and weekly Environmental Checklist.

Similar to the Construction Phase, the Al Ghaith Plant Operations Manager will also ensure that all construction machinery and vehicles operational on site are maintained according to a set schedule as per the manufacturer’s specifications so that they are in good working condition at all times and consequently non-design exhaust emissions are minimised.

Same as for the Construction phase above.

Daily monitoring of minimization of doublehandling of vehicles – to be reported in daily field HSE report and weekly Environmental Checklist. Monthly maintenance reporting on site vehicles and construction machinery – to be reported in weekly Environmental Checklist and quarterly Environmental Audit Report.

Same as for the Construction phase above.

Responsible Party

Al Ghaith Plant Environmental Manager Al Ghaith Plant Operations Manager

Al Ghaith Plant Environmental Manager Al Ghaith Plant Operations Manager

Not applicable.

Not applicable.

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Not applicable.

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

Low

Combustion and Fugitive Emissions from Operation of AL GHAITH Plant

Operations

Air Quality

Since the potential mitigation measures concern the design of the plant facilities, the EPC Contractor in coordination with the Project Proponent will select the appropriate mitigation measures to be implemented in order to reduce combustion-related and fugitive emissions from operation of the Al Ghaith plant. These measures are detailed hereunder. With respect to fugitive emissions, the EPC Engineering Coordinator will ensure that appropriate flow level controllers are installed in the back up fuel storage tanks in order to alert operators to fuel levels in the tank in excess of design levels and consequently trigger appropriate action to mitigate the scenario where VOCs are built up at the top of the tank resulting in their accelerated fugitive emissions.

EPC Engineering Contractor Maintenance of plant equipment as per manufacturer specifications and Plant Maintenance Philosophy – to be documented in Plant Maintenance Checklist

PEHSR Chlor-Alkali Plant Al Ghaith Industries

No Impact

Combustion and Fugitive Emissions from Operation of AL GHAITH Plant

Decommissioning

Air Quality

The Al Ghaith Plant Operations Manager will ensure that all plant equipment are regularly maintained to manufacturer specifications in order to reduce the potential for non-design performance of the equipment that can result in higher direct emissions from equipments such as the GTs as well as fugitive emissions from equipments such as valves and flanges.

Not applicable.

Not applicable.

Project Number 44130065 Page 131

Al Ghaith Plant Operations Manager (Third Party Specialist if required)

Not applicable.

Emission of Greenhouse Gasses

Phase

Signific ance

Mitigation

Monitoring

The EPC Site Environmental Manager and/or EPC Maintenance Manager will encourage implementation of good construction practices with respect to handling GHG containing materials such as refrigerants, as mentioned in Section 5.1.2.3. This will be to ensure that fugitive emissions from improperly closed storage containers are prevented. Low

Impact

Construction

Air Quality

Receptor

This would typically involve ensuring that safety valves on refrigerant gas containing cylinders are only opened when they are in use and otherwise kept normally shut to reduce the potential for fugitive emissions.

Responsible Party

Daily monitoring of shutting off safety valves on refrigerant gas containing cylinders – to be reported in the daily Field HSE Report, and the weekly Environmental Inspection Checklist.

EPC Site Environmental Manager

Same as for Construction phase above.

Al Ghaith Plant Environmental Manager

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Emission of Greenhouse Gasses

Decommissioning

Air Quality

However, the best form of mitigation would be to utilize alternate refrigerant gas that does not have a GHG impact.

Same as for Construction phase above.

Project Number 44130065 Page 132

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Low

Emissions from accidental events

Construction

Air Quality

The EPC Site Environmental Manager will ensure that appropriate internal wiring is utilised in construction machinery and it is run according to the manufacturer’s specifications in order to reduce the potential for a fire occurring due to a short-circuit and therefore the resulting combustion emissions. Additionally, it will also be ensured that the machinery is regularly inspected and maintained in order to reduce the potential for non-design performance of the equipment and therefore resulting higher direct exhaust emissions. The EPC Site Environmental Manager will also ensure that flammable chemicals on site are temporarily stored in accordance with the manufacturer’s and MSDS requirements, in order to reduce the potential for an accidental fire occurring. As a further fire preventative measure, the EPC Site Environmental Manager will also enforce an indoor no-smoking policy within the site buildings (i.e. offices) to reduce the potential for human-induced fires occurring. Relevant employees will also be trained in the measures to be followed in case a fire breaks out so that it can be controlled soon after break-out and the risk to employees’ health reduced. The EPC Site Environmental Manager will also prepare a project emergency response strategy/plan addressing appropriate emergency procedures to be followed in case of a fire occurring during construction works. Again, this will ensure that a fire can be controlled soon after it breaks out and the risk of deterioration of ambient air quality and employees’ health is reduced. PEHSR Chlor-Alkali Plant Al Ghaith Industries

Responsible Party

Weekly monitoring of appropriate internal wiring utilised in construction machinery – to be reported in weekly field maintenance report. Monthly monitoring of the maintenance of site vehicles and construction machinery – to be reported in Weekly Environmental Inspection Checklist and Quarterly Environmental Audit Report. Daily monitoring of appropriate storage of flammable chemicals – to be reported in weekly field maintenance report. Daily enforcement of indoor no smoking policy – to be reported in weekly field maintenance report. Quarterly monitoring of fire response procedure documentation and review of appropriate training for staff – to be documented within the Quarterly Environmental Audit Report.

Project Number 44130065 Page 133

EPC Site Environmental Manager

Emissions from accidental events

Phase

Signific ance

Mitigation

Monitoring

To reduce the risk of a human induced fire occurring near to the large diesel inventory on site in the back up fuel storage tanks, as well as to prevent any adverse effects on humans in the vicinity of the tanks, the Plant Operator will enforce controlled access of personnel/visitors to the back-up fuel storage tanks. Moreover, the area around the storage tanks will strictly be a no-smoking zone in order to minimise the potential for the fuel being ignited. Low

Impact

Operation

Air Quality

Receptor

In addition to these, the Plant Operator will also exercise control over the inventory of fuel entering the back-up fuel storage tanks and stored in them via the flow level controllers assembly as part of the tanks, in order to prevent an overflow occurring and raising the potential for a fire occurring due to accidental ignition.

All

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Monitoring undertaken once for appropriate flow level control in back-up fuel storage tanks. To be undertaken by the Plant Control Room Operator, and reported within the Plant Description Documentation.

Al Ghaith Plant Environmental Manager

Quarterly monitoring of the fire response procedure and the appropriate training of staff – to be reported in the Quarterly Environmental Report.

Low

Decommissioning

Cumulative

Daily monitoring of the Controlled Access of plant personnel/visitors to back-up fuel storage tanks – reporting not applicable.

Same as for Construction phase.

Same as for Construction phase.

EPC Site Environmental Manager

-

Air Quality

Emissions from accidental events

Air Quality

The Plant Operator will also be responsible for enforcing the site emergency response requirements in the event of a fire occurring to facilitate controlling the fire at the earliest.

Responsible Party

No additional mitigation required.

No additional monitoring required.

-

Project Number 44130065 Page 134

Residual

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Phase

Signific ance

-

Impact

All

Air Quality

Receptor

Mitigation

Monitoring

No additional mitigation required.

No additional monitoring required.

Project Number 44130065 Page 135

Responsible Party

-

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. CEMP to include solid waste management. 2. Reduce, reuse, recycling of wastes where possible. 3. Dedicated solid waste storage area on site. 4. Storage area to have hard standing base and appropriate drainage. 5. Segregate wastes where feasible.

7. Waste transfer notes used for Environmental Service Providers. Low

Solid Waste

Construction

Waste Management

6. Inventory maintained for wastes on site.

Daily monitoring of quantities and types of solid waste stored on site – to be recorded on waste checklists by the EPC Site Environmental Manager

8. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 9. Good site housekeeping. 10. Covering of soil stock piles. 11. Colour coded skips and rubbish bins around site. 12. Clear signage for solid waste storage areas. 13. Training of staff in waste management procedures. 14. Materials ordered on a “as needs basis”. 15. Preparation of a decommissioning waste management plan.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 136

EPC Site Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. OEMP to include solid waste management. 2. Reduce, reuse, recycling of wastes where possible. 3. Dedicated solid waste storage area on site. 4. Storage area to have hard standing base and appropriate drainage. 5. Segregate wastes where feasible.

7. Waste transfer notes used for Environmental Service Providers. Low

Solid Waste

Operation

Waste Management

6. Inventory maintained for wastes on site.

Daily monitoring of quantities and types of solid waste stored on site – to be recorded on waste checklists by the Al Ghaith Plant Environmental Manager

8. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 9. Good site housekeeping. 10. Covering of soil stock piles. 11. Colour coded skips and rubbish bins around site. 12. Clear signage for solid waste storage areas. 13. Training of staff in waste management procedures. 14. Materials ordered on a “as needs basis”. 15. Preparation of a decommissioning waste management plan.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 137

Al Ghaith Plant Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

Daily monitoring of quantities and types of solid waste stored on site – to be recorded on waste checklists by the Site Environmental Manager (Contractor)

Site Environmental Manager (Contractor)

1. DEMP to include solid waste management. 2. Reduce, reuse, recycling of wastes where possible. 3. Dedicated solid waste storage area on site. 4. Storage area to have hard standing base and appropriate drainage. 5. Segregate wastes where feasible.

7. Waste transfer notes used for Environmental Service Providers. Moderate

Solid Waste

Decommissioning

Waste Management

6. Inventory maintained for wastes on site.

8. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 9. Good site housekeeping. 10. Covering of soil stock piles. 11. Colour coded skips and rubbish bins around site. 12. Clear signage for solid waste storage areas. 13. Training of staff in waste management procedures. 14. Materials ordered on a “as needs basis”. 15. Preparation of a decommissioning waste management plan.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 138

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. CEMP to include liquid waste management. 2. Monitoring and treatment of all effluent discharges to the marine environment to ensure that they meet ADWEA’s permissible discharge limits set for this project. 3. Potable water used for hydrotesting. 4. Reduce, reuse, recycling of wastes where possible. 5. Dedicated liquid waste storage area on site. 6. Liquid wastes stored in good quality, sealed and labelled drums. 7. Incompatible liquid wastes stored separately.

Liquid Waste

Moderate

9. Segregate wastes where feasible. Construction

Waste Management

8. Storage area to have hard standing base and appropriate drainage.

10. Inventory maintained for wastes on site. 11. Waste transfer notes used for Environmental Service Providers. 12. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections.

Daily monitoring of quantities and types of liquid waste stored on site- to be recorded on site checklist by EPC Site Environmental Manager Pre-discharge monitoring of water quality of dewatering discharge testing against permissible discharge limits set for this project/EAD limits – to be undertaken by EPC Site Environmental Manager

13. Good site housekeeping. 14. Clear signage for liquid waste storage areas. 15. Training of staff in waste management procedures. 16. Chemicals ordered on a “as needs basis”. PEHSR Chlor-Alkali Plant Al Ghaith Industries

17. Spill response plan and appropriate staff spill

Project Number 44130065 Page 139

EPC Site Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. OEMP to include liquid waste management. 2. Monitoring and treatment of all effluent discharges to the marine environment to ensure that they meet ADWEA’s permissible discharge limits set for this project. 3. Potable water used for hydrotesting. 4. Reduce, reuse, recycling of wastes where possible. 5. Dedicated liquid waste storage area on site. 6. Liquid wastes stored in good quality, sealed and labelled drums. 7. Incompatible liquid wastes stored separately.

Liquid Waste

Critical

9. Segregate wastes where feasible. Operation

Waste Management

8. Storage area to have hard standing base and appropriate drainage.

10. Inventory maintained for wastes on site. 11. Waste transfer notes used for Environmental Service Providers. 12. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections.

Continuous monitoring of closed circuit cooling water discharge for temperature at the Al Ghaith Plant discharge point. To be the responsibility of the Al Ghaith Plant Operations Manager. Monthly monitoring of desalination plant brine water discharge with water quality testing against ADWEA’s permissible discharge limits set for this project – to be conducted by Al Ghaith Plant Environmental Manager

13. Good site housekeeping. 14. Clear signage for liquid waste storage areas. 15. Training of staff in waste management procedures. 16. Chemicals ordered on a “as needs basis”. PEHSR Chlor-Alkali Plant Al Ghaith Industries

17. Spill response plan and appropriate staff spill

Project Number 44130065 Page 140

Al Ghaith Plant Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. DEMP to include liquid waste management. 2. Monitoring and treatment of all effluent discharges to the marine environment to ensure that they meet ADWEA’s permissible discharge limits set for this project. 3. Potable water used for hydrotesting. 4. Reduce, reuse, recycling of wastes where possible. 5. Dedicated liquid waste storage area on site. 6. Liquid wastes stored in good quality, sealed and labelled drums. 7. Incompatible liquid wastes stored separately.

9. Segregate wastes where feasible. Moderate

Liquid Waste

Decommissioning

Waste Management

8. Storage area to have hard standing base and appropriate drainage.

10. Inventory maintained for wastes on site. 11. Waste transfer notes used for Environmental Service Providers. 12. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 13. Good site housekeeping. 14. Clear signage for liquid waste storage areas.

Daily monitoring of quantities and types of liquid waste stored on site- to be recorded on site checklist by Site Environmental Manager (Contractor) Pre-disposal water quality testing of hydrotest water against ADWEA’s permissible discharge limits set for this project/EAD limits – to be undertaken by the Site Environmental Manager (Contractor). Pre-discharge monitoring of water quality of dewatering discharge testing against ADWEA’s permissible discharge limits set for this project/EAD limits – to be undertaken by Site Environmental Manager (Contractor).Continuous

15. Training of staff in waste management procedures. 16. Chemicals ordered on a “as needs basis”. PEHSR Chlor-Alkali Plant Al Ghaith Industries

17. Spill response plan and appropriate staff spill

Project Number 44130065 Page 141

Site Environmental Manager (Contractor)

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. CEMP to include hazardous waste management. 2. Monitoring and treatment of all effluent discharges to the marine environment to ensure that they meet ADWEA’s permissible discharge limits set for this project. 3. Reduce, reuse, recycling of hazardous wastes where possible. 4. Dedicated hazardous waste storage area on site. 5. Hazardous liquid wastes stored in good quality, sealed and labelled drums. 6. Incompatible hazardous wastes stored separately.

Hazardous Waste

Moderate

8. Storage area only to be accessible to approved and trained staff. Construction

Waste Management

7. Storage area to have hard standing base and appropriate drainage.

9. Segregate hazardous wastes where feasible. 10. Inventory maintained for wastes on site. 11. Waste transfer notes used for Environmental Service Providers.

Daily monitoring of quantities and types of hazardous waste stored on site- to be recorded on waste checklist by EPC Site Environmental Manager

12. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 13. Good site housekeeping. 14. Clear signage for hazardous waste storage areas. 15. Training of staff in waste management procedures. PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 142

EPC Site Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. OEMP to include hazardous waste management. 2. Monitoring and treatment of all effluent discharges to the marine environment to ensure that they meet ADWEA’s permissible discharge limits set for this project. 3. Reduce, reuse, recycling of hazardous wastes where possible. 4. Dedicated hazardous waste storage area on site. 5. Hazardous liquid wastes stored in good quality, sealed and labelled drums. 6. Incompatible hazardous wastes stored separately.

