Volume 1 - Main Report

PROPOSED 2-ETHYLHEXANOIC ACID II
PLANT IN EXISTING INTEGRATED

CHEMICAL SITE OF BASF PETRONAS
CHEMICALS GEBENG, KUANTAN, PAHANG
Environmental Impact Assessment

(EIA)
Volume 1: Main Report
July 2022
PROPOSED 2-ETHYLHEXANOIC ACID II PLANT IN EXISTING
INTEGRATED CHEMICAL SITE OF BASF PETRONAS CHEMICALS,
GEBENG, KUANTAN, PAHANG
Environmental Impact Assessment (EIA)
Project Code EJ 727

Issue No. 1.0
Issue Date July 2022
Prepared by JCE/ANI/ARU/ARZ/MUJ
Approved by TYC
Files H:\ERE Projects\EJ 727 2-Ethylhexanoic Acid

BASF\Reports\2. EIA
ENVIRONMENTAL PLEDGE FROM
PROJECT PROPONENT
DECLARATION FORM AND EIA TEAM
DECLARATION FROM EIA STUDY TEAM LEADER

I declare that the entire EIA is the product of my own work and the work of my team
members (i.e. other consultants who are also qualified person) who worked under
my supervision and all the facts stated in the report and the accompanying
information are to the best of my knowledge and belief true and correct and that I
have not withheld or distorted any material facts. I have briefed the Project
Proponent on the content of the Report and highlighted to him all the pollution
prevention and mitigating measures (P2M2) described in it, and in the
Environmental Management Plan (EMP), and in the LD-P2M2, and the Project
Proponent has agreed to implement them (P2M2).
Signature : Official Stamp:

Name : Tan Yen Chen
IC / Passport No. : 851207-04-5309
Designation : Team Leader
(CEP-CS0220)
Date : 4 July 2022
1
DECLARATION FROM EIA STUDY TEAM MEMBER
I declare the following:

i) I have conducted the study professionally using acceptable methodologies;
ii) The study findings are correct to the best of my knowledge; and have not
been altered in any manner;
iii) The mitigating measures proposed (whenever relevant) to the best of my
knowledge are reliable, practical and adequate to comply with the relevant
legal requirements; and
iv) I shall be accountable for any misleading information in any part of this
report.

Name : Prof. Dr. Jamal Hisham Hashim
IC / Passport No. : 571110-02-5903
Designation : EIA Consultant (CEP-CS0113)
Date : 4 July 2022

ii) The study findings are correct to the best of my knowledge; and have not
been altered in any manner;
report.

Name : Prof. Dr. Mohd Shahwahid Haji Othman
IC / Passport No. : 550417-10-6115
Designation : EIA Consultant (CEP-SS0345)
Date : 4 July 2022
2

ii) The study findings are correct to the best of my knowledge; and have not been
altered in any manner;
report.

Name : Tan Poh Aun
IC / Passport No. : 730410-10-5329
Designation : EIA Consultant (CEP-C0019)
Date : 4 July 2022

report.

Name : Deva Kumari
IC / Passport No. : 770918-07-5892
Date : 4 July 2022

3

report.

Name : Sharmila Devi Valaitham
IC / Passport No. : 860820-38-5824
Date : 4 July 2022

report.

Name : Wan Mujahid bin Wan Hamidon
IC / Passport No. : 890709-43-5173
Date : 4 July 2022

4

report.

Name : Adnan bin Yusop Ali
IC / Passport No. : 781116-10-5053
Designation : Subject Specialist (CEP-SS0038)
Date : 4 July 2022
5
List of EIA Consultants Involved in the EIA Study
Registration with DOE Proposed
No. Name Qualification Signature
Category Area/Field ID. No. Valid Date Study Area
A. EIA Study Team Leader
1. Tan Yen Chen B. Eng. (Hons) EIA 1. Air, Noise & CEP- 31 May 2024 Air Quality
Chemical Consultant Vibration and CS0220 Assessment
M. Eng. & Subject Water Quality
(Environmental Specialist Modelling
Engineering) 2. Qualitative &
Quantitative Risk
Assessments
3. Air, Noise &
Vibration and
Water Quality
Monitoring and
Baseline
Assessments
4. Industrial and
Chemical Process
B. EIA Study Team Member
1. Prof. Dr. Jamal B. A. (Biology and EIA 1. Qualitative Risk CEP- 31 May 2024 Health Impact
Hisham Environmental Consultant Assessment CS0113 Assessment
Hashim Studies) & Subject 2. Quantitative Risk
M.Sc. (Public Specialist Assessment
Health) 3. Health Impact
Ph. D. Assessment
(Environmental
Health)
2. Tan Poh Aun B. Sc. (Chemistry) EIA 1. Air Quality CEP- 31 May 2023 • Noise
M. Tech. Consultant Modelling C0019 Assessment
(Environmental 2. Noise and
Management) Vibration
Modelling
3. Water Quality
Modelling
3. Deva Kumari B. Eng. (Chemical) EIA 1. Recovery CEP- 31 May 2025 Waste
A/P Mohan Consultant Technology and C0226 Management
Dass Design
2. Solid Waste
Management
3. Handling and
Management of
Scheduled Waste
4. Sharmila Devi B. Sc. Zoology EIA 1. Water Quality CEP- 31 May 2025 Water Quality
Valaitham Consultant Monitoring C0090
5. Wan Mujahid B. Eng. (Chemical EIA 1. Air Quality CEP- 31 May 2024 Air Quality
bin Wan Engineering Consultant Monitoring and C0243
Hamidon M. Eng. Baseline
(Environmental Assessment
Engineering) 2. Air Quality
Modelling
3. Qualitative Risk
Assessment &
Quantitative Risk
Assessment
4. Water Quality
Modelling
6. Prof. Dr. Mohd B. Sc. (Forestry) Subject 1. Social Impact CEP- 31 May 2024 Socio-
Shahwahid Haji M. Sc. (Resource Specialist Assessment/ SS0345 Economic
Othman Management and Socio-economic Study
Policy) analysis and
M. A. (Economics) Economic
Ph. D. (Resource Valuation
Management and
Policy)
7. Adnan bin B. Eng. (Chemical Subject 1. Quantitative Risk CEP- 31 May 2023 Risk
Yusop Ali Engineering) Specialist Assessment SS0038 Assessment
List of EIA Assistant Consultants Involved in the EIA Study
Registration with DOE Proposed Study
No. Name Qualification Supervised by Signature
Category Area/Field ID. No. Area
1. Nur Idzumi Bt. B.Eng. (Civil) Assistant 1. Air Quality and CEP- Water Quality Sharmila Devi
Mohamed M.Civil.Eng. Consultant Odour AC0371 Valaitham
Hasnan (Environment) 2. Noise and
Vibration
3. Water Quality
4. Solid Waste
Management
2. Anisa Mohd B. Sc. Assistant 1. Noise and CEP- Noise Tan Poh Aun
Azhar (Environmental Consultant vibration AC0289
Health and Safety) 2. Solid and
Scheduled
Waste
Management
3. Amirul Rahman B.S. Civil Assistant - CEP- Air Quality Wan Mujahid
bin Zamri Engineering Consultant AC0292 bin Wan
Hamidon
List of EIA Trainees Involved in the EIA Study
Registration With DOE Proposed
No Name Qualification Supervised By Signature
Category Area/Field ID. No. Study Area
1. Joyce Wong B. Eng. (Chemical) - - - Waste Deva Kumari

Wui Mei Management
2. Arularasu B. Sc. (Marine - - - Water Quality Sharmila Devi

Muthaliar Biology) Assessment Valaitham
Tamotharan M. Sc.
(Biotechnology)
TOC TABLE OF CONTENTS
TABLE OF CONTENTS
Page
Table Of Contents i
List Of Appendices x
List Of Abbreviations x
List Of Figures xiii
List Of Tables xiv
List of Plates xx
List Of Charts xxi
Executive Summary ES-i
Ringkasan Eksekutif RE-i
SECTION 1 : INTRODUCTION 1-1

1.1 PROJECT TITLE 1-1
1.1.1 Project Background 1-1
1.1.2 Project Location 1-2
1.2 PROJECT PROPONENT AND QUALIFIED PERSONS 1-3
1.2.1 Project Proponent 1-3
1.2.2 EIA Consultant 1-4
1.3 LEGAL FRAMEWORK 1-4
1.4 CONFORMANCE WITH POLICIES AND DEVELOPMENT PLANS 1-4
1.4.1 Twelfth Malaysia Plan 1-4
1.4.2 Rancangan Fizikal Negara 4 1-5
1.4.3 Rancangan Struktur Negeri Pahang 2050 1-7
1.4.4 Rancangan Tempatan Daerah Kuantan 2035 (Penggantian) 1-7
1.4.5 East Coast Economic Region Master Plan 2.0 1-7
1.5 SCOPE OF EIA STUDY 1-9
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-i

SECTION 2 : TERMS OF REFERENCE 2-1
2.1 INTRODUCTION 2-1
2.2 ENDORSEMENT OF TERMS OF REFERENCE 2-1
SECTION 3 : STATEMENT OF NEED 3-1

3.1 NEED FOR THE PROJECT 3-1
3.1.1 Increasing Demand in 2-EHAcid 3-1
3.1.2 Stimulating Local Economy 3-2
SECTION 4 : PROJECT OPTIONS 4-1

4.2 NO PROJECT ALTERNATIVES 4-1
4.3 TECHNOLOGY ALTERNATIVES 4-1
4.3.1 Production Method 4-1
SECTION 5 : PROJECT DESCRIPTION 5-1

5.1 PROJECT CONCEPT 5-1
5.2 PROJECT COMPONENTS 5-4
5.3 PROCESS DESCRIPTION 5-6
5.3.1 Raw Materials, Modulator and Products 5-7
5.3.1.1 2-Ethylhexenal 5-7
5.3.1.2 Hydrogen 5-7
5.3.1.3 Oxygen 5-7
5.3.1.4 Potassium Hydroxide 5-7
5.3.1.5 2-Ethylhexanoic Acid 5-7
5.3.2 Main Production Processes 5-8
5.3.2.1 Selective Hydrogenation of EHexenal to EHexanal 5-8
5.3.2.2 Purification of EHexanal 5-8
5.3.2.3 Oxidation of EHexanal to EHAcid 5-9
5.3.2.4 EHAcid Purification 5-9
5.3.3 Off-Gas & Waste Disposal 5-10
5.3.4 Existing Wastewater Treatment Plant 5-11
5.3.5 Air Pollution Control Systems 5-12
5.3.5.1 Flare 5-12
ii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