Hazardous Waste

Moderate

8. Storage area only to be accessible to approved and trained staff. Operation

Waste Management

7. Storage area to have hard standing base and appropriate drainage.

9. Segregate hazardous wastes where feasible. 10. Inventory maintained for wastes on site. 11. Waste transfer notes used for Environmental Service Providers.

Daily monitoring of quantities and types of hazardous waste stored on site- to be recorded on waste checklist by Al Ghaith Plant Environmental Manager

12. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 13. Good site housekeeping. 14. Clear signage for hazardous waste storage areas. 15. Training of staff in waste management procedures. PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 143

Al Ghaith Plant Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

Daily monitoring of quantities and types of hazardous waste stored on site- to be recorded on waste checklist by Site Environmental Manager (Contractor)

Site Environmental Manager (Contractor)

1. DEMP to include hazardous waste management. 2. Monitoring and treatment of all effluent discharges to the marine environment to ensure that they meet ADWEA’s permissible discharge limits set for this project. 3. Reduce, reuse, recycling of hazardous wastes where possible. 4. Dedicated hazardous waste storage area on site. 5. Hazardous liquid wastes stored in good quality, sealed and labelled drums. 6. Incompatible hazardous wastes stored separately.

8. Storage area only to be accessible to approved and trained staff. Moderate

Hazardous Waste

Decommissioning

Waste Management

7. Storage area to have hard standing base and appropriate drainage.

9. Segregate hazardous wastes where feasible. 10. Inventory maintained for wastes on site. 11. Waste transfer notes used for Environmental Service Providers. 12. Appointed Environmental Service Provider to prepare a waste management plan for the site including frequency of collections. 13. Good site housekeeping. 14. Clear signage for hazardous waste storage areas. 15. Training of staff in waste management procedures.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 144

No additional monitoring identified.

-

No monitoring identified.

-

No monitoring identified.

-

-

-

No additional mitigation measures identified.

Residual impact

-

No additional monitoring identified.

Cumulative Impact

No additional mitigation measures identified.

Disturbance to site soils

Low

Monitoring

No mitigation identified.

Disturbance to site soils

Low

Mitigation

All Phases

Signific ance

All Phases

Phase

Construction

Impact

Operation

Geology, Seismicity, Soil, Geology, Seismicity, Soil, and Groundwater and Groundwater

Waste Waste Management Management

Receptor

No mitigation identified.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 145

Responsible Party

Disturbance to site soils

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Phase

Signific ance

Low

Impact

Decommissioning

Geology, Seismicity, Soil, and Groundwater

Receptor

Mitigation

Monitoring

No mitigation identified.

No monitoring identified.

Project Number 44130065 Page 146

Responsible Party

-

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

1. Secondary containment (i.e. drip pans or concrete containment) will be provided for fuel and chemical storage tanks such that containment is designed for a minimum of 110% of the total volume of the largest storage tank 2. Fuel and chemical storage tanks will be located at a designated position and appropriate clear signage and barrier protection from vehicular movements. 3. All hard-standing and bunds will be inspected on a regular basis and cracks reported and repaired. 4. All temporary fuel storage tanks will be doublewalled containers. 5. Acid wash waste, if applicable, during commissioning will be fully contained and removed from site by authorised waste management contractors. 6. Refuelling will be undertaken in designated areas following set procedures, to be set out in the CEMP. 7. Vehicles operating on site will undergo routine maintenance and regular inspection to minimise the potential for leakage of oil and other fluids.

ismicity, Soil, and Groundwater

8. A regular equipment and tank inspection and repair program will be developed on site. 9. Emergency shut down and spill response procedures for a hazardous waste spill will be required to be developed and implemented by the EPC contractor. 10. The EPC contractor will encourage workers to report all spills using a ‘no blame’ culture. PEHSR Chlor-Alkali Plant Al Ghaith Industries

Daily inspection of Fuel and chemical storage facilities to be undertaken by the EPC Site Environmental Manager and reported in the Daily Field HSE Report, and Weekly Environmental Inspection Checklist Hardstanding areas and bunds inspected weekly by the EPC Site Environmental Manager and reported in the Weekly Environmental Inspection Checklist Vehicle inspections inspected weekly by the EPC Site Environmental Manager and reported in the Weekly Environmental Inspection Checklist

Project Number 44130065 Page 147

Responsible Party

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. EPC contractor to develop OEMP including an environmental monitoring plan. 2. Appropriate protocols will be established for the transfer and disposal of contaminated fuel, oil and soil in accordance with Municipality requirements in the Waste Management Plan.

Contaminati on of soil

Moderate

4. Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities.

Operation

Geology, Seismicity, Soil, and Groundwater

3. Fuel, oil and chemical storage facilities to include 110% secondary containment.

5. If any inadvertent leakage or spillage of hydrocarbons occurs, the operator will implement spill response measures to contain and excavate any contaminated soil present. 6. Chemical Management, Waste Management, Emergency and Spill Response plans will be established for the site. 7. All contaminated wastewater will be treated to within appropriate discharge limits prior to disposal. 8. Routine and regular documented inspections of the plant including chemical/oil/fuel storage facilities and waste storage areas.

Weekly inspection of Fuel and chemical storage facilities to be undertaken by the Al Ghaith Plant Environmental Manager and reported in the Weekly Environmental Inspection Checklist. Weekly inspection of Plant facilities to be undertaken by Al Ghaith Plant Environmental Manager and recorded in the Weekly Environmental Inspection Checklist. Monthly inspection and maintenance of site vehicles and plant machinery to be undertaken by the Al Ghaith Plant Environmental Manager and reported in the Weekly Environmental Inspection Checklist, and the Quarterly Environmental Audit Report

9. Immediate excavation and removal of any contaminated soil to the designated waste facility. These measures when followed properly as part of a rigorous OEMP will largely mitigate against the potential for soil contamination. However due to the presence of plant and buildings associated with the PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 148

Al Ghaith Plant Environmental Manager

Contaminati on of soil

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Phase

Signific ance

Moderate

Impact

Decommissioning

Geology, Seismicity, Soil, and Groundwater

Receptor

Mitigation

Monitoring

Responsible Party

Same as for Construction phase.

Same as for Construction phase.

Site Environmental Manager (Contractor)

Project Number 44130065 Page 149

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

1. Secondary containment (i.e. drip pans or concrete containment) will be provided for fuel and chemical storage tanks such that containment is designed for a minimum of 110% of the total volume of the largest storage tank 2. Fuel and chemical storage tanks will be located at a designated position and appropriate clear signage and barrier protection from vehicular movements. 3. All hard-standing and bunds will be inspected on a regular basis and cracks reported and repaired. 4. All temporary fuel storage tanks will be doublewalled containers. 5. Acid wash waste, if applicable, during commissioning will be fully contained and removed from site by authorised waste management contractors. 6. Refuelling will be undertaken in designated areas following set procedures, to be set out in the CEMP. 7. Vehicles operating on site will undergo routine maintenance and regular inspection to minimise the potential for leakage of oil and other fluids.

ismicity, Soil, and Groundwater

8. A regular equipment and tank inspection and repair program will be developed on site. 9. Emergency shut down and spill response procedures for a hazardous waste spill will be required to be developed and implemented by the EPC contractor. 10. The EPC contractor will encourage workers to report all spills using a ‘no blame’ culture. Contaminati PEHSR Chlor-Alkali Plant Al Ghaith Industries

Daily inspection of Fuel and chemical storage facilities to be undertaken by the EPC Site Environmental Manager and reported in the Daily Field HSE Report, and Weekly Environmental Inspection Checklist Hardstanding areas and bunds inspected weekly by the EPC Site Environmental Manager and reported in the Weekly Environmental Inspection Checklist Vehicle inspections inspected weekly by the EPC Site Environmental Manager and reported in the Weekly Environmental Inspection Checklist

Project Number 44130065 Page 150

Responsible Party

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

1. EPC contractor to develop OEMP including an environmental monitoring plan. 2. Appropriate protocols will be established for the transfer and disposal of contaminated fuel, oil and soil in accordance with Municipality requirements in the Waste Management Plan.

Contaminati on of shallow groundwate r

Moderate

4. Refuelling & maintenance to be carried out at designated sealed hardstanding area/s with appropriate spill clean up and containment facilities.

Operation

Geology, Seismicity, Soil, and Groundwater

3. Fuel, oil and chemical storage facilities to include 110% secondary containment.

5. If any inadvertent leakage or spillage of hydrocarbons occurs, the operator will implement spill response measures to contain and excavate any contaminated soil present. 6. Chemical Management, Waste Management, Emergency and Spill Response plans will be established for the site. 7. All contaminated wastewater will be treated to within appropriate discharge limits prior to disposal. 8. Routine and regular documented inspections of the plant including chemical/oil/fuel storage facilities and waste storage areas.

Weekly inspection of Fuel and chemical storage facilities to be undertaken by the Al Ghaith Plant Environmental Manager and reported in the Weekly Environmental Inspection Checklist. Weekly inspection of Plant facilities to be undertaken by Al Ghaith Plant Environmental Manager and recorded in the Weekly Environmental Inspection Checklist. Monthly inspection and maintenance of site vehicles and plant machinery to be undertaken by the Al Ghaith Plant Environmental Manager and reported in the Weekly Environmental Inspection Checklist, and the Quarterly Environmental Audit Report

9. Immediate excavation and removal of any contaminated soil to the designated waste facility. These measures to minimise contamination occurrences within the soil horizon will largely mitigate against the potential for shallow groundwater contamination. However, due to the presence of plant PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 151

Al Ghaith Plant Environmental Manager

Residual Impacts

PEHSR Chlor-Alkali Plant Al Ghaith Industries

-

Signific ance

-

Geology, Seismicity, Soil, and Groundwater

Cumulative Impact

Phase

All

Impact

All

Geology, Seismicity, Soil, and Groundwater

Receptor

Mitigation

Monitoring

No additional mitigation identified.

Monitoring the cumulative impacts on soil and groundwater is not generally practicable, due to the spatial distribution of monitoring points generally required and the associated often prohibitive costs. However, permanent groundwater monitoring wells, if established across the Al Ghaith site, would allow regular monitoring of groundwater quality throughout all phases of the project. During the construction phase, weekly monitoring would be suitable under the responsibility of the EPC Site Environmental Manager with results reported weekly. During the operations phase of the project, annual monitoring would potentially be sufficient under the responsibility of the Al Ghaith Plant Environmental Manager. The decommissioning phase would mirror the construction monitoring requirements.

Al Ghaith Plant Environmental Manager

No additional mitigation measures identified.

Permanent groundwater monitoring boreholes to be established on the Al Ghaith Plant site, and quarterly routine monitoring program to be established – to be reported in Quarterly Environmental Audit Report to EAD

Al Ghaith Plant Environmental Manager

Project Number 44130065 Page 152

Responsible Party

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

Low

Loss of habitat within Al Ghaith project site

Construction

Terrestrial Ecology

1. Clearing of vegetation will be confined to that necessary for the establishment of the plant. Areas for clearance will be established with the EPC HSE Site Coordinator before works. 2. Management strategies will be implemented to protect any remaining native vegetation communities by controlling the occurrence and spread of weeds and minimising the impact of soil erosion/sedimentation. This will include general good housekeeping on site and assessment during the daily site inspection by the EPC HSE Site Coordinator.

Monitoring for compliance with selected mitigation measures during the construction phase shall be undertaken by the EPC Site Environmental Manager during daily inspections and shall be recorded within the Field HSE Report and the weekly Environmental Inspection Checklist..

These measures will not fully mitigate the loss of the present habitats as this impact is unavoidable due to the footprint of the plant facilities. These measures will, however, reduce the impact from loss of habitat as far as possible.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 153

EPC Site Environmental Manager

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

Low

Loss of habitat within Chlor-Alkali project site

Operation

Terrestrial Ecology

No specific measures have been identified to mitigate the loss of native habitat on site. However: 1. Planting vegetation composed of local species, preferably coastal, within the available space will provide ‘green’ areas. Such landscaping within the plant fence line will provide some habitat/shelter for species including insects and birds on site, and though not directly mitigating for the impact, will provide areas of some limited value. Such areas would also be visually appealing, particularly if instated in administration or office areas. Basic landscaped areas also cost relatively little to instate and maintain.

No monitoring identified.

Al Ghaith Plant Environmental Manager

No monitoring identified.

Site Environmental Manager (Contractor)

It should be noted that the impact of habitat loss will be realised during the construction phase and that the operational phase will not further increase this impact. In addition, landscaping mitigation will only provide alternate habitat and limited compensation and will not provide any habitat recreation.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Loss of habitat within Chlor-Alkali project site

Decommissioning

Terrestrial Ecology

Responsibility for landscaping during the operational phase will be with the Al Ghaith Plant Environmental Manager. This activity will be a continual activity, likely falling within the plant maintenance schedule.

Same as for Construction phase.

Project Number 44130065 Page 154

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

No mitigation identified.

No monitoring identified.

-

Low

No mitigation identified.

No monitoring identified.

-

Low

Residual impact.

Monitoring

No mitigation identified.

No monitoring identified.

-

-

Cumulative impact.

Mitigation

No cumulative impact was identified, therefore no mitigation is suggested.

No monitoring identified.

-

-

Construction

Disturbance to flora and fauna within Chlor-Alkali Project site

All

Operation

Disturbance to flora and fauna within Chlor-Alkali Project site

All

Decommissioning

Terrestrial Ecology

Disturbance to flora and fauna within Chlor-Alkali Project site

Terrestrial Ecology

Signific ance

Terrestrial Ecology

Phase

Terrestrial Ecology

Impact

Terrestrial Ecology

Receptor

No additional mitigation measures identified.

No additional monitoring identified.

-

Project Number 44130065 Page 155

Responsible Party

Emissions from operation of vehicles and temporary equipment

Phase

Signific ance

Mitigation

Monitoring

The EPC Site Environmental Manager will enforce speed restrictions on site traffic and ensure that equipment used on an intermittent basis (such as bulldozers or idling cars) will be shut down or throttled down to a minimum to cut down on unnecessary noise emissions. Moreover, any known noisy activities such as piling will be scheduled such that they occur during daylight hours in order to minimise potential disturbance to humans as well as fauna during the night time when they are more sensitive to changes in noise levels. Low

Impact

Construction

Noise

Receptor

The EPC Site Environmental Manager will also ensure that all known noisy construction equipment (such as hand tools or air compressors) have acoustic covers installed on their noisy parts (e.g. engines), which are kept closed at all times.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Emissions from operation of vehicles and temporary equipment

Operation

Noise

The EPC Maintenance Manager will also ensure that all construction machinery and vehicles operational on site are maintained according to a set schedule as per the manufacturer’s specifications so that they are in good working condition at all times and consequently non-design noise emissions are minimised.