5.3.5.2 Thermal Oxidizer 5-12
5.4 PLANT UTILITY 5-12
5.4.1 Electricity Consumption 5-12
5.4.2 Steam and Condensate Consumption 5-12
5.4.3 Water Consumption and Refrigeration 5-12
5.5 PRINCIPAL PROJECT ACTIVITIES 5-13
5.5.1 Pre-Construction Phase 5-13
5.5.2 Construction Phase 5-13
5.5.3 Operational Phase 5-14
SECTION 6 : EXISTING ENVIRONMENT 6-1

6.2 PHYSICAL ENVIRONMENT 6-1
6.2.1 Topography and Terrain 6-1
6.2.2 Geology and Soil 6-2
6.3 LAND USE AND SENSITIVE RECEPTORS 6-2
6.3.1 Land Use Within Project Site 6-2
6.3.2 Existing Land Use Within 5 km of the Project Site 6-3
6.3.3 Future Land Use Within 5 km of the Project Site 6-10
6.3.4 Proposed Future Developments 6-10
6.4 CLIMATE 6-10
6.4.2 Temperature 6-11
6.4.3 Rainfall 6-11
6.4.4 Relative Humidity 6-11
6.4.5 Surface Wind 6-11
6.5 HYDROLOGY AND DRAINAGE 6-11
6.5.1 River Catchment 6-11
6.5.2 Drainage System 6-11
6.5.3 Flood Prone Areas 6-12
6.5.3.1 Existing Flood Risk Mitigation and Action Plans 6-13
6.5.4 Beneficial Use 6-17
6.5.4.1 Water Infrastructure 6-17
6.5.4.2 Recreational Use and Fishing Activities 6-17
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA iii

6.5.4.3 Commercial Use 6-18
6.5.5 Existing River Conservation Programme 6-21
6.6 GROUNDWATER 6-22
6.7 ENVIRONMENTAL QUALITY 6-27
6.7.1 Air Quality 6-27
6.7.1.1 Monitoring Location and Parameters 6-28
6.7.1.2 Result and Discussion 6-29
6.7.2 Environmental Noise Quality 6-34
6.7.3 Water Quality 6-42
6.8 WASTE MANAGEMENT 6-68
6.8.1 Solid Waste 6-68
6.8.1.1 Existing Solid Waste Management 6-68
6.8.1.2 Existing Solid Waste Generation 6-69
6.8.2 Scheduled Waste 6-69
6.8.2.1 Existing Scheduled Waste Management 6-69
6.8.2.2 Existing Scheduled Waste Generation 6-71
6.9 EXISTING TRAFFIC CONDITION 6-72
6.10 SOCIO-ECONOMIC PROFILE 6-74
6.10.1 Demographic and Socio-economic Profile of Mukim Sg. Karang 6-75
6.10.1.1 Population and Ethnic Composition 6-75
6.10.1.2 Households and Living Quarters Distribution 6-76
6.10.1.3 Population and Age Group 6-76
6.10.1.4 Dependency Age Ratio 6-77
6.10.2 Zone of Influence (ZOI) 6-78
6.10.2.1 Residential Areas 6-78
6.10.2.2 Institutions and Public Amenities 6-78
6.10.3 Perception Survey Outcome 6-78
6.10.3.1 Demographic Profile 6-79
6.10.3.2 Employment Status and Occupation 6-79
iv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

6.10.3.3 Household Income 6-80
6.11 EXISTING PUBLIC HEALTH 6-81
6.11.1 Public Health Survey 6-81
6.11.1.1 Background of Respondents 6-81
6.11.1.2 Housing 6-82
6.11.1.3 Environmental Sanitation Status 6-83
6.11.2 Community Health Status 6-84
6.11.3 Morbidity Statistics 6-86
SECTION 7 : EVALUATION OF IMPACTS 7-1

7.2 EVALUATION METHODOLOGY 7-2
7.2.1 Receptor Sensitivity 7-2
7.2.2 Impact Significance 7-2
7.3 PRE-CONSTRUCTION PHASE 7-7
7.3.1 Project Planning and Site Investigation 7-7
7.4 CONSTRUCTION PHASE 7-7
7.4.1.1 Potential Impact 7-7
7.4.1.2 Assessment 7-7
7.4.2 Noise Pollution 7-8
7.4.4 Waste Management 7-17
7.4.4.1 Solid Waste 7-17
7.4.4.2 Scheduled Wastes 7-19
7.4.5 Socio-Economic Analysis 7-20
7.5 OPERATION PHASE 7-23
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA v

7.5.2 Greenhouse Gas Emission 7-48
7.5.4 Risk 7-54
7.5.4.1 Hazard Identification 7-55
7.5.4.2 Qualitative Risk Assessment 7-56
7.5.4.3 Frequency Analysis 7-68
7.5.4.4 Event Tree Analysis 7-70
7.5.4.5 Consequence Analysis 7-72
7.5.4.6 Risk Criteria 7-76
7.5.4.7 Risk Summation 7-76
7.5.4.8 Salient Findings 7-79
7.5.6.1 Solid Wastes 7-88
7.5.6.2 Scheduled Wastes 7-89
7.5.7 Socio-Economic Assessment 7-92
7.5.8 Health Impact Assessment 7-115
7.5.8.1 Issues Identification 7-116
7.5.8.2 Hazard Identification 7-116
7.5.8.3 Dose-Response Assessment 7-121
7.5.8.4 Exposure Assessment 7-121
7.5.8.5 Health Risk Characterization 7-125
vi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

7.5.8.6 Uncertainty Analysis 7-127
7.5.8.7 Assessment Summary 7-127
7.6 PROJECT ABANDONMENT 7-128
SECTION 8 : PROPOSED MITIGATION MEASURES 8-1

8.2 PRE-CONSTRUCTION PHASE 8-1
8.2.1 Project Planning and Site Investigation 8-1
8.3 CONSTRUCTION PHASE 8-1
8.3.2.1 Control Noise at Source 8-3
8.3.2.2 Controlling the Spread of Noise 8-5
8.3.4.2 Scheduled Waste 8-13
8.3.5 Socio-Economic Study 8-16
8.4 OPERATION PHASE 8-17
8.4.2 Greenhouse Gas Emission 8-18
8.4.4 Risk 8-22
8.4.6.2 Scheduled Waste 8-25
8.4.7 Socio-Economic Study 8-30
8.4.8 Health Impact Assessment 8-32
8.5 PROJECT ABANDONMENT 8-32
8.5.1 Project Abandonment Plan 8-32
8.5.1.1 Pre-Abandonment Activities 8-33
8.5.1.2 Abandonment Activities 8-34
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA vii

8.5.1.3 Post Abandonment Activities 8-34
SECTION 9 : ENVIRONMENTAL MANAGEMENT PLAN (EMP) 9-1

9.2 ENVIRONMENTAL MANAGEMENT OBJECTIVES 9-1
9.3 ORGANISATION STRUCTURE 9-2
9.3.1 Chain of Responsibilities 9-2
9.3.2 Department of Environment 9-2
9.3.3 Project Proponent 9-2
9.3.4 Environmental Consultant 9-2
9.3.5 Environmental Officer 9-3
9.3.6 Establishment of Environmental Performance Monitoring Committee
(EPMC) 9-3
9.3.7 Meeting and Reporting System 9-3
9.4 POLLUTION PREVENTION AND MITIGATION MEASURES (P2M2) 9-4
9.5 PROPOSED MONITORING PROGRAMME 9-4
9.5.1 Performance Monitoring 9-5
9.5.2 Compliance Monitoring 9-5
9.5.3 Impact Monitoring 9-5
9.5.3.1 Water Quality 9-5
9.5.3.2 Air Quality 9-6
9.5.3.3 Noise Level 9-6
9.6 ENVIRONMENTAL AUDITING 9-6
9.7 ENVIRONMENTAL MAINSTREAMING AND GUIDED SELF-
REGULATION 9-6
9.7.1 Environmental Policy 9-7
9.7.2 Environmental Budgeting 9-7
9.7.3 Environmental Monitoring Committee 9-7
9.7.4 Environmental Facility 9-8
9.7.5 Environmental Competency 9-8
9.7.6 Environmental Reporting and Communication 9-8
9.7.6.1 Internal Reporting 9-8
9.7.6.2 Environmental Performance Monitoring Document 9-8
9.7.6.3 Performance Monitoring Report 9-9
viii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

9.7.6.4 Environmental Transparency 9-9
9.7.6.5 Environmental Mainstreaming Tools Compliance Report 9-9
SECTION 10 : STUDY FINDINGS 10-1
REFERENCES
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ix

LIST OF APPENDICES
Appendix A Existing 2-EHAcid Plant DEIA Approval

Appendix A1 Appealed Noise Limits
Appendix B TOR Endorsement
Appendix B1 Written Comments from Technical Agencies and Appointed
Individuals
Appendix C Safety Data Sheets of Raw Materials, Modulator and Product
Appendix D DOF Pahang Response Letter
Appendix E Groundwater Monitoring Report (2014)
Appendix E1 Groundwater Monitoring Report (2020)
Appendix F Baseline Monitoring Report
Appendix G License for Solid Waste Disposal
Appendix H Quantitative Risk Assessment (QRA)
Appendix I Safety Data Sheet of Catalyst
Appendix J Emergency Response and Preparedness Plan
Appendix K Sample of Waste Management Plan
Appendix L Wastewater Treatment Plant Supervisory Manual
Appendix M CePSWAM Certification of Competent Person
Appendix N Company Health, Safety and Environmental Policy
LIST OF ABBREVIATIONS
2-EHAcid 2-Ethylhexanoic Acid