Same as for the Construction phase above.

Responsible Party

Daily monitoring of site traffic following speed restrictions – to be recorded in daily site HSE Report and also in weekly Environmental Inspection Checklist. Daily monitoring of equipment/vehicles used on intermittent basis shut down or throttled down to minimum when not in use – to be recorded in daily site HSE Report and also in weekly Environmental Inspection Checklist. Daily monitoring of noisy activities not conducted at night (as far as is practicable) – to be recorded in daily site HSE Report and also in weekly Environmental Inspection Checklist.

EPC Site Environmental Manager

Daily monitoring of appropriate acoustic covers installed on noisy equipment – to be recorded in daily site HSE Report and also in weekly Environmental Inspection Checklist. Monthly monitoring of maintenance of site vehicles and construction machinery – to be recorded in weekly Environmental Inspection Checklist and quarterly Environmental Audit Report.

Same as for the Construction phase above.

Project Number 44130065 Page 156

Al Ghaith Plant Environmental Manager

Noise

Emissions from operation of vehicles and temporary equipment

Decommissioning

Noise

Emissions from operation of Chlor-Alkali Plant

Construction

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Mitigation

Monitoring

Low

Signific ance

Impact

Same as for the Construction phase above.

Same as for the Construction phase above.

No Impact

Phase

Receptor

Not applicable.

Not applicable

Project Number 44130065 Page 157

Responsible Party

Al Ghaith Plant Environmental Manager

-

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Responsible Party

Maintenance of plant equipment as per manufacturer specifications and Plant Maintenance Philosophy – to be recorded in Plant Maintenance Checklist

Al Ghaith Plant Operations Manager

Moderate

Emissions from operation of Chlor-Alkali Plant

Operation

Noise

Since the potential mitigation measures concern the design of the plant facilities, the EPC Contractor in coordination with the Project Proponent will select the appropriate mitigation measures to be implemented in order to reduce noise emissions from operation of the Al Ghaith plant. These measures are detailed hereunder. Plant equipment will be selected and installed that has been designed to adhere to the Project noise philosophy as well as local regulations to minimise the potential for exceedance of noise limits during normal operation of the plant. The Al Ghaith Plant Operations Manager also will ensure that all plant equipment are regularly maintained to manufacturer specifications in order to reduce the potential for non-design performance of the equipment that can result in higher noise emissions from equipments.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

No Impact

Emissions from operation of Al Ghaith Plant

Decommissioning

Noise

It is recommended that low noise valves are used where practicable to minimise noise emissions during emergency situations and to protect any worker at a position close to these valves.

Not applicable.

Note applicable.

Project Number 44130065 Page 158

-

Emissions from abnormal events

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Phase

Signific ance

Low

Impact

Construction

Noise

Receptor

Mitigation

Monitoring

The EPC Maintenance Manager will ensure that all construction machinery and vehicles operational on site are maintained according to a set schedule as per the manufacturer’s specifications so that they are in good working condition at all times and consequently non-design noise emissions are minimised. In case malfunctioning equipment generating high/non-design levels is found on site, contingency procedures established by the Maintenance Department will be in place to address the issue and rectify it at the earliest possible.

Monthly monitoring of maintenance of site vehicles and construction machinery – to be recorded in weekly Environmental Inspection Checklist and the quarterly Environmental Audit Report.

Project Number 44130065 Page 159

Responsible Party

EPC Site Environmental Manager

Emissions from abnormal events

Phase

Signific ance

Low

Impact

Operation

Noise

Receptor

Mitigation

Monitoring

To reduce the risk of a human induced explosion occurring near to the large diesel inventory on site in the back up fuel storage tanks and leading to elevated noise levels, as well as to prevent any adverse effects on humans in the vicinity of the tanks, the Plant Operator will enforce controlled access of personnel/visitors to the back-up fuel storage tanks. Moreover, the area around the storage tanks will strictly be a no-smoking zone in order to minimise the potential for the fuel being ignited and resulting in a potential explosion.

Daily enforcement of indoor no smoking policy – to be reported in weekly field maintenance report.

In addition to these, the Plant Operator will also exercise control over the inventory of fuel entering the back-up fuel storage tanks and stored in them via the flow level controllers assembly as part of the tanks, in order to prevent an overflow occurring and again raising the potential for excessive noise emissions due to a resulting explosion.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Emissions from abnormal events

Decommissioning

Noise

The Plant Operator will also be responsible for enforcing the site emergency response requirements in the event of an explosion occurring to facilitate the appropriate mitigation measures to be implemented to control the ensuing fire and any associated elevated noise levels.

Same as for Construction phase.

Responsible Party

Daily monitoring of the Controlled Access of plant personnel/visitors to back-up fuel storage tanks – reporting not applicable. Monitoring undertaken once for appropriate flow level control in back-up fuel storage tanks. To be undertaken by the Plant Control Room Operator, and reported within the Plant Description Documentation.

Al Ghaith Plant Environmental Manager

Quarterly monitoring of the fire response procedure and the appropriate training of staff – to be reported in the Quarterly Environmental Report.

Monthly monitoring of maintenance of site vehicles and construction machinery – to be recorded in weekly Environmental Inspection Checklist and the quarterly Environmental Audit Report.

Project Number 44130065 Page 160

EPC Site Environmental Manager

No monitoring identified.

Al Ghaith Plant Environmental Manager

-

-

-

No monitoring identified

No additional mitigation measures identified.

Land used and community impacts

Low

-

Residual impact

No mitigation identified.

Land used and community impacts

Low

-

All

-

No additional mitigation measures identified.

All

-

Cumulative impact

Construction

Monitoring

Operation

Mitigation

Noise

Signific ance

Noise

Phase

Socioeconomic

Impact

Socioeconomic

Receptor

Maintain as an industrial zone and avoid any new residential or other recreational activities around the site

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 161

Responsible Party

Receptor

Impact

Phase

Signific ance

Mitigation

Monitoring

Low

Land used and community impacts

Decommissioning

Socio-economic

As the socio-economic benefits of the project are primarily beneficial mitigation measures have not been identified for most aspects of the project. The only mitigation measure that has been selected as an ultimate requirement of the project is: 1. A decommissioning plan for the site is produced. The decommissioning plan will be the responsibility of the Operations Manager prior to any decommissioning activities commencing and will need to consider issues such as waste handling and disposal, site investigations, and restoration of the site. This plan will need to be approved through EAD.

No monitoring program is considered necessary at this stage of the Project. When the site is eventually decommissioned post closure monitoring is recommended to ensure the fitness of the land for the intended future use. This shall be determined within the decommissioning plan.

Responsible Party

Al Ghaith Plant Environmental Manager

Decommissioning

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Operation

Social impact

No monitoring identified.

Major

Construction

Socioeconomic

Social impact

No mitigation identified.

Provide adequate assistance and facilities to allow permanent workers to integrate in the local community.

No monitoring identified.

Low

Socioeconomic

Social impact

Socio-economic

Note that other environmental mitigation measures including traffic management that will benefit the community are addressed in separate sections.

As mitigation for land use during decommissioning phase.

As monitoring for land use during decommissioning phase.

Project Number 44130065 Page 162

-

Decommissioni ng All

Residual impact

All

Socio- Socio-economic economic Socioeconomic

Cumulative impact

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Low

Operation

Economic impact

No mitigation identified.

No monitoring identified.

-

Major

Construction

Socioeconomic

Economic impact

Monitoring

No mitigation identified.

No monitoring identified.

-

Low

Socioeconomic

Economic impact

Mitigation

As mitigation for land use during decommissioning phase.

As monitoring for land use during decommissioning phase.

-

Signific ance

Impact

No additional mitigation measured identified.

No additional monitoring measure identified.

-

-

Phase

Receptor

No additional mitigation measured identified.

No additional monitoring measure identified.

-

Project Number 44130065 Page 163

Responsible Party

5.11. Risk Assessments In line with EAD technical guidance for EIA (2010) and the EAD EHSMS, accidental environmental risks associated with the Al Ghaith Project have been assessed within this section of the EIS. Accidental impacts are considered to be those impacts which occur due to unplanned events, mishaps, or failures during any project stage (construction, operation, or decommissioning). Examples of accidental events include (but are not limited to) the following: 

Failure of materials



Failure of equipment



Non-conformance with procedure



Unforeseen non-routine process



Process equipment/processes not performing according to design parameters

Examples of accidental environmental impacts include (but are not limited to) the following: 

Spills



Leaks



Uncontrolled discharge



Uncontrolled emissions



Generation of wastes (hazardous and non-hazardous)



Fire



Explosion



Process blow-downs

Within the EHSMS, AD EHSMS CoP05 – Risk Management (v1.2 July 2009) presents the methodology for the environmental assessment of accidental impacts. The environmental consequence and probability of an accidental impact is used to determine the level of ‘Risk’ which may result from the associated project activity. Each environmental impact is ranked to yield both a consequence and probability score. This is achieved through the use of prescriptive tables which provide a definition for each assigned rank (see Table 5 -11 and Table 5 -12). Environmental consequence of project interactions are ranked between 1 (insignificant consequences) and 5 (catastrophic consequences), while probability of occurrence is also ranked from 1 (rare) through to 5 (frequent). Once scores for consequence and

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 164

probability have been established, they are then used to determine the Risk of the environmental impact through the use of a matrix. The ‘Risk Categories’ matrix determines significance through the product of the environmental consequence of the interaction and the probability of the action occurring, and is expressed as ‘Risk = probability x consequence’. This Risk is expressed as a number between 1 and 25, with: 

1-3 representing low risk



4-6 representing moderate risk



8-12 representing high risk



15-25 signifying extreme risk

The lower half of the matrix provides details on the action which must be taken for environmental impacts defined within these categories. If a risk is identified as extreme, the activity/industry can not proceed in its current form as the risk is too high. Other required actions include design or procedure modifications such as remedial planning and further action subject to the environmental assessment. The Matrix is shown in Figure 1 -17. Section 5.11.1 presents the Environmental Hazard and Effects Register (EHER). Accidental environmental impacts for the Al Ghaith Project are identified and assessed for the magnitude of the potential environmental risk within the EHER.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 165

Table 5-11 Score

1.

Insignificant Consequence

Potential Environmental Impact and Potential Incident Consequence Rating from AD EHSMS CoP05

Land-based Ecosystem

Insignificant environmental impact. Occasional damage by erosion, or of flora and fauna. Some disruption to flora or fauna habitats

Aquatic Ecosystem

Atmosphere/ Waste/ Other

Cultural Heritage (Indigenous and Modern)

Temporary nuisance from noise, odour, dust, other air emissions, greenhouse gasses, vibration, visual impact. Occasional short-term impact and / or disruption to aquatic flora and fauna.

Minor use of water, fuels and energy and other natural resources.

Minor repairable damage to commonplace structures.

Results in the generation of significant quantities of nonhazardous wastes.

2.

Minor Consequence

Minor impacts on fauna/flora and habitat, but no negative impacts on ecosystem function. Limited damage to a minimal area of land of no significant value (i.e. no unique habitats). Temporary damage/disruption ( 50600V in equipment

Short circuit

Fire, personnel injury, fatality.

D1

D1

B1

Design to British Standards, UAE design codes

General

H-15.03

Voltage > 600V

Short circuit

Fire, personnel injury, fatality.

D1

D1

B1

Design to British Standards, UAE design codes

General

H-15.04

Lightning discharge

Lighting strike.

Fire, personnel injury, fatality.

D1

D1

B1

Do not work with conductor material during storms.

General

PEHSR Chlor-Alkali Plant Al Ghaith Industries

C1

B1

Project Number 44130065 Page 199

A1

Mitigation/Recovery Controls

Trained first aider on site.

Emergency response team follow emergency response procedure, trained first aider on site. Emergency response team follow emergency response procedure, trained first aider on site. Emergency response team follow emergency response procedure, trained first aider on site. Emergency response team follow emergency response procedure, trained first aider on site. Emergency response team follow emergency response procedure, trained first aider on site. Trained first aider on site.

Risk Potential

B1

No confined space working situations present on site.

C1

Small working volume, PPE, operational procedures, training

Fatality.

H-20.06

Chlorine

Uncontrolled release from process pipes (10kg max release).

Personnel injury, fatality.

General

H-21.11

Corrosion inhibitors

Breach of containment resulting in spillage of corrosion inhibitors.

Damage to environment.

A1

A1

A1

A1

General

H-21.12

Scale inhibitors

Breach of containment resulting in spillage of scale inhibitors.

Damage to environment.

A1

A1

A1

A1

H-21.17

Used engine oils

Breach of containment resulting in spillage of used engine oils.

Damage to environment.

General

H-22.04

Sodium hypochlorite

Breach of containment resulting in spillage of sodium hypochlorite.

Minor injury, minor environmental impact.

A1

A1

A1

A1

General

H-23.02

Hydrochloric acid

Breach of containment resulting in spillage of hydrochloric acid.

Damage to environment, chemical burns.

C2

A2

A2

A2

PEHSR Chlor-Alkali Plant Al Ghaith Industries

A1

Prevention Controls

Asphyxiation.

General

D1

Reputation

Consequences

Assets

Threats / Top Event

Excessive N2

General

H-19.04

Sources

Environment

General

HAZid

People

Guideword/ Activity

Risk Controls

D1

A1

A1

A1

A1

Project Number 44130065 Page 200

A1

Corrosion inhibitors held in appropriate containment units, operational procedures in place. Scale inhibitors held in appropriate containment units, operational procedures in place. Engine oils held in appropriate containment units, operational procedures in place. Sodium hypochlorite held in appropriate containment units, operational procedures in place. HCl held in appropriate , bunded containment units, operational procedures in place.

Mitigation/Recovery Controls

Emergency response team follow emergency response procedure, trained first aider on site. Emergency response team follow emergency response procedure, trained first aider on site. Appropriate spill/ splash kit equipment on site, trained first aider on site. Appropriate spill/ splash kit equipment on site, trained first aider on site. Appropriate spill/ splash kit equipment on site, trained first aider on site. Appropriate spill/ splash kit equipment on site, trained first aider on site. Appropriate spill/ splash kit equipment on site, trained first aider on site.

Risk Potential

Threats / Top Event

Damage to environment, chemical burns.

C2

General

H-23.04

Caustic soda

Breach of containment resulting in spillage of caustic soda.

General

H-25.01

Manual materials handling

Misuse/ improper handling.

Personnel injury.

General

H-25.04

Heat stress

Over exposure.

General

H-25.05

High humidity

General

H-30.01

Dangerous goods in transport activities

Primary Brine Section

Ref

Waste sludge

Secondary Brine Section

Ref

Filter backwash

PEHSR Chlor-Alkali Plant Al Ghaith Industries

A2

A2

A1

A1

A1

Dehydration, personnel injury.

C2

A2

A2

Over exposure.

Dehydration, personnel injury.

C2

A2

A2

Breach of containment resulting in spillage.

Environmental, personnel injury.

B2

B2

A2

A2

Environmental impact.

A1

A1

A1

A1

Environmental impact.