ALARP As Low As Reasonably Practicable
ASRs Air Sensitive Receptors
AT Averaging Time
BC Baseline Concentration
BDO Butanediol
BOD Biochemical Oxygen Demand
BH Borehole
BPC BASF PETRONAS Chemicals Sdn. Bhd.
CAPEX Capital Expenditure
CAQM Continuous Air Quality Monitoring
CePSWaM Certified Environmental Professional in Scheduled Waste
Management
CIMAH Control of Industrial Major Accident Hazards
COD Chemical Oxygen Demand
COVID-19 Coronavirus Disease 2019
CSM Conceptual Site Model
DEIA Detailed Environmental Impact Assessment
DID Department of Irrigation and Drainage
x Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

DIV Dutch Intervention Values
DO Dissolved Oxygen
DOE Department of Environment
DOF Department of Fisheries
DOSM Department of Statistics Malaysia
EB Environmental Budgeting
EC Exposure Air Concentration
ECER East Coast Economic Region
ECERDC East Coast Economic Region Development Council
ECRL East Coast Rail Line
ED Exposure Duration
EF Environment Facilities
EHexanal Ethylhexanal
EHol Ethylhexanol
EIA Environmental Impact Assessment
EMC Event Mean Concentration
EMP Environmental Management Plan
EMT Environmental Mainstreaming Tools
ENV BPC's Environmental Department
EO Environmental Officer
EPA Environmental Protection Agency
EPMC Environmental Performance Monitoring Committee
EPMD Environmental Performance Monitoring Document
ERCMC Environmental Regulatory Compliance Monitoring Committee
ERP Emergency Response Plan
ESI Environmental Scoping Information
FC Fundamental Components
FGD Focus Group Discussion
GDP Gross Domestic Product
GHG Greenhouse gases
GIE Gebeng Industrial Estate
GIPC Gebeng Integrated Petrochemical Complex
GLC Ground Level Concentrations
GSR Guided Self Regulation
GSSB Gading Senggara Sdn. Bhd.
HAZOP Hazard and Operability Study
HIA Health Impact Assessment
HP High Pressure
HQ Hazard Quotient
HRA Health Risk Assessment
ICS Integrated Chemical Site
ILP Institut Latihan Perindustrian
IPCC The Intergovernmental Panel on Climate Change
IUCN International Union for Conservation of Nature
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xi

JKM Jabatan Kebajikan Masyarakat
JPSPN Jabatan Pengurusan Sisa Pepejal Negara
KASA Environment and Water Minister
KPC Kuantan Port City
KPKT Kementerian Perumahan, Kesejahteraan Bandar dan Kerajaan
Tempatan
LOS Level of Service
LP Low Pressure
LPT Lebuhraya Pantai Timur
MAAQS Malaysia Ambient Air Quality Standard
MAIC Maximum Average Incremental Concentration
MAn Maleic Anhydride
MBK Majlis Bandaraya Kuantan
MKN Majlis Keselamatan Negara
MMD Malaysian Meteorological Department
MRL Malaysia Rail Link Sdn. Bhd.
MSL Mean Sea Level
NGOs Non-Governmental Organizations
NMVOC Non-Methane Volatile Organic Compound
NWQS National Water Quality Standards
OAAQC Ontario's Ambient Air Quality Criteria 2020
OGP Oil, Gas and Petrochemical
OPEX Operational Expenditure
P2M2 Pollution Prevention and Mitigation Measures
PDF Permanent Disposal Facility
PETRONAS Petroleum Corporation Petroliam Nasional Berhad
PKNP Pahang State Development Corporation
PMR Performance Monitoring Report
PPE Personal Protective Equipment
PRAB National Flood Forecasting and Warning Program
PRABN National Flood Forecasting and Warning Centre
PSV Pressure Safety Valve
PTK Pelan Tidakan Khas
PVB Polyvinyl Butyral
PVC Polyvinyl Chloride
QC Quality Control
QRA Quantitative Risk Assessment
RfC Reference Concentration
RTD Rancangan Tempatan Daerah
SDG Sustainable Development Goals
SDS Safety Data Sheet
SS Suspended Solid
SSL Malaysian Recommended Site Screening Levels for Contaminated
Land for Tapwater
xii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

SVOCs Semi-Volatile Organic Compounds
SWMP Scheduled Waste Management Plan
TIA Traffic Impact Assessment
TOR Terms of Reference
TOX Thermal Oxidizer
TPH Total Petroleum Hydrocarbons
TPJJ Jabor-Jerangau Landfill
TSS Total Suspended Solids
USEPA United States Environmental Protection Agency
VOCs Volatile Organic Compounds
WCS Worst Case Scenario
WCCS Worst Case Credible Scenario
WLP Water Leach Purification
WMP Waste Management Plan
WRI World Resources Institute
WWTP Wastewater Treatment Plant
ZOI Zone of Influence
LIST OF FIGURES
Figure 1-1 Project Location Plan 1-11

Figure 1-2 Overall Layout Plan 1-12
Figure 5-1 Project Layout Plan 5-18
Figure 6-1 Elevation of the Project Site 6-95
Figure 6-2 Geological and Soil Map of the Project Site 6-96
Figure 6-3 Existing Land Use Within 5km Radius of the Project Site 6-97
Figure 6-4 Future Land Use Within 5km Radius of the Project Site 6-98
Figure 6-5 Proposed Future Development in Kuantan 6-99
Figure 6-6 Climate Pattern at Kuantan Meteorological Station (1985 – 2020) 6-100
Figure 6-7 Kuantan Annual and Seasonal Wind Rose 6-101
Figure 6-8 River Catchment Surrounding Project Site 6-102
Figure 6-9 Drainage System Within the Integrated Chemical Site (ICS) 6-103
Figure 6-10 Flood Prone Area 6-104
Figure 6-11 Baseline Sampling Locations for Water Quality, Air Quality, and Noise
Levels 6-105
Figure 6-12 Existing Monitoring Stations 6-106
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xiii

Figure 6-13 Residential Areas, Institutions and Public Amenities Within 5km of the
Project Site 6-107
Figure 9-1 Proposed Environmental Monitoring Locations During Construction
9-19
Figure 9-2 Proposed Environmental Monitoring Locations During Operation 9-20
LIST OF TABLES
Table 1-1 Coordinates of the Project Site 1-2

Table 2-1 Written Comments from Agencies, Technical Departments and
Appointed Individuals and Meeting Minutes 2-2
Table 2-2 Comments from TOR Endorsement 2-60
Table 4-1 Comparison of 2-Ethylhexanoic Acid Production Methods 4-2
Table 5-1 Key Project Components 5-5
Table 5-2 Activities During Construction Stage 5-13
Table 6-1 Key Landmarks Within 5km Radius of the Project Site 6-4
Table 6-2 Groundwater Sampling Results for Groundwater Wells BH2, BH4, BH6
BH8 and BH10 6-23
Table 6-3 Groundwater Sampling Results for Groundwater Wells BH2, BH4, BH6
BH8 and BH10 6-24
Table 6-4 Groundwater Sampling Results for Groundwater Wells BH4 and BH5A
(Total Petroleum Hydrocarbon and Heavy Metals) 6-25
Table 6-5a Groundwater Sampling Results for Groundwater Wells BH4 and BH5A
(Volatile Organic Compounds) 6-25
Table 6-5b Groundwater Sampling Results for Groundwater Wells BH4 and BH5A
Table 6-5c Groundwater Sampling Results for Groundwater Wells BH4 and BH5A
Table 6-5d Groundwater Sampling Results for Groundwater Wells BH4 and BH5A
Table 6-5e Groundwater Sampling Results for Groundwater Wells BH4 and BH5A
Table 6-6 Location of Air Quality Sampling Points 6-28
Table 6-7 Location of Air Monitoring Stations 6-29
Table 6-8 Baseline Ambient Air Quality Result 6-30
xiv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Table 6-9 Summary of Air Quality at Balok Baru and Kuantan CAQM Stations in
2019 and 2020 6-33
Table 6-10 Ambient Air Monitoring Results for the Year 2021 6-34
Table 6-11 Location of Baseline Environmental Noise Monitoring Points 6-35
Table 6-12 Location of Existing Environmental Noise Monitoring Stations 6-35
Table 6-13 Ambient Noise Quality Results 6-37
Table 6-14a Results of Historical Periodic Ambient Noise Monitoring for the year of
2019 to 2021 (Station PN1, PN3, PN4) 6-38
Table 6-14b Results of Historical Periodic Ambient Noise Monitoring for the year of
2019 to 2021 (Station PN2) 6-41
Table 6-15 Baseline Water Quality Sampling Location 6-42
Table 6-16 Water Quality Parameter and Analysis Method 6-43
Table 6-17 Water Quality Monitoring Stations by Department of Environment 6-44
Table 6-18 Water Quality Monitoring Location 6-45
Table 6-19 Baseline Water Quality Sampling Results 6-47
Table 6-20 DOE Water Quality Monitoring Data at Station 4CBKL002 in Sg. Balok
in 2017 6-56
in 2017 6-57
in 2018 to 2020 6-58
in 2018 to 2020 6-59
Table 6-24 Water Quality Data (Station PW1) from Post EIA Compliance
Monitoring by BASF PETRONAS Chemicals Sdn. Bhd 6-62
Table 6-30 Estimated Quantity of Scheduled Wastes Generated from Existing 2-
EHAcid Plant (Plant I) 6-71
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xv