A1

A1

A1

A1

Breach of containment resulting in spillage. Breach of containment resulting in spillage.

A2

Reputation

Sources

Assets

Consequences

Environment

HAZid

People

Guideword/ Activity

Risk Controls

Project Number 44130065 Page 201

Prevention Controls

Caustic soda held in appropriate bunded containment units, operational procedures in place. All personnel given appropriate training, operational procedures up to date. Appropriate UAE Health and Safety laws implemented. No working outdoor during hottest part of day. Appropriate UAE Health and Safety laws implemented. No working outdoor during hottest part of day. All dangerous goods in transit held in appropriate containment tankers, operational safety procedures in place. Sludge held in appropriate containment units. Brine held in appropriate containment units.

Mitigation/Recovery Controls

Appropriate spill/ splash kit equipment on site, trained first aider on site. Trained first aider on site.

Trained first aider on site.

Trained first aider on site.

Trained first aider on site. Appropriate spill/ splash kits available. Appropriate spill/ splash kits available. Appropriate spill/ splash kits available.

Risk Potential

Risk Controls

HAZid

Sources

Threats / Top Event

Environment

Assets

Reputation

Secondary Brine Section

Ref

Ion exchange regeneration waste

Breach of containment resulting in spillage.

Environmental impact.

A1

A1

A1

A1

Electrolysis of Salt

Ref

Maintenance activity

Misuse/ improper handling.

Personnel injury.

B1

B1

C1

A1

Caustic Conc./ Flaking

H-25.01

Manual materials handling

Exposure to caustic, Spill/ splash

Chemical burns.

C2

A2

A2

Hydrochloric Acid

H-25.01

Manual materials handling

Exposure to HCl pill/ splash

Chemical burns.

C2

A2

A2

Consequences

People

Guideword/ Activity

A2

Maintenance, PPE, safety procedures & training

Appropriate spill/ splash kit equipment on site, trained first aider on site.

Over pressure receiver.

Equipment damage, personnel injury.

C1

A1

A1

A1

Instrument Air System

Ref

ER operations

Release of compressor oil.

Damage to environment.

A1

B1

A1

A1

Page 202

Trained first aider on site.

A2

ER operations

Project Number 44130065

Appropriate spill/ splash kits available.

Appropriate spill/ splash kit equipment on site, trained first aider on site.

Ref

Al Ghaith Industries

Liquid must be held in appropriate containment units. Maintenance operator's manuals followed and updated regularly. Appropriate PPE provided. All relevant safety procedures & training implemented.

Mitigation/Recovery Controls

Maintenance, PPE, safety procedures & training

Instrument Air System

PEHSR Chlor-Alkali Plant

Prevention Controls

Safety valve controls implemented. Regular maintenance and checking of safety valves. Safety valve controls implemented. Regular maintenance and checking of safety valves.

Trained first aider on site.

Appropriate spill/ splash kit equipment on site.

Risk Potential

Threats / Top Event

Reputation

Prevention Controls

Damage to environment.

A1

A1

A1

A1

Appropriate procedures for informing regulator in place.

Damage to environment.

A1

A1

A1

A1

pH adjustment prior to discharge.

Ref

ER operations

Waste water exceeds environmental discharge limits.

Effluent Neutralization System

Ref

Neutralization tank

Off spec discharge.

Al Ghaith Industries

Consequences

Assets

Sources

Waste Water System

PEHSR Chlor-Alkali Plant

Environment

HAZid

People

Guideword/ Activity

Risk Controls

Project Number 44130065 Page 203

Mitigation/Recovery Controls

None

Table 6-15 Occupational Health Hazards Initiating Events / Causes

Exposure Rating

Occupation al Health Risk

Site watering PPE

E

Medium

2

National Legislation Rest area provided with water / hydrolite provided

C

Medium

Noise emissions

2

PPE Piling activities during daytime Regular maintenance

B

Medium

Application of waterproofing

Toxicity Fire

2

PPE Application method statement/procedures

A

Low

Application of epoxy coatings

Toxicity

1

PPE

A

Low

2

PPE Competent Personnel Chemical handling procedures

A

Low

Consequence s / Escalation

Hazard Rating

Earthworks

Dust Generation

1

Weather and environment

High temperatures

Heat Stress

2.7

Noise / Dust / Odour/ Light/ Radiation / Electromagnetic emissions

Piling Activities

2.10

Construction methods

4.2

Construction methods

No.

Keyword

2.1

Site preparation / groundworks

2.3

6.6

Chemical Handling

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Application/use of lube oils, resins, paints.

Fumes

Safeguards/ Controls/ PCDM

Project Number 44130065 Page 204

As the hazard effect register above shows, most hazards either present a low risk, or will be effectively managed by the safeguards and controls provided (Probability A Exposures are negligible, or B - Exposures are controlled and likely to remain so in accordance with screening and performance criteria). The exposure rating or one hazard has been assessed as Probability C (Exposures are currently controlled to meet screening and performance criteria, but control cannot be assured). This being the hazard of “weather and environment”. Obviously, the weather is outside the direct control of the construction team. It is therefore necessary to mitigate the effects of the weather to ensure that the risk is acceptable. It is considered that the safeguards proposed meet good practice and are suitable and sufficient to reduce risk to ALARP. Table 7-16 Hazards – Safeguards Rationale

No.

Hazard

Rationale

Construction Phase 2.3

Weather and Environment

National Legislation prevents working outside during the hottest part of the day in the summer months. A rest area is provided with water/hydrolite as required.

A discussion of the occupational health hazards and their management is presented in the following sections. The health and safety hazards inventory tables given in the sections below do not show risk ranking as they are generic.

6.5.

Physical Health Hazards Physical health hazards refer to extraneous physical forces that can have an effect on the health of the individual. They may be found in a specific work environment (e.g. working beside a noisy generator or air compressor) or may be associated with equipment used (e.g. vibration from impact wrench). The main physical occupational health hazards likely to be involved during the construction, pre-commissioning and commissioning phases of the Project are depicted below. These include the potential hazards of: excessive levels of noise, inadequate lighting, excessive levels of vibration from working with heavy moving equipment or rotating equipment, exposure to non-ionizing radiation, exposure to thermal extremes, electricity, and machinery hazards.

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Project Number 44130065 Page 205

6.5.1. Noise Table 7-17 Health Hazard Inventory – Physical Agents – Noise

Hazard Title Location of hazard

Noise General in all the areas associated with the use of all rotating and moving equipment, Use of compressed air / electric tools, portable generators etc.

Relevant Corporate Standards Excessive exposure to noise over a period of time may result in Noise Induced Hearing Loss (NIHL). This is a progressive form of deafness categorised largely by the loss of hearing response at a particular frequency in the ear (4 KHz). This is clearly shown by a marked dip in Health Effects of Hazard hearing response at the 4KHz band when audiometry is performed on an affected individual. Noise exposure may also result in Tinnitus. This is a constant ringing in the ears that, in many cases, is highly distressing for the individual affected. It is not expected that any of the Construction areas will be subject to high noise levels from existing plant since these are located away from noisy plant areas.

Risk Control Recommendations

Construction noise associated with near ground-level works should be controlled using standard techniques such as the placement of stockpiled materials to screen any adjacent noise sensitive areas. Regular equipment maintenance, the use of “silenced” equipment where appropriate, together with local enclosures for particularly noisy activities will help to reduce the spread of construction noise. Construction generators and air compressors will have full acoustic protection (acoustic box).

Main Activities / Tasks

Mechanical Maintenance in plant areas Electrical Maintenance Activities Instrument Maintenance Activities Grit blasting Power washing and brushing / hydrojetting Use of powered tools (grinders, needle guns) Diesel generator

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Crane Operations Floor cleaning Workshop activities Mechanical Technicians Painting Operatives Main Personnel Involved Contractors Inspection

According to the UK Health and Safety Executive Publications, work-related hearing damage is one of the most serious and widespread industrial diseases. Construction industry workers generally suffer significant loss of hearing after more than fifteen years in the trade. Occupational exposure to noise can result in fatigue and work-related stress, tinnitus, hearing damage, and eventual deafness if not managed appropriately. Noise can also prevent work from being conducted effectively, for example by making communication difficult or by preventing alarms from being heard. Temporary threshold shift occurs when hearing is temporarily affected by a short exposure to high noise levels but returns on stopping the exposure. This may be typical of exposure such as where a single shift is working at high noise levels with inadequate controls. The threshold shift can become permanent due to long term damage to the sensitive hairs in the ear which transmit sound to the auditory nerve. Typically as stated above this may occur over a period of ten to fifteen years and typically, due to the human ear’s response to sound frequencies, has the greatest effect in the normal human speech range and can severely affect resultant quality of life. Physical damage to the small bones in the middle ear and permanent damage to the sensitive hairs in the cochlea can also result from a single high intensity sound impulse. High levels of background noise when sleeping or carrying out daily activities outside the workplace can result in stress, poor sleep and other psychological effects. Construction noise may be controlled through a variety of measures, and application of these should be based on the Source-Path-Receiver principle. Noise should be controlled or eliminated at source where possible rather than by the use of PPE as a first resort. In fact PPE should be used as a last resort where other measures are not sufficient or are impracticable.

Control at Source

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Project Number 44130065 Page 207

 Purchasing equipment with reduced noise specifications and noise attenuation devices (e.g. low noise electric motors)  Use of baffles, silencers or acoustic enclosures on equipment  Profiling and stiffening of panels on equipment to prevent vibration and noise conduction  Maintenance of equipment to prevent deterioration of controls designed to ensure noise levels do not increase  Avoid parallel scheduling for noisy tasks  Minimization of drop heights for waste soils and other loads Control of Noise Path  Construction of temporary screens or bunds, using waste soils, stock piled materials or acoustic fencing, interrupts the path between the source and receiver  Provision of local enclosures around noisy working areas prevents the noise from affecting those outside the area and is appropriate for static areas such as the ones involved in the current work areas  Pointing vehicle exhausts away from noise receivers  As a general principle, impulsive methods such as impact piling should be avoided, especially when in close proximity to services corridors or other vibration sensitive receivers. When piling is required, bored or cast-in-situ methods should be favoured. Control of Noise at the Receiver  Use of PPE: Appropriate PPE should be used to supplement other noise management measures on the construction site. The use of hearing protection is mandatory in “hearing protection zones”. These zones are areas where an individual would be exposed to a noise level greater than 85dB(A) LEP,d or the peak action level. These zones must be clearly identified and marked with signs or communicated to the workforce by suitable means  Work Rotation will reduce the overall daily noise dose experienced by an individual and can be used to manage the overall LEP,d experienced by the workforce involved in the noisy task of the work.  The time-weighed average dBLA eq level (or noise dosage) to which employees are exposed depends upon the various noise levels and times spent at each noise level. The 8-hour limit for unprotected hearing is set at no more than 85 dBLAeq, 8h, although there are international pressures to reduce this limit to 80 dBLAeq, 8h.

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Project Number 44130065 Page 208

6.5.2. Lighting Adequate natural or artificial lighting must be provided particularly in workshops and work areas as well as in surrounding service areas. Table 7-18 Occupational Health Hazard Inventory – Physical Agents – Lighting

Hazard Title

Lighting

Location of hazard

Offices areas, workshops, kitchens, storage areas

Relevant Corporate Standards Health Effects of Hazard Risk Control Recommendations

Eye strain, arc eye and cataracts Comply with ADNOC recommended illumination levels depicted inTable 7 -19 Mechanical Maintenance in plant areas Electrical Maintenance Activities

Main Activities / Tasks Instrument Maintenance Activities Office and workshop activities Mechanical Technicians Instrument Technicians Main Personnel Involved Electrical Technicians Cooks and catering personnel

Lighting is often overlooked as an occupational health hazard and a hazardous situation. The following conditions can severely impact sight or contribute to pain and discomfort. Glare from computers and reflecting surfaces is often associated with eye strain and subsequent discomfort and pain leading to fatigue and headaches. Poor lighting conditions are very often observed in workshop areas and are rarely mitigated. For the construction phase, most work will be outdoors. Suitable lighting will be provided in all offices and work areas. Table 7-19 ADNOC Recommended Illumination Levels

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Project Number 44130065 Page 209

Area / Location

Illumination (Lux)*

Area / Location

Illumination (Lux)*

Ablution Block

200

Office Area

500

Bakery

300

Recreation Room

300

Clinic

500

Room Desk Surface

300

Dining Room

300

Sleeping Rooms

150

Dormitory Living Room

200

Stairways (Interior)

150

Exterior Area (Compound)

50

Storage Areas

200

Galley

500

Toilets

200

Hallways

150

Walk In Freezers

100

Kitchens

500

Walkway (Exterior)

50

Laundry Room

250

Workshops

300

*Measurement taken 1.2 meters above floor

6.5.3. Vibration Table 7-20 Occupational Health Hazard Inventory – Physical Agents – Hand- arm Vibration/Whole Body Vibration

Hazard Title Location of hazard

Relevant Corporate Standards

Health Effects of Hazard

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Hand-Arm Vibration (HAV) / Whole Body Vibration (WBV) Use of hand-tools – such as grinders, needle-guns and electrical drills, jackhammers, compactor, drilling machine/lathe. ADNOC-CoP-V3-01 – ADNOC Manual of Codes of Practice – Framework of Occupational Health Risk Management and Underlying Codes of practice. ADNOC CoP-V3-05 – ADNOC Manual of Codes of Practice – Physical Agents. Excessive exposure to hand-arm vibration over a period of time may result in Hand-arm Vibration Syndrome (HAVS). This is a condition that affects both the nervous system and the blood vessels of the hand – particularly the

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Hazard Title

Hand-Arm Vibration (HAV) / Whole Body Vibration (WBV) fingers. Symptoms of this condition include pain, numbness, temperature sensitivity (particularly to cold) and blanching of the fingers (also known as Vibration White Finger). In addition to the pain inflicted by this condition, it can seriously affect the quality of life for the person suffering from it. Activities such as gardening, DIY or playing golf can be seriously restricted – particularly in cold weather. Work using vibrating hand tools can also result in injuries to tendons and ligaments of the hand and wrist.

Risk Control Recommendations

Mapping of HAV /WBV sources. According to the ADNOC Codes of Practice, where whole body vibration exceeds 0.5 m/s 2 per day (or 1.25 m/s2 1-hour average) control measures should be put in place, with vibration exposure assessments and health surveillance of exposed workers. Above 0.7 m/s2, job rotation should be used to reduce exposure time. Where hand arm vibration exceeds 2.5 m/s2 per day similar monitoring and control measures must be implemented. Equipment rated as 10 m/s 2 for short periods, and 20 m/s2 as a daily average must be marked and exposure time reduced severely. Use of power tools (grinders and needle guns) Use of compactor

Activities / Tasks Cutting Drilling machine/lathe operations Grinders and needle gunners Personnel Involved Mechanical Technicians (grinders).