Table 6-31 Level of Service (LOS) for Access Roads 6-73
Table 6-32 Level of Service 6-74
Table 6-33 Total Population of Pahang State, Kuantan District and the mukim of
Sg. Karang 6-75
Table 6-34 Ethnic Composition of Sg. Karang Mukim, 2020 6-76
Table 6-35 Projected Number of Households and Living Quarters in Mukim Sg.
Karang 6-76
Table 6-36 Dependency Ratios in Mukim Sg. Karang, 2020 6-77
Table 6-37 Residential Areas Within 5km From the Project Site 6-78
Table 6-38 Institutions and Public Amenities Within 5km From the Project Site 6-78
Table 6-39 General Profile of the Respondents Surveyed 6-79
Table 6-40 Employment Status of Villagers Surveyed 6-79
Table 6-41 Nature of Jobs Being Employed 6-80
Table 6-42 Distribution of Household Incomes Among Community Surveyed 6-80
Table 6-43 Distribution of Households Sampled by Residential Areas 6-81
Table 6-44 Respondents’ Highest Level of Education 6-82
Table 6-45 Respondents’ Length of Stay in Present House 6-82
Table 6-46 Type of Respondents’ Houses 6-83
Table 6-47 Building Materials Used for Houses 6-83
Table 6-48 Type of Toilet in the Houses Surveyed 6-83
Table 6-49 Source of Drinking Water in the Houses Surveyed 6-83
Table 6-50 Garbage Disposal Practices by the Households Surveyed 6-84
Table 6-51 Pest Problems Experienced by the Households Surveyed 6-84
Table 6-52 Household Members Diagnosed with Selected Diseases By Doctors
Within The Last Year 6-85
Table 6-53 Reasons for Seeking Medical Treatments by Household Members Within
the Last 3 Months 6-86
Table 6-54 Disease Cases Related to Air Pollution Seen at Klinik Kesihatan Balok
2021 6-88
Table 6-55 Skin Disease Cases Seen at Klinik Kesihatan Balok In 2021 6-89
Table 6-56 Disease Cases Related to Air Pollution Seen at Hospital Tengku
Ampuan Afzan In 2021 6-90
Table 6-57 Disease Cases Related to Water Pollution Seen At Hospital Tengku
Ampuan Afzan In 2021 6-91
xvi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Table 6-58 Disease Cases Related To Animal Vectors And Reservoirs Seen At
Hospital Tengku Ampuan Afzan In 2021 6-92
Table 6-59 Skin Disease Cases Seen At Hospital Tengku Ampuan Afzan In 2021
6-93
Table 6-60 Prevalence Rates of Selected Communicable Diseases In District Of
Kuantan In 2021 6-94
Table 7-1 Impact Significance Matrix 7-2
Table 7-2 Summary of Impacts 7-4
Table 7-3 Location of Existing Noise Monitoring Station 7-9
Table 7-4 Sound Power Levels of Heavy Machinery and Equipment on Project
Site 7-10
Table 7-5 Predicted Noise Levels and Anticipated Community Response 7-11
Table 7-6 Mixing Model Input for TSS Assessment 7-16
Table 7-7 Predicted TSS Level at PKNP Drainage and Sg. Balok Under Scenario 1
and Scenario 2 7-16
Table 7-8 Potential Impacts from Solid Waste Mismanagement 7-18
Table 7-9 Estimated Quantities of Solid Wastes During Construction Stage 7-18
Table 7-10 Source and Type of Scheduled Wastes Generation 7-19
Table 7-11 Negative Impacts Perceived During Construction Stage 7-20
Table 7-12 Perceived Positive Impacts During Construction 7-22
Table 7-13 Expected Pollutant Emissions from Project Operation during Normal
and Abnormal Scenario 7-23
Table 7-14 Setting Conditions of AERMET and AERMOD 7-25
Table 7-15 Source Specification 7-28
Table 7-16 Emission Concentration and Emission Rate 7-28
Table 7-17 Predicted Maximum Average Incremental Concentration (MAIC) and
Ground Level Concentration (GLC) at Air Sensitive Receptors (ASRs) 7-35
Table 7-18 GHG Emission from Project Operation 7-50
Table 7-19 Predicted Noise Levels and Anticipated Community Response During
Daytime 7-52
Table 7-20 Predicted Noise Levels and Anticipated Community Response During
Night-time 7-53
Table 7-21 Characterization of Hazardous Material 7-56
Table 7-22 A Risk Matrix Table 7-57
Table 7-23 Level of Likelihood 7-57
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xvii