The construction of the facilities will involve the use of percussive equipment (such as jack hammers), hand-held power tools, powered equipment such as pneumatic drills and air lances and non-powered work equipment such as hammer and bolster. This equipment can cause hand arm vibration syndrome (HAVS). This is a painful condition which represents a range of potentially permanent injuries affecting the circulation, nerves, bones, and muscles in the hands and arms. It gives rise to the effect known as vibration white finger (VWF). This aspect can be controlled by the adoption of hand arm vibration exposure limits (ISO 53491). Construction activities will also involve the deployment of earth-moving equipment, dumper trucks, etc which can subject an operator to whole body vibration (WBV). This 1

ISO 5349-1:2001 - Mechanical vibration - Measurement and evaluation of human exposure to hand-transmitted vibration -Part 1: General requirements. ISO 5349-2:2001 - Mechanical vibration - Measurement and evaluation of human exposure to hand-transmitted vibration -- Part 2: Practical guidance for measurement at the workplace.

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can cause lower back pain and spinal damage. This aspect can be controlled by the adoption of the WBV limits given in ISO 2631 2. Practical control measures would include responding to worker complaints and symptoms (e.g. of ‘bad back’), minimising exposure periods by rotating work activities, and improved vehicle seating. WBV can cause serious musculoskeletal disorders affecting the spine and is associated with back pain. Other work factors such as posture and heavy lifting activities are also known to contribute to back problems. Whole body vibration symptoms range from a general feeling of discomfort and motion sickness to lower jaw symptoms, chest and abdominal pains, urge to urinate and influence on breathing movements. Engineering Controls  Examining alternative methods of working that do not require use of high vibration tools  Purchasing equipment with improved axle and/or cab suspension for heavy machinery.  Fitting anti-vibration mounts where possible  Routing of the exhaust of hand held engine powered equipment through the handles reduces the effect of vibration in cold climates, but is not expected to be of significant benefit in this climate Management Practices Means to reduce hand-arm vibration include: 

Reducing exposure time of machinery operators though work breaks and job rotation and allocation



Ensuring the right tool is used for the right job under adequate supervision



Advising workers on exercises for their fingers to improve blood flow



Labelling all equipment and tools (new tools if acceleration exceeds 2.5 m/s 2 as required by CoP V3-05)



Ensuring the use of anti vibration or low vibration tools, hand tools, grips and gloves



Constructing jigs to hold materials or tools

2

ISO 2631-1:1997 - Mechanical vibration and shock - Evaluation of human exposure to whole-body vibration -- Part 1: General requirements.

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

Designing the job so that poor posture (which may cause strain on hands and arms) is avoided



Maintaining tools to the manufacturer’s specifications to avoid worsening vibration e.g.:



o

Replace vibration mounts before they are worn out;

o

Ensure rotating parts are checked for balance and replaced if necessary;

o

Keep tools sharp.

o

Taking advice from the equipment manufacturer on safe use of the equipment

Providing tool support to take the weight of the tool (e.g. tensioners or balancers),so: o

Allowing the operator to reduce grip and feed force;

o

Letting the tool do the work;

Medical Surveillance Programmes, Employee Awareness Employee self-checks: For example, tingling of the fingers lasting more than 20 minutes after using vibrating equipment, waking at night with pain, tingling, or numbness in hand or wrist, numb fingers, blanching of the fingers i.e. turning visibly white from the tips with a clear margin. Before using vibrating tools, medical screening and on-going medical checks should be undertaken.

6.5.4. Non Ionising Radiation Non-ionizing electromagnetic radiation (NIEMR) includes optical radiation (UV, visible and infrared) and longer wavelength electromagnetic fields (such as those associated with electrical power, mobile telecommunications, microwaves and radio). A range of industrial processes generate NIEMR, but the more commonly known sources – and the ones of relevance to the project – include the sun, electrical equipment (photocopiers, welding equipment, television, microwaves, and visual display units), telecommunications and electricity supply. ADNOC does not currently publish limits for exposure to NIEMR. In its absence, guidance from international sources was sought and is presented in the following summary tables.

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Table 6-21 Occupational Health Effects of Non-ionizing Electromagnetic Radiation

NIEMR

Source

Occupational Health Effects

Welder’s flash or arc eye’: inflammation of superficial membranes of the cornea and the eyelids (“sunburn” of Arc welding the eyes) caused by sunlight or intense reflection from sand or the sea Cataracts: clouding of the eye lens: UV sources in Sunburn, with blistering and swelling if severe, skin photocopiers and spots, which can turn into cancers such as basal cell laser printers. carcinomas, the most common type of skin cancer, and melanomas, the most dangerous form of skin cancer, Lasers. which can be fatal if not detected and treated in the early Welding. stages The sun

Ultraviolet (UV)

The sun Spotlights Visible light

Arc welding Laser devices such as laser

Visible light is not normally a problem, but where intense (e.g. in lasers) can potentially cause damage to the cornea and retina of the eye. It can also cause cataracts

levels

Very Low Frequency (VLF) and Extra Low Frequency (ELF)

Power lines & cables, wiring, electric equipment

VLF and ELF have been linked to potentially increased likelihood of a number of cancers, including leukaemia (such as motors) and brain tumours Electronic equipment (e.g. computers, televisions)

Infrared (IR)

The sun

Burns to the eye, including the retina, Cataracts

Flares

Heat stress, including heat stroke

Hot surfaces Lasers.

Skin burns

Molten glass.

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NIEMR

Source

Occupational Health Effects

Infrared lamps.

Radiofrequency fields can have thermal and non-thermal effects Thermal effects

Mobile communications Radiofrequency Fields

(phones, CB radios, walkie talkies)

Exposure to radiofrequencies can cause a rise in body temperature. An increase of more than 6ºC can lead to death. Lower increases can cause heat stroke, brain damage, infertility in men and birth defects. Other possible thermal effects are cataracts and localised burns Non-thermal effects

Dielectric heaters The non-thermal effects can include headaches, eyestrain, fatigue, loss of appetite, sleep disturbance, and Induction heaters interference with pacemakers and other medical implants. Radiofrequency fields may also cause changes in cells. Radiofrequencies lower than 100 MHz can charge metal and poorly grounded objects. The potential effects include sparking on metal structures, activation of electrical devices and ignition of flammable substances

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Table 7-22 Health Hazard Inventory – Physical Agents – Non-Ionising Radiation – Ultraviolet light

Hazard Title

Non-ionising radiation – Ultraviolet Light Welding operations have the potential to cause “arc-eye” – an acute condition caused by exposure to UV light generated from the welding arc.

Location of hazard

Relevant Corporate Standards

During outdoor activities– personnel are exposed to high levels of UV light from the sun, this is particularly of importance in the UAE where there is an average of 357 sunny days per year. ADNOC-CoP-V3-01 – ADNOC Manual of Codes of Practice – Framework of Occupational Health Risk Management and Underlying Codes of practice. ADNOC CoP-V3-05 – ADNOC Manual of Codes of Practice – Physical Agents.

Health Effects of Hazard Welding operations / gas cutting arc-eye. This is a painful, acute condition caused by the exposure of the cornea to the intensive UV light derived from the electric arc that is used during welding procedures. When unprotected eyes are exposed to strong ultraviolet rays, such as an electrical arc, they will become inflamed and sore and exposure can result in a temporary loss of sight Using evidence systematically collected from the scientific literature, nine adverse health outcomes have been identified that are clearly caused by UV exposure. The nine diseases assessed were: Cutaneous malignant melanoma (CMM): Melanoma of the skin is a malignant cancer of great severity. Although treatment is improving, melanoma still carries a significant risk of death. Between 50% and 90% of the burden of disease from melanoma is due to UV exposure. Squamous cell carcinoma of the skin (SCC): This is another type of malignant skin cancer which generally progresses less rapidly than melanoma and is less likely to cause death or ongoing disability. Of the total SCC disease burden, 50-70% is attributable to UV exposure. Basal cell carcinoma of the skin (BCC): This skin cancer appears predominantly in older people and grows slowly by local spread. The incidence and mortality of BCC were estimated to be 50-90% attributable to UV exposure. Squamous cell carcinoma of the cornea or conjunctiva (SCCC): This is a rare tumour of the surface of the eye. Some 50-70% of the disease burden due to SCCC is attributable to UV exposure.

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Hazard Title

Non-ionising radiation – Ultraviolet Light The following conditions are also the consequence of excess UV, but there is considerable uncertainty about the overall burden of disease estimates, since few data are available on incidence and/or UV-attributable fraction: Photoageing: Chronic sun damage is associated with the development of skin conditions called solar keratoses. On rare occasions, these are premalignant conditions. The burden of disease due to solar keratoses is 100% attributable to UV exposure. Sunburn: Sunburns may be severe and blistering, and the resulting disease burden is 100% attributable to UV exposure. Cortical cataract: Cataract is an eye disease where the lens becomes increasingly opaque, resulting in impaired vision and eventual blindness. Long term sun exposure to the eye increases the risk of developing a specific cataract type called cortical cataract. Five percent of all cataractrelated disease burden is directly attributable to UV exposure. Pterygium: This is a wing-shaped fleshy growth on the surface of the eye. 40-70% of the disease burden is attributable to UV exposure. Reactivation of herpes of the lip (RHL): Excessive UV exposure causes immunosuppression and reactivation of the herpes simplex virus (“cold sores”). 25-50% of the disease burden is attributable to UV exposure. Personnel wear coveralls and hard hats Mitigation from eye-damage – UV protective safety goggles Welders shield

Risk Control Recommendations

Burners goggles Labourers wear protective clothing during daily work Protective shelters. Suitable protective clothing and administrative controls, including job rotation and rest breaks, should be provided where engineering controls are unavailable or ineffective to reduce exposure levels. Welding.

Activities / Tasks Work outside during summer. Maintenance Technicians Personnel Involved

Operators Labourers

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The UV region covers the wavelength range 100-400 nm and is divided into three bands: 

UVA (315-400 nm)



UVB (280-315 nm)



UVC (100-280 nm).

Worldwide some 12 to 15 million people become blind from cataracts annually, of which up to 20% may be caused or enhanced by sun exposure according to WHO estimates. Furthermore, a growing body of evidence suggests that environmental levels of UV radiation may suppress cell-mediated immunity and thereby enhance the risk of infectious diseases and limit the efficacy of vaccinations. UAE is located close to the equator and hence, people are exposed to the very high levels of UV radiation that occur in these regions. It is a popular misconception that only fair skinned people need to be concerned about overexposure to the sun. Although darker skin has more protective melanin pigment and the incidence of skin cancer is lower in dark skinned people, skin cancers do occur within this group and unfortunately they are often detected at a later, more dangerous stage. The risk of UV radiation-related health effects on the eye and immune system is independent of skin type. UV reaching the earth’s surface is largely composed of long-wavelength UVA with a small amount of the shorter wavelength UVB. Most UVB and the very short wavelength UVC is filtered out by the atmosphere. UV radiation levels are influenced by:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Sun elevation: the higher the sun in the sky, the higher the UV level, with an increase in UVB relative to UVA. Thus UV levels vary with time of day and time of year.



Latitude: the closer to equatorial regions, the higher the UV levels.



Cloud cover: UV levels are highest under cloudless skies. However, even with cloud cover, UV levels can be high due to scattering within the atmosphere.



Altitude: at higher altitudes, the atmosphere is thinner and the air mass is decreased; less UV is absorbed.



Ozone: ozone present in the atmosphere absorbs some of the UV that would otherwise reach the earth’s surface. Ozone depletion leads to increased UVB levels with little impact on UVA levels.



Ground reflection: grass, soil and water reflect less than 10% of UV; fresh snow reflects as much as 80%; dry beach sand about 15% and sea foam about 25%.

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UV can neither be seen nor felt. Therefore UV measurements are necessary to determine precisely the extent of ground level (ambient) UV. UV measurements such as the global solar UV index add up all the solar UV, taking account of its ability to cause skin damage. If measurements are not available, an approximation of ambient UV levels can be based on geographic latitude. For individuals, the UV exposure additionally depends on factors such as behaviour and use of sun protectants, e.g., clothing, hats, sunscreen and sunglasses, during outdoor (including occupational) activities. A person’s skin type is also important. Fair skinned people suffer from sunburn much more readily than dark-skinned people. Prevention of UV overexposure:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Limit time in the midday sun: The sun’s UV rays are the strongest between 10 a.m. and 2 p.m ( = 2 hours each side of the solar noon). To the extent possible, limit exposure to the sun during these hours.



Use shade wisely: Seeking shade when UV rays are the most intense is recommended, however, shade structures such as trees, umbrellas or canopies do not offer complete sun protection.



Wear protective clothing: A hat with a wide brim offers good sun protection for eyes, ears, face, and the back of your neck. Sunglasses, with adequate side protection that provide 99 to 100 percent UV-A and UV-B protection will greatly reduce eye damage from sun exposure. Tightly woven, loose fitting clothes will provide additional protection from the sun.



Use sunscreen: Liberal application of a broad-spectrum sunscreen of SPF 15+ and re-application every two hours, or after working outdoors, can help protect the skin from UV. Sunscreen should be used to protect the skin when exposure is unavoidable.



It is noted that experience from previous projects in Abu Dhabi that most workers cover their body and head to prevent sun exposure. A policy of wearing long sleeves at all times should be in place.

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6.5.5. Thermal Extremes Table 7-23 Occupational Health Hazard Inventory – Physical Agents – Thermal Extremes

Hazard Title Location of hazard

Thermal Extremes Heat stress is an issue during manual work outdoors during the construction phase. Heat stress: Heat stroke may occur when core body temperature rises above 40 degrees. Likely to only become an issue where personal are exposed to high temperatures, combined with a high workload. Can be fatal if untreated. Other heat-related conditions include: • Heat Syncope – heat induced fainting. • Heat Stroke, which occurs when the body’s temperature regulatory system fails and sweating, becomes inadequate. The victim is mentally confused, delirious, perhaps in convulsions, or unconscious. Unless the victim receives quick and appropriate treatment, death can occur

Health Effects of Hazard

• Heat Exhaustion occurs when large quantities of fluids and salts are lost through copious sweating. The victim may vomit or lose consciousness • Fainting may occur when a worker unaccustomed to hot environments stands erect and immobile. Vasodilation causes the blood to pool rather than return to the heart for recirculation • Heat Rash or prickly heat occurs in hot, humid environments where sweat does not evaporate easily • Transient Heat Fatigue refers to the temporary discomfort and mental or psychological strain arising from prolonged heat exposure. Heat acclimatization should reduce the severity of this disorder

Relevant Corporate Standards

ADNOC-CoP-V3-01 – ADNOC Manual of Codes of Practice – Framework of Occupational Health Risk Management and Underlying Codes of practice. ADNOC CoP-V3-05 – ADNOC Manual of Codes of Practice – Physical Agents.

Risk Control Recommendations

Heat stress workshops or awareness campaign

Activities / Tasks

All outdoors activities

Personnel Involved

Various

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Access to drinking water on site. See below

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The construction workers on the Project are, potentially at risk of heat stress. Heatinduced disorders range in their severity according to a number of factors including duration of exposure, individual fitness, ambient temperature, fluid intake and work rate. Four environmental factors affect the amount of stress a worker faces: temperature, humidity, radiant heat (sun-shine) and air velocity. Perhaps most important to the level of Heat stress an individual faces are personal characteristics such as age, weight, fitness, medical condition and acclimatization to the heat. Remediation methods are: Acclimatisation: The human body can adapt over time to heat exposure. As cardiovascular demand is reduced, the worker will sweat more efficiently and maintain body temperature more easily. For many workers already adapted to UAE working conditions this is already the case. Fluid Replacement Provide workers with large and easily available amounts of water and recommend drinking regime of one cup every 20 minutes. Provide adequate supplies of water and other drinking liquids in all working areas. Engineering Controls Provide air ventilation and local air cooling using fans, air conditioning where feasible, shielding (carefully placed to avoid loss of air flow and regularly cleaned to maintain effectiveness). Dead man’s switch or other safeguards to avoid loss of equipment control in the event of fainting. Worker Monitoring Programmes Personal monitoring is required for all workers exposed to the risk of heat stress. Training in heat management should include guidance on measuring workmates’ heart rate and anticipating signs of heat stress in fellow workers. Other Administrative Controls should include reducing the physical demands of the work where possible (e.g. using mechanical aids to avoid manual handling); providing recovery areas (e.g. shaded with good air circulation); implementing shift work regimes (early morning, night work) and intermittent rest periods with water breaks; using relief workers; pacing workers to a specific job; assigning extra workers; limiting worker occupancy and providing air conditioning and adequate ventilation for worker (CoPV305). The EPC Contractor will implement a plan to control Heat Stress risk, by having in place appropriate preventative measures, recognising the symptoms of heat stress, monitoring the ambient temperature and having suitable medical aid on hand. Heat stress occurs when the body cannot dispose of excess heat. When this happens, the body’s core temperature rises and the heart rate increases. As the body continues to store heat, the individual begins to lose concentration and has difficulty focusing on a task; they may become irritable or sick and often lose the desire to drink. The next stage is most often fainting, and death is possible if the person is not removed from the heat stress.

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6.5.6. Electricity Table 7-24 Occupational Health Hazard Inventory – Physical Agents – Electricity

Hazard Title Location of hazard

Electricity Electrical supplies, cables

Relevant Corporate Standards Spasms, burns, muscle paralysis, or death can result depending on the amount of the current flowing through the body, the route it takes, and the Health Effects of Hazard duration of exposure Injury to persons, even small electric shock can result in loss of balance and resulting falls, from ladders, scaffold or other work platforms Risk Control recommendations

See below

Activities / Tasks

All involving electrical supply

Personnel Involved

The particular groups at risk from electrocution would include electrical and control system workers and those carrying out general construction works where this is a possibility of striking cables during excavation

For most people contact with an electrical current will have the following health effects. Table 7-25 Health Effects of Electricity

Effect Death from disturbed heart action

Current (mA)

Voltage (V)

1000

Above 230

Can cause serious burns, shock, stopped breathing Ventricular fibrillation Paralysis of diaphragm

200 – 240 50

Above 50

30-40

Above 50

In extreme cases can cause serious burns Makes hands “clamp-on” Muscular contraction, burns Involuntary reflex Current can be felt as a pain Perception Current can be felt as a tingle

70 or more 15-20

25 or more

2

20 – 25

Below 1

15

Health effects could result if:

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

Individual is in direct contact with the electrical energy



The electricity arcs (jumps) through a gas (such as air) to a person who is grounded (that would provide an alternative route to the ground for the electricity)



The heat generated by the electric arc causes thermal burns including flash burns from heat generated by an electric arc



Materials that catch on fire from heating or ignition by electrical currents causing flame burns. High voltage contact burns can cause severe internal burns while leaving only very small injuries on the outside of the skin



Muscle contractions, or a startle reaction cause a person to fall from a ladder, scaffold or aerial bucket

Risk Control recommendations: Control and Mitigation measures against accidental electrocution include: 

Employing only trained competent electrical and control engineers and technicians. Competence should be tested and verified against a training and skills matrix.



The use of service plans and cable locating devices will reduce the likelihood of penetration of high-voltage cables.



Electrical tools, where possible should be run from 110V centre tapped earth systems. This will limit the potential voltage to which a person can be exposed to 55V. Portable electrical appliances shall be earthed or double insulated and shall be inspected at least weekly. The Permit to Work System controls the use of portable electrical equipment.



All electrical tools must be individually identified and registered. This register should include details of: o

The type of tool,

o

The age of the tool

o

The date and results of the last detailed examination and maintenance

o

Any remedial action taken at that date

o

The date of the next required detailed examination.

This register must be kept up to date and used to record the maintenance and examination history of all electrical tools. All tools must be inspected before use every day that they are used. Users must be trained to carry out these inspections and be aware of the pass/fail criteria and means of rectifying the defects.

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All portable tools must undergo regular appliance testing. For 110V equipment, in a construction environment, the recommended interval is every three months. For 240V tools, the recommended interval is every month. All electrical installations shall conform to the relevant safety and design standards, and all machinery and equipment shall be effectively earthed. In Hazardous areas all electrical apparatus shall be intrinsically safe or explosion proof. To ensure the safety of personnel working on or in the vicinity of electrical equipment, all such electrical equipment shall be electrically isolated prior to the work being carried out, and de-isolated when the work is completed.

6.5.7.

Machinery Hazards

Table 7-26 Occupational Health Hazard Inventory – Physical Agents – Machinery Hazards

Hazard Title Location of hazard

Machinery Hazards For any activity involving close proximity to a potential machinery hazard, including e.g. rotating machinery, abrasive wheels, hydraulic systems, or portable power operated tools

Health Effects of Hazard See below Relevant Corporate Standards Risk Control Recommendations

See below

Activities / Tasks

Using Electrical Power Tools, Rotating Machinery, Abrasive Wheels, Hydraulic Jacks, Pneumatic Tools

Personnel Involved

Various

All machinery, which has moving parts, shall be considered as hazardous.

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A person may be in danger of being injured by coming into contact with machinery, by being trapped between the machinery and any material or fixed structure, by becoming entangled with moving parts of the machinery, by being struck by parts of the machinery or any material ejected from it. For any activity involving close proximity to a potential machinery hazard, including e.g. rotating machinery, abrasive wheels, hydraulic systems, or portable power operated tools, a risk assessment shall be carried out and a specific procedure should be prepared. Rotating Machinery Machine Guards Every dangerous part of all machinery shall be securely guarded, as follows:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Guards shall automatically prevent the machine operator coming into contact with a moving dangerous part of a machine.



All guards, whether fixed or automatic, shall be constantly maintained and kept in position while the machinery is in service or on standby. All guards shall be of sound design and of adequate strength, sufficient to withstand the stresses of the process and environmental conditions.



Guards shall not only provide protection but be so constructed and in such condition that they do not create any hazard themselves.



Guards shall be systematically maintained by competent persons and defects shall be repaired immediately.



Fixed guards shall be checked to ensure that they are securely fastened in place that no access is possible from any point into the trapping area, and no

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secondary trap has been formed between the guard itself and any moving part of the machine. 

Adjustable guards shall be checked daily to ensure that the adjustable element of the guard remains firmly in place once positioned.

Abrasive Wheels All persons handling, or using, grinding machines or abrasive wheels shall be familiar with the hazards involved. Sufficient heat may be generated by the operation in the form of sparks, or by friction, to ignite a flammable mixture; heavy hydrocarbons can also be vaporised by the heat of grinding. A hot work permit shall be obtained before using grinders, or abrasive cutters, in hazardous areas, or on equipment, which is not completely free of oil residue. The permit must state the conditions for carrying out the operation safely. All persons handling, or using, this equipment, shall ensure that: 

Abrasive wheels are maintained properly and only by persons trained in accordance with the schedule to the regulations.



Every abrasive wheel, in excess of 55 mm diameter, shall be marked with the maximum permissible speed. Maximum speeds of small wheels shall be stated on a notice attached to the machine.



The maximum permissible peripheral speed of an abrasive wheel shall never be exceeded.



The spindle shall not be operated at a speed in excess of the maximum permissible speed of the wheel.



The maximum working speed of spindles on grinding machines shall be marked on the spindle.



A guard shall be provided to enclose the wheel to the greatest possible extent, with the opening as small as possible consistent with the nature of the work.



Do not use grinding machines and abrasive wheels unless you are competent to do so.

Hydraulic Jacks The following precautions are to be observed when using hydraulic jacks to raise equipment: 

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Jacks are to be inspected before use to ensure that they are in a sound condition and that the oil in the reservoir reaches the minimum recommended level.

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

Before a jack is operated, care is to be taken to ensure that it has an adequate lifting capability for the work for which it is to be used and that its foundation is level and of adequate strength.



Jacks are to be applied only to the recommended or safe jacking points on equipment.



Equipment under which personnel are required to work are to be properly supported with chocks, wedges or by other safe means, never by jacks alone.



Jack-operating handles are to be removed, if possible, when not required to be in position for raising or lowering the jack.

Electrical Power Tools A permit to work is required before any work is carried out in a hazardous area using electrically operated tools. The only electrical equipment, which can safely be used in hazardous areas, is equipment, which has been approved by the appropriate authority. Portable power tools shall not be used if any defect is suspected or any damage apparent. Care shall be taken to avoid damage to flexible cables and connectors. Kinking and the tying of knots in cables can cause serious damage, which may not be apparent on the outside. Crushing and damage to the outer sheath shall be treated as damage necessitating repair. Portable electrically powered tools shall not be used in potentially hazardous or explosive environments. In addition, extreme care shall be taken in working areas containing oil, water, caustic, corrosive or conductive fluids, particularly with regard to routing of power leads. Where applicable, protective guards shall be securely fitted, and correctly adjusted. In order to minimise the effects of electric shock, the power requirements for portable equipment, e.g. Hand lamps, should be a maximum of 25 volts. Electrical power tools shall be double insulated or properly earthed. All plugs, joints, extension leads etc. shall be checked and be in good condition before using the equipment. Electric cables are not to be used for hoisting or lowering the equipment. The cable is to be routed to avoid any hazard that may cause damage to the cable. Should any fault occur in the equipment it is to be replaced immediately and not used again until properly repaired. Portable equipment shall be connected to an electrical supply only through the correct connectors and preferably via a residual current device. Temporary or locally made connectors shall not be used. Portable equipment shall be suitable for the hazards in the area where it is to be used. In use or storage, the connectors to any part of portable equipment shall not be subjected to undue strain. Portable electrical equipment shall not be left unattended or stowed in hazardous or dangerous areas. Portable equipment such as torches, test lamps, inspection lamps, etc. shall be issued against a signature and the user is responsible for it until its return within a specified period when its condition shall be checked.

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Pneumatic Tools Operators shall ensure that the air pressure is properly regulated and is no higher than necessary to undertake the work satisfactorily. Only hoses and couplings of the recommended size and in good condition shall be used. Caution: Under no circumstances shall compressed air be directed at any part of a person’s body. The air supply shall be disconnected from pneumatic tools before changing attachments or carrying out any adjustment or dismantling. The air hose to the equipment shall be safely routed to prevent damage due to heat, chemical or machinery means. Tools shall not be modified or the labels and inscriptions defaced or removed. Pneumatic drills are designed for use with drilling bits, which can be held by chuck or collet adaptors. These drills shall not be used for any other purpose without consulting the manufacturer. Drill bits shall not be larger than the rated capacity of the chuck or collet. Similarly, drill bits used with collets shall be designed for one specific size or range of collet. The drill bit shall be inserted as far as possible into the chuck or collet and clamped securely and centrally (with the air supply isolated). Chuck keys shall always be removed after use. The work piece shall be sufficiently secure to accept the drilling operation without moving or turning, particularly when sharp edged sheet material is being worked on. Care shall be taken to avoid jamming (seizing) of the drill. Thrust shall be applied in the direction of drilling particularly with angle drills. If a side handle or additional grip handle is used, it shall be securely fixed. Seizure or jamming of the drill bit causes a reaction torque, which may be dangerous with hand held drills. Lubrication and/or a reduction in feed pressure should reduce the likelihood of the drill bit jamming.

6.5.8. Dust Construction activities such as abrasive blasting of structures, excavation, earth moving and digging, masonry, concrete work, demolition, pressurized air blowing, jack hammering, removing rust or paint, sanding and scaling, hauling, pouring, mixing, or dumping silica-containing materials generates high levels of respirable dust which often contains a high crystalline silica content. Furthermore the project location is in a sandy area that will likely expose employees to high levels of ambient dust and respirable particles. Breathing in this dust can lead to the development of respiratory ill health, in particular scarring of the lung tissue (silicosis) which can result in serious breathing difficulties, depending on the extent of exposure. Chronic obstructive pulmonary disease including airways diseases such as asthma, chronic bronchitis, and emphysema is characterized by airways dysfunction and is often associated with occupational exposure to airborne respirable particles.

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From an occupational health perspective, clay, sand, brick dust and ash are all respiratory sensitisers. They usually contain silica or silica dust, and are known as Respirable Crystalline Silica (RCS). Control of Substances Hazardous to Health Regulations 2002 (COSHH) has been amended in 2004 to include the control of the exposure to RCS and to further protect workers’ health. Respiratory sensitisers are substances which when breathed in can trigger an irreversible allergic reaction in the respiratory system. Once this sensitisation reaction has taken place, further exposure to the substance, even to the tiniest trace, will produce symptoms. Sensitisation does not usually take place right away. It generally happens after several months or even years of breathing in the sensitiser. In addition to being able to trigger allergic response, occupational exposure to dust arising from sand or from work-related respiratory symptoms, can typically results in chest tightness/wheeze, nasal and eye irritation.

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Table 7-27 Occupational Health Hazard Inventory – Physical Agents – Dust

Hazard Title Location of hazard

Dust Work areas associated with grinding, cement handling and outdoor areas exposed to sand dust

Relevant Corporate Standards Respiratory tract irritation possibly leading to silicosis or other chronic Health Effects of Hazard pulmonary impairment. Dust can also irritate eyes and cement can also irritate the skin. Use of guards for cutting and grinding, and wetting where applicable. Use of extract ventilation where available. Use of suitable PPE e.g. dust mask or face mask

Risk Control recommendations

Wearing of suitable PPE when handling or working with cement and other dusty materials. Use of handling operations to minimise dust generation, including good housekeeping For sand dust – traffic management plans to minimise dust generation in areas where people maybe working, monitoring of dust conditions and damping down of dusty areas, wearing of PPE where dust levels area problem.

Activities / Tasks

Cement working, cutting and grinding, working outdoors in dusty locations, blasting

Personnel Involved

The particular groups at risk would be those involved in grinding operations, those mixing or handling cements, and personnel working near vehicles etc where sand dust may be generated

The major airborne particles identified in the scope of this project are: Cement Dust Cement dust is a particularly alkaline and irritant dust, and might therefore be considered to pose a greater risk of respiratory tract damage than many other poorly soluble dusts (generically often referred to as “low toxicity dusts”). International data describes evidence for an increased risk of chronic bronchitis and impairment of pulmonary function in cement dust exposed workers, but there is a lack of data on dose-response relationships. Some studies have been published suggesting that exposure to cement dust may be a cause of laryngeal and pharyngeal cancer and other evidences reports that repeated exposure to cement has produced chronic bronchitis and impaired pulmonary function.

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Furthermore, Hexavalent chromium (Cr (VI)) can be present in cement raw materials, Hexavalent chromium being a highly toxic form of chromium. Sand Inhaling Respirable Crystalline Silica (RCS) can lead to silicosis. Silicosis is a serious and irreversible lung disease that causes permanent disablement and early death, and it is made worse by smoking. In order to minimize the amount of RCS and to minimize nuisance to construction workers, the following recommendations could be applied: 

Restrict vehicle speeds



Damp down surface of main critical areas generating high levels of airborne dust



Avoid breathing in dust;



Do the job in the correct way and minimise dust clouds;



Always use the dust suppression and extraction equipment properly;



Keep all equipment clean and working properly;



Keep protective equipment clean, and wear it properly.

Occupational exposure to respirable crystalline silica is a serious but preventable health hazard. As an indication, prevention and elimination of silicosis and silica-related disease in the United States are priorities of the National Institute for Occupational Safety and Health (NIOSH), the Occupational Safety and Health Administration (OSHA).

6.6.

Chemical Health Hazards

6.6.1. Accidental Release of Chlorine Gas Accidental chlorine gas release impacts generally associated with Caustic / Chlorine industrial facilities are unlikely to occur during the operation of the plant based on the proposed preventive and control measures. The common causes of chlorine gas release at similar facilities are listed below. These causes are ranked in the order of severity of the leak and the hazard posed by its occurrence. 1. Fire; 2. Flexible connection failure; 3. Fusible plug corrosion;

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4. Accidents caused by carelessness and ignorance; 5. Valve packing failure; 6. Gasket failure; 7. Piping failure; 8. Equipment failure; 9. Physical damage of containers in collision accidents; 10. Container failure; and 11. Chlorine pressure gauge failure. Chorine Gas Health Effects: The USEPA has determined that chlorine is not a persistent pollutant, in that it photolyzes rapidly to hydrochloric acid (HCl), a much less toxic substance, following the release. Chlorine, as a powerful oxidizer, attacks the lungs, causing inflammation (pneumonitis) and fluid accumulation (pulmonary edema), and is intensely irritating to the eyes. Prolonged and/or acute exposure may be fatal. Table 6 -28 below summarizes typical symptoms of exposure to various concentrations of chlorine. Table 6-28:

Summary of Chlorine Health Effects

Concentration (ppm in air)

Health Effects

1-3 ppm

Mild mucous membrane irritation

5-15 ppm

Upper respiratory tract irritation

30 ppm

Immediate chest pain, vomiting, shortness of breath (dsypnea) and cough

40-60 ppm

Inflammation of lung tissues (toxic pneumonitis) and fluid accumulation (pulmonary edema)

430 ppm

Death within 30 minutes

1,000 ppm

Death within a few minutes

Chlorine Exposure Limits The Emergency Response Planning Guideline Level 2 (ERPG-2) value for chlorine gas is 3 ppm, which is set as end point concentrations for chlorine gas plume during emergency response. ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual’s ability to take protective action.

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The American Industrial Hygiene Association (AIHA) publishes ERPG levels for various chemicals (http://www.aiha.org/Committees/documents/erpglevels.pdf.). If an EPRG-2 value has been published, the Emergency Response Guideline uses this number for setting the Protective Action Distance (PAD). If an ERPG-2 value has not been established, the PAD is set at 0.01 x Lethal Concentration (LC) 50. The other useful exposure limits for chlorine are presented below in Table XXX) Table 6-29:

Other Useful Exposure Limits for Chlorine

Standard Setting Body

National Institute of Occupational Safety and Health (NIOSH)

Description

0.5

Recommended Exposure Limit (REL)

American Conference of Governmental Industrial Hygienist (ACGIH)

0.5

Threshold Limit Value (TLV) – Time Weighted Average (TWA)

UK Health and Safety Executive (HSE)

0.5

Long-term exposure limit (8 hour), OEL

USEPA

0.5

Environmental air limit

Occupational Safety and Health Administration (OSHA)

1.0

Permissible Exposure Limit (PEL)

NIOSH

1.0

Short Term Exposure Limit (STEL)

ACGIH

1.0

STEL

UK HSE

1.0

STEL, OEL

NIOSH

10

Immediately Dangerous to Life or Health (IDLH)

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Permissible Exposure, (ppm)

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6.6.2. Lubricants and Used Oils Table 7-30 Occupational Health Hazard Inventory – Chemical Agents – Lubricants and Used Oils

Hazard Title Location of hazard

Lubricants and Used Oils Widespread use – mechanical equipment. Use of oils may lead to irritation and contact dermatitis.

Health Effects of Hazard Long-term contact with used oils (which contain polycyclic aromatic hydrocarbons) may result in increased risk of skin cancer. Relevant Corporate Standards Use Impervious gloves Risk Control Status

Inspect quality of current gloves Implement Skin Health Programme or awareness campaign lubrication activities

Activities / Tasks

Mechanical maintenance activities (general) Instrument maintenance activities Mechanical Maintenance Technicians

Personnel Involved

Electrical Technicians Instrument Technicians

6.6.3. Maintenance Chemicals Substances in the category of maintenance chemicals, covers substances as diverse as: adhesives, sealants, ‘WD40’ type sprays and degreasing agents. These chemicals are typically packaged in small cans, tubes or aerosol sprays. They are only used in small quantities as required by the job. Table 7-31 – Occupational Health Hazard Inventory – Chemical Agents – Maintenance Chemicals

Hazard Title Location of hazard

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Maintenance and Inspection Chemicals Wide-spread use – mechanical and electrical equipment.

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Hazard Title

Maintenance and Inspection Chemicals

Range of toxicity (normally low hazard to irritant/harmful range) – Health Effects of Hazard depending upon the substance used. In actuality, toxic effects are normally limited by small quantities used and the short duration of use. Relevant Corporate Standards Maintenance chemicals cover such substances as release sprays, silicone sealants, corrosion protection sprays and greases, degreasing agents and adhesives. Risk Control Status The use of these chemicals is typically of short duration and low quantity. Personnel are required to wear appropriate PPE during use – as directed by manufacturers’ data. Mechanical Maintenance Activities. Activities / Tasks

Electrical Maintenance Activities. Instrument Maintenance Activities. Mechanical Maintenance Technicians.

Personnel Involved

Electrical Technicians. Instrument Technicians.

6.6.4. Welding Fumes Table 7-32 Occupational Health Hazard Inventory – Chemical Agents – Welding Fume

Hazard Title Location of hazard

Welding Fume During welding operations

Health Effects of Hazard Welding fumes are irritating by inhalation. Long-term exposure to welding fumes containing nickel and chromium may give rise to an enhanced risk of personnel developing cancers of the respiratory tract. Welding fumes can have acute effects on the respiratory system. For example, welding on galvanized steel can cause a condition known as ‘Fume Fever’, which is caused by the inhalation of cadmium and zinc particles. A welding process generates a tremendous amount of heat. A welder may be exposed to a heat stress situation as a result of the process and it is essential that a protocol be developed to address the potential for worker distress.

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Hazard Title

Welding Fume The welding area should always be equipped with a fire blanket and a wellstocked first aid kit.

Relevant Corporate Standards Risk Control Recommendations

See below Welding activities.

Activities / Tasks Metal fabrication/reparation activities Personnel Involved

Worker groups exposed to welding and solder fumes will be predominantly welders and electricians respectively, both groups being exposed as part of their routine work. Mechanical Maintenance Technicians.

The potential hazards from solder fumes depend on the flux material (typically tungsten or silver). Silver solder may contain cadmium, a heavy metal which can cause rapid fatality (within 20 minutes), zinc fumes can cause metal fume fever, a temporary condition like flu, but which can have severe effects from high enough exposure. Long-term exposure can result in siderosis (CoP). Coatings and insulation materials may result in exposure to other harmful chemical agents (e.g. carbon monoxide from epoxy-coatings). Arc welding produces fumes of metallic oxides, amorphous silica, silicates and fluorides. Polyurethane coatings on the welding materials may produce hydro-cyanide, formaldehydes and isocyanates (Carcinogenic). Chromium, nickel and lead may also be present. These heavy metals have long-term potentially fatal occupational health effects. Al Ghaith HSE Management should ensure arc welding follows best management practice:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Purchasing and selection of materials



Select solder flux without zinc, cadmium, and other toxic chemical agents



Select metals, coatings and fuels without adverse health effects



Ensure manufacturer’s instructions, MSDSs, and safety procedures are followed to minimise the hazards of welding gases



Use substitute materials such as water-based cleaners or high flash point solvents when preparing welding surfaces. Avoid chlorinated hydrocarbon degreasers. Cover the degreaser baths or containers to avoid solvent exposure

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

Avoid welding on surfaces that are still wet with a degreasing solvent



Avoid welding near degreasing baths



Avoid welding in confined spaces: adequate ventilation in a workplace will prevent the displacement or enrichment of oxygen and prevent the accumulation of flammable atmospheres



Use of PPE: Full-face masks, eye protection (for UV radiation and projectiles), aprons, gloves, etc.

To control or eliminate fire hazards, good housekeeping should be maintained in and around areas of welding, cutting or grinding. In the event that the work area is located in a confined space, ventilation and other safety systems should be provided to ensure the area is safe. Welding or burning will require assessment and approval via the Permit to Work System and Hot Work Permit. Fire prevention equipment should be located in the proximity of the welding and cutting operating area. An employee trained as a Fire Watch should be present and be ready to use the extinguisher if needed. Welding machinery and equipment should be maintained in accordance with manufacturer’s specifications and be inspected on a regular basis. Check the cables, ground clamp, electrode holder, gauges and switches to make sure that all are working properly before proceeding to weld. Workmen in charge of the oxygen or fuel-gas supply equipment, including generators, and oxygen or fuel-gas distribution piping systems shall be instructed and judged competent by their employers for this important work before being left in charge. Rules and instructions covering the operation and maintenance of oxygen or fuel-gas supply equipment including generators, and oxygen or fuel-gas distribution piping systems shall be readily available.

6.6.5. Paints and Thinners Table 7-33 Occupational Health Hazard Inventory – Chemical Agents – Paints and Thinners

Hazard Title

Paints and Thinners

Location of hazard

Various – application where required.

Health Effects of Hazard

Irritant and narcotic (may cause drowsiness, lassitude etc. during the inhalation of high concentrations). Thinners may be absorbed through the skin. Long-term use has been implicated in increased risk of damage to the nervous system.

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Uncontrolled use of polyurethane and epoxy-based paints may result in lung and skin sensitisation respectively. Relevant Corporate Standards Polyurethane / isocyanate paints Some spray-painting of polyurethanes Epoxies Substitution with a safer product Risk Control Status

Work prohibited in confined spaces, permitted only in well-ventilated workplaces and upwind from source. All paint handling will be carried out outdoors to ensure good ventilation. PPE: Use of a suitable respirator where TLVs or PELs dictate, gloves and eye protection to avoid skin contact Training and awareness for employees to minimise the exposure and recognise signs of intoxication. Induction in first aid and medical emergency procedures

Activities / Tasks

Painting activities

Personnel Involved

Painters and also nearby employees due to the probable diffusion of vapours. Exposed worker groups include those engaged in surface preparation prior to welding, painters and those using and handling sealants and adhesives.

Paints, primers and thinners can contain organic solvents, epoxy resins, isocyantes and potentially Hexavalent chromium compounds (primers for anti-corrosive purposes). Solvents may be used as degreasers and be present in paints, adhesives and sealants. Exposure to other worker groups would be insignificant in comparison unless working in confined or poorly ventilated spaces with the identified groups. Hexavalent chromium (zinc chromate, strontium chromate etc found in anti-corrosion paints and pigments) can induce occupational health effects such as carcinogenic effects or chrome ulcers. Epoxy resins found in paints sealants and coatings can cause skin and respiratory sensitisation and can also cause dermatitis and asthma. Table 7-34 Health Effects of main Chemicals found in Paints and Thinners

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Chemical group

Organic solvents

Found in

Paints, thinners, degreasing agent

Health Effects Skin, eye and respiratory tract irritant, causes dermatitis and asthma. Exposure to extremely high concentration can result in fatality Contributes to negative ozone depletion

Isocyanates

Paint additive

Respiratory sensitiser, carcinogenic

Aromatic amines (benzene, toluene etc)

Paint additive

Carcinogenic (bladder and kidney)

Lead and lead compounds

Paints ( no longer available) but might be in use on existing equipment

Neurological damage and death

6.6.6. Carbon Monoxide Carbon Monoxide (CO) is a colourless, odourless gas, which bonds strongly to haemoglobin in the blood, preventing the body from absorbing and transporting oxygen effectively. The effects of carbon monoxide exposure are related to the level of CO that has accumulated in the blood. Table 7 -35 shows the physiological effects of exposure to increasing concentrations of CO. Carbon monoxide is produced as a result of incomplete combustion of carbon containing materials and can be produced during welding operations with insufficient ventilation. CO is also produced as an exhaust product of internal combustion engines. As CO is a light gas, it will not tend to accumulate in high concentrations in open, well ventilated areas, but conversely may accumulate in poorly ventilated confined spaces such as welding booths and inside vessels. Welding booths should be adequately ventilated.

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Table 7-35 Health Effects of Carbon Monoxide

CO Concentration (ppm)

Exposure Time

50

8 hours

25

8 hours

Observed Health Effects Maximum occupational exposure allowed by OSHA as a permissible exposure. Maximum occupational exposure allowed by ACGIH as a threshold limit value (source ACGIH

200

2-3 hours Mild headache, fatigue, nausea and dizziness

400

1-2 hours

800

45 min.

Dizziness, nausea and convulsions. Unconscious within 2 hours. Death within 2-3 hours

1600

20 min.

Headache, dizziness and nausea. Death within 1 hour

Serious headache – other symptoms intensify. Life threatening after 3 hours

The local exhaust ventilation must be maintained and inspected as per the legal requirements. Users should be trained in its positioning and pre-use checks to ensure that it has no obvious defects. In no circumstances should personnel consider enriching the atmosphere inside a confined space with additional oxygen to counter the effects of CO. This presents significant hazards itself, specifically a greatly increase fire and explosion risk.

6.7.

Biological Health Hazards Biological hazards include viruses, bacteria, fungi, protozoa, insects, or other living organisms that can cause disease in humans. Biological agents are classified into the following hazard banding groups (CoPV3-04):

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Group 1 – unlikely to cause human disease.



Group 2 – can cause human disease and may be a hazard to employees; it is unlikely to spread to the community and there is usually effective prophylaxis or treatment available.



Group 3 – can cause severe human disease and may be a serious hazard to employees; it may spread to the community, but there is usually effective prophylaxis or treatment available.



Group 4 – causes severe human disease and is a serious hazard to employees; it is likely to spread to the community and there is usually no effective prophylaxis or treatment available

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6.7.1. Bioaerosols Table 7-36 Occupational Health Hazard Inventory – Biological Agents – Bioaerosols

Hazard Title Location of hazard

Bioaerosols Air conditioning systems at the sanitaries

Bioaerosols Bacteria and viruses are the most likely agents to affect the workforce, particularly if suspended in liquid droplets and spread though Health Effects of Hazard close body contact or the air conditioning systems at the sanitaries and or washing facilities. Agents include influenza, tuberculosis and Hepatitis A. Relevant Corporate Standards Risk Control Recommendations

See below

Activities / Tasks Personnel Involved

Various / potentially all.

Other bioaerosols such as fungi (where fungi spores or mycotoxins blown into the air during extensive renovation demolishing works) and antigens are unlikely to create a significant risk to occupational health. Control measures should include:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Moisture control through dehumidification, ventilation and increased temperature on the building surfaces to prevent condensation



Maintenance of air conditioning systems including drainage pans, coils, cooling towers, ductwork and humidifiers



Filter checking and replacement to avoid fungal spores and other biological particles



Keeping drainage pans and the rest of the system clear of sediments which may provide nutrients or harbourage



Ensuring water treatment programmes disinfect and maintain the system



Design of sanitary hot water provisions to showers etc to minimise the incidence of dead legs



Maintenance of hot water systems at 55ºC to prevent the growth of legionella



Monitoring of circulating water systems in air conditioning and sanitary systems to detect the presence of legionella and to monitor the level of biocides present

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

Promotion of health and hygiene issues and education to the workforce

6.7.2. Legionella Table 7-37 Occupational Health Hazard Inventory – Biological Agents – Legionella and Legionnaire’s Disease and Sick Building Syndrome

Hazard Title Location of hazard

Legionella and Legionnaire’s Disease and Sick Building Syndrome Freshwater pipe-work, heating and humidification systems.

Growth of legionella pneumophila within susceptible freshwater systems and their subsequent introduction into the workplace can result in a serious Health Effects of Hazard respiratory infection (Legionnaire’s disease). This condition has been known to be fatal – especially in elderly or those with compromised immune systems. Relevant Corporate Standards Risk Control Recommendations

Identify any hazardous water systems.

Activities / Tasks

Exposure to water systems containing legionella pneumophila.

Personnel Involved

Various / potentially all.

Legionella and Legionnaires’ Disease: Legionella is a waterborne bacterial agent, which may colonise man-made recirculating water systems such as air conditioning systems and dead legs in sanitary hot water systems at worker camps. It proliferates in water at 20-45 °C. Legionellosis has a fatality rate of approximately 12%.

6.7.3. Sanitation Sanitation generally refers to the provision of facilities and services for the safe disposal of human urine and faeces. Inadequate sanitation is a major cause of disease world-wide and improving sanitation is known to have a significant beneficial impact on health both in households and across communities (WHO 1993, WHO 1999, ADNOC 2000). The word ‘sanitation’ also refers to the maintenance of hygienic conditions, through services such as garbage collection and wastewater disposal.

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Table 7-38 Occupational Health Hazard Inventory – Biological Agents –Infectious Diseases

Hazard Title Location of hazard

Infectious Diseases Personnel Hygiene Facilities and Toilets

Health Effects of Hazard See below Relevant Corporate Standards Risk Control Recommendations

See below

Activities / Tasks

Personnel hygiene

Personnel Involved

Various / Potentially all.

Personnel hygiene facilities such as wash basins with a supply of soap, hot and cold water, hygienic means for drying hands, lavatories and changing facilities must be available to ensure that an appropriate degree of personal hygiene can be maintained and to avoid contaminating or spreading contamination (OSHA 1998, ADNOC May 2000). Toilets/lavatories must be located such that they do not open directly into any food preparation, cooking or eating area. Storage lockers must be provided in changing rooms. Control of infectious diseases in the workplace should be performed by: 

Educating personnel about the principles of infection transmission and stressing individual responsibility for infection control.



Collaborating with medical authorities in monitoring and investigating potentially harmful infectious exposures and outbreaks amongst personnel.



Providing care to personnel for work-related illnesses or exposures.



Identifying work-related infection risks and instituting appropriate preventive measures (CDCP, 1998).

Standard precautions must also be instituted for other infectious diseases of significance in the workplace (HMSO, 1981). These include, but are not limited to:

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Respiratory diseases including tuberculosis, influenza, pertussis, pneumonia and the common colds.



Viral disease such as measles, mumps, rubella, chickenpox and epidemic conjunctivitis.

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

Skin disease such as herpes simplex, impetigo, cellulites, pediculosis, and scabies.

6.7.4. Ergonomic Health Hazards Ergonomic hazards cause various health effects through repeated or single trauma. These may be present in the work environment (e.g. uncomfortable furniture, inadequate lighting), in the equipment/tool used (e.g. vibration from mechanical tools), or in a specific activity (e.g. manual handling, awkward positions, heavy load handling, prolonged typing etc). Manual handling involves lifting, lowering, carrying, pushing, pulling, handling Hot / Cold loads and handling rough loads. These can result in back injury, hernia, etc. and other health ergonomic related health effects (CoPV3-06). Repetitive movements such as those involved in keyboard work, repeated screwdriver use, hammer and chisel use, and bricklaying can result in work related upper limb disorders. Posture is also important in ergonomic hazards such as prolonged seated work, work above head height and work at floor level, as these can also result in work related upper limb disorders, stress, pain and general discomfort.

6.7.5. Confined Space / Trenches Table 7-39 Occupational Health Hazard Inventory – Ergonomic Factors – Confined Space / Trenches

Hazard Title Location of hazard

Confined Space / Trenches Work in: tanks, pits, unventilated rooms, excavations, vessels

Health Effects of Hazard Asphyxiation, explosion, fumes poisoning, claustrophobia Relevant Corporate Standards

Risk Control recommendations

Design and definition of workplace and confined spaces, ensuring adequate ventilation/lighting and access/ egress, avoiding other activities or ensuring isolations so person in confined space not put at extra risk, electrical safety for power tools. emission monitoring Recommendation to carry out an awareness raising programme.

Activities / Tasks

Valve removal and maintenance. Mechanical Maintenance Activities. Instrumentation Maintenance Activities. Electrical Maintenance Activities.

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Grit-blasting activities. Production Operators. Mechanical Maintenance Technicians. Welding Operations. Personnel Involved Electrical Technicians. Instrument Technicians. Service Company Crew.

While the principles of confined space entry are generally universal, local regulatory requirements may impose specific additional responsibilities or may specify standards that differ from those usually stated elsewhere. Many incidents occur because victims do not fully understand the threat of airborne hazards that they cannot see, smell, or feel. Additional incidents occur when untrained persons enter unknown atmospheres to rescue fallen co-workers. Common causes of confined space related incidents are: 1. Unsafe Acts and Omissions a. Failure to test the atmosphere in a confined space before entry. b. Failure to continuously monitor the atmosphere in a permit-required confined space. c.

Failure to lock out hazardous fluids, mechanical equipment, and electrical power to equipment inside the confined space.

d. Failure to follow approved entry procedures. e. Failure to pre-plan rescue and retrieval efforts. f.

Failure to use adequate respirators.

2. Unsafe Conditions a. Lack of training. b. Fall hazards. c.

Oxygen deficient atmosphere.

d. Oxygen enriched atmosphere. e. Poor or improper lighting

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f.

Flammable atmosphere.

g. Lack of a communication system when entrants are out of sight. h. Toxic or narcotic atmosphere. i.

Electrical shock hazards.

j.

Presence of an engulfing or drowning medium.

k.

Entrapping mechanisms.

l.

Grinding, crushing, or mixing mechanisms.

m. Contact with hazardous chemicals. Excavations can result in: head injuries from falling material, impact from moving machinery, rupture of high pressure hydraulic hoses, excessive noise, collapse of excavation walls and piles due to poorly secured soil, heavy rain and nearby poor soil drainage capacity, heavy traffic nearby, etc. No deep excavations are planned for the construction phase.

6.7.6. Manual Handling Table 7-40 Occupational Health Hazard Inventory – Ergonomic Factors – Manual handling

Hazard Title Location of hazard

Manual Handling Widespread – various locations

Manual handling can result in a range of different injuries and health Health Effects of Hazard effects, from muscle pulls, through soft tissue injuries to lower back trauma. In the case of lower back trauma, this can cause severe lower back pain and/or sciatica. Relevant Corporate Standards Control at source –Forklift use or trolley Risk Control Status Recommendation to carry out an awareness raising programme in lifting Valve removal and maintenance Mechanical Maintenance Activities Activities / Tasks

Instrumentation Maintenance Activities Electrical Maintenance Activities Grit-blasting activities

Personnel Involved

PEHSR Chlor-Alkali Plant Al Ghaith Industries

Production Operators

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Mechanical Maintenance Technicians Welding Operations Electrical Technicians Instrument Technicians Service Company Crew

Manual handling covers a wide range of activities including lifting, lowering, pushing, pulling or carrying. Manual handling incidents often cause musculoskeletal disorders (MSD’s), i.e. disorders relating to, or involving, the muscles and the skeleton (COPV306). These types of disorders are one of the largest contributors to work-related illness, e.g. muscular back pain, slipped disk, and fractured arm.

6.7.7. Work-related Upper Limb Disorders Table 7-41 Occupational Health Hazard Inventory – Ergonomic Factors – Work-related Upper Limb Disorders (WRULDs)

Hazard Title Location of hazard

Work-related Upper Limb Disorders (WRULDs) Widespread – various locations (possibly)

Health Effects of Hazard Work-related soft-tissue injuries of the hand, wrist, elbow and neck. Relevant Corporate Standards Risk Control Status

WRULD risk at the site will mostly come from repetitive movements and some awkward positions that may cause sprains and strains.

Activities / Tasks

Process Operation Activities (general).

Personnel Involved

All performing manual handling activities

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Many chronically disabling muscular skeletal disorders (like tendonitis, carpal tunnel syndrome and low-back pain) occur as a result of traumatic injury, repetitive forceful movements, and awkward postures or over exertion. Studying the ergonomics of a workers environment may help reduce the risk. Employees particularly at risk include: 

Masons, electricians, welders, structural metal installers and scaffolders for awkward working positions



Masons, carpenters, and others involved in repetitive motion and carrying heavy loads



Where feasible, equipment should be selected with ergonomic design considerations and ensure equipment has adjustable mechanisms (e.g. for handgrip, height, seat position, etc.)



Mechanical equipment should be used where possible, in order to avoid manual handling



Task risk analysis/assessment should include an element of manual handling risk assessment where appropriate.



Job allocation and rotation should be used to avoid prolonged work in awkward positions or repetitive heavy loads



Medical facilities will be available for workers who suffer symptoms of MSDs



Medical surveillance based on reported cases can be used to monitor the prevalence of MSDs amongst the workforce and as an indicator of potential problems

6.7.8. Slips and Trips Table 7-42 Occupational Health Hazard Inventory – Ergonomic Factors – Slips and Trips

Hazard Title Location of hazard

Slipping and Tripping Hazards All areas, wet floors or surfaces

Health Effects of Hazard Injury, broken bone Relevant Corporate Standards Risk Control Recommendations

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Floors, platforms, ramps, stairs and walkways available for use by workers shall be maintained in a state of good repair and kept free of slipping and tripping hazards.

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Activities / Tasks

All

Personnel Involved

Various

Slips and trips are the most common cause of major injuries at work. They occur in almost all workplaces, 95% of major slips result in broken bones. Most slips occur in wet or contaminated conditions. Most trips are due to poor housekeeping. Al Masaood need to assess the risks to identify the necessary preventative measures. These shall include (in no particular order):

PEHSR Chlor-Alkali Plant Al Ghaith Industries



Prevention of contamination.



Management of spillages and cleaning regimes.



Choice of suitable footwear.



Design of workplace and work activities.



Maintenance of plant and the work environment.



Specification of appropriate flooring.



Housekeeping.



Effective training and supervision.

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7.

PROJECT ALTERNATIVES

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8.

STATEMENT OF COMMITMENTS

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9.

SUMMARY OF FINDINGS This Preliminary Environment, Health and Safety Review for the Al Ghaith Industries Caustic / Chlorine Project covers the various environmental, health and safety aspects and related impacts due to this project. Al Ghaith Industries has used one of the best available technologies (BAT) for their Project and has taken reasonable measures in its design philosophy to tie-in to existing facilities and utilities thus helping to eliminate and mitigate potential impacts on the people, the environment, company assets and company reputation. The entire plant has been designed on the principle of Best Available Technology Not Entailing Excessive Cost (BATNEEC) and where residual impacts remained, BAT was applied. The selection of membrane cell technology itself for the production of caustic and chlorine at the plant is considered to be BAT. Reasons for selection of this technology are: 

Membrane cell technology does not use toxic chemicals such as mercury and asbestos; therefore, it is the most environmentally-friendly process in comparison to other popular technologies (Diaphragm cell and Mercury cell) for the production of chlorine and caustic; and



Membrane cell technology is the most energy-efficient option, and the power consumption is only 60 to 65 % when compared to other available technologies.

The following are other BAT options considered by Al Ghaith Industries. 

Installation of chlorine absorption unit designed to be able to absorb the full cellroom chlorine production in the event of process upset until the plant can be shut down;



Use of entire hydrogen gas as fuel in the hydrochloric acid (HCl) synthesis in order to conserve energy;



Hydrogen gas venting may be required at times of start-up, shutdown and process upsets from the plant through process safety relief valves to a safe location in order to maintain the safe operation of the plant. The vent system will include flame sensors, nitrogen and steam purging;



Installation of Vapor Absorption System in the chilled water unit to avoid use of ozone-depleting substances;



Installation of low NOx burners with the steam boiler and flaking unit to reduce NOx emissions; and



Recycling of water, wherever possible, utilizing Reverse Osmosis (RO) Unit.

There were no potential impacts found to be of extreme to high risk as per Zonescorp CoP EHS04.

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From the information gathered from the baseline studies, and after review of the potential impacts and proposed mitigation and monitoring requirements set forth in this PEHSR, it is believed that potential project impacts have been adequately identified and addressed through the effective use of mitigation and control measures, and/or monitoring requirements. The proposed expansion being located within ICAD-1 is also an advantage and helps lower environmental impact due to the use of existing infrastructure and resources and the synergies that can be optimally used at various stages of the project. The location for proposed plant was selected in ICAD-1 based on the following reasons. 

The existence of Musaffah Industrical City as a well-organized industrial city;



Availability of continuous power supply; and



No adequate caustic / chlorine production facilities in Abu Dhabi region in general to meet the growing demand for the HCl, caustic soda and sodium hypochlorite chemicals.

Taking into consideration the information documented in this PEHSR, it can be stated that the Al Ghaith Industries Caustic / Chlorine project can avoid environmental, health and safety concerns during its construction and operation phase by implementing the mitigation, control and monitoring measures provided.

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Appendix A -

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