Table 7-24 Level of Consequences 7-58
Table 7-25 List of Scenarios 7-59
Table 7-26 Hole Sizes for Release Modelling 7-61
Table 7-27 Listing of Release and Outcome Events for Consequence Analysis 7-62
Table 7-28 Equipment Failure Rates 7-69
Table 7-29 Generic Ignition Probabilities 7-70
Table 7-30 Immediate and Delayed Ignition Probability Distribution 7-70
Table 7-31 Probability of Explosion Given Gas Cloud Ignition 7-70
Table 7-32 Hazard Zones Criteria 7-73
Table 7-33 Mixing Model Input for Water Quality Assessment during Operational
Stage 7-83
Table 7-34 Mixing Model Output for Water Quality Assessment Under Scenario 1
7-86
7-87
Table 7-36 Estimated Quantities of Solid Wastes During Operation Stage 7-88
Table 7-37 Estimated Maximum Quantity of Potential Scheduled Wastes
Generated During Operation Phase 7-89
Table 7-38 Toxicity and Ecological Information 7-91
Table 7-39 Average Negative Impact Scores During Project Operation 7-93
Table 7-40 Perceived Positive Impacts During the Proposed Project Operational
Phase 7-94
Table 7-41 Distribution of Respondents Surveyed Among the Villages in the ZOIs
7-96
Table 7-42 General Profile of the Respondents Surveyed 7-97
Table 7-43 Race Distribution of the Respondents 7-97
Table 7-44 Age Distribution of the Respondents 7-98
Table 7-45 Education Level of Respondents 7-98
Table 7-46 Employment Status of Villagers Surveyed 7-99
Table 7-47 Nature of Jobs Being Employed 7-99
Table 7-48 Distribution of Household Incomes Among Community Surveyed 7-99
Table 7-49 Number of Household Members 7-100
Table 7-50 Residential Duration at Existing Location 7-100
Table 7-51 Previous Residential Locations for Those Having Been in Residence for
Less Than 5 Years 7-101
xviii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Table 7-52 Channel of Conveying Information on the Proposed Project 7-102
Table 7-53 Level of Support of the Proposed Project 7-103
Table 7-54 Perceived Positive Impacts of Existing Project in Operation 7-103
Table 7-55 Form of Negative Impacts Perceived from the Existing Project in
Operation 7-104
Table 7-56 Feedbacks Received During FGD With Local Residents 7-107
Table 7-57 Feedback Received During GISG Engagement 7-113
Table 7-58 Air Sensitive Receptors (ASR) For Air Quality Impact Assessment
7-122
Table 7-59 Predicted Maximum Average Incremental Concentration (MAIC) and
Ground Level Concentration (GLC) at Air Sensitive Receptors (ASRs) 7-123
Table 7-60 Predicted Highest Ambient and Adjusted Exposure Concentrations,
RfC and HQ For Non-Carcinogenic Health Effects of Air Pollutants for An Exposure
at The Most Sensitive ASR Sites During A Normal Project Operation Scenario 7-126
Table 7-61 Potential Impacts During Project Abandonment 7-128
Table 8-1 Examples for Methods of Reducing Noise Levels from Construction
Equipment 8-4
Table 8-2 Sanitation Facility Specifications 8-7
Table 8-3 Design Capacity of Oil and Grease Trap 8-8
Table 8-4 Recommended Reusage for Construction Materials 8-12
Table 8-5 Mitigation Measures for the Proposed Project During Construction
Phase 8-16
Table 8-6 Special Actions for Direct Benefits of Local Employment Opportunities
8-17
Table 8-7 BASF PETRONAS Chemicals Sustainability Pillars 8-20
Table 8-8 List of Competent Persons for Scheduled Waste Management 8-25
Table 8-9 Storage Design of Existing Scheduled Waste Storage Area 8-27
Table 8-10 Community Preference and Ratings on Their Expectations of
Implementation of Mitigation Measures Against Negative Impacts During Operation
Stage 8-30
Implementation of Enhancement Activities Of Positive Impacts During Operation
Stage 8-31
Table 9-1 Proposed Monitoring Programme and Auditing during Construction
Phase 9-11
Table 9-2 Proposed Monitoring Program and Auditing during Operation Phase
9-13
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xix

Table 10-1 Summary of the Study Findings 10-1
LIST OF PLATES
Plate 1-1 Project Site 1-3

Plate 5-1 Existing Tank Farm 5-1
Plate 5-2 Existing Residue Tank 5-1
Plate 5-3 New Loading Arm at Bay 6 5-2
Plate 5-4 Existing Oxo Tank Farm 5-2
Plate 5-5 Centralized Wastewater Treatment Plant at ICS 5-3
Plate 5-6 Product Loading Facility at ICS (Drums) 5-3
Plate 5-7 Product Loading Facility at ICS (Gantry) 5-4
Plate 6-1 Existing 2-EHAcid Plant 6-3
Plate 6-2 Retention Pond Within ICS Boundary 6-12
Plate 6-3 PKNP’s Stormwater Drainage Outside ICS Boundary 6-12
Plate 6-4 Flash Flood at Gebeng Bypass 6-13
Plate 6-5 KASA Implements Flood Disaster Risk Assessment 6-16
Plate 6-6 Pusat Rekreasi Pantai Balok 6-17
Plate 6-7 Sungai Balok 6-18
Plate 6-8 Fishing Boat Stationed along Sg. Balok, near Jalan Kuantan-Kemaman 6-19
Plate 6-9 Fishing Boats at Sg. Balok Estuary, near Pasar Nelayan Balok 6-19
Plate 6-10 Shrimp Hatchery Operating in Balok, Pahang 6-21
Plate 6-11 Existing Scheduled Waste Storage Area Within ICS (A 342) 6-70
Plate 7-1 Enumerator Interviewing Local Resident 7-95
Plate 7-2 Enumerator Interviewing Local Resident 7-96
Plate 7-3 Briefing about the Project to the Local Residents 7-105
Plate 7-4 Feedback Session Conducted During the FGD with Local Residents 7-106
Plate 7-5 Engagement with ILP Kuantan 7-111
Plate 7-6 Engagement with Representatives of the Gebeng Industrial Support Group
(GISG) 7-112
Plate 8-1 Water Bowser Spraying Water along the Haul Road 8-2
Plate 8-2 Vehicle Load Covered with Tarpaulin 8-2
Plate 8-3 Example of Portable Toilet at Construction Site 8-7
xx Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Plate 8-4 Proper Segregation and Storage of Solid Wastes for Construction Sites
8-13
Plate 8-5 Examples of Waste Characteristic Labels 8-15
Plate 8-6 Existing Scheduled Wastes Storage (A 345) 8-26
Plate 8-7 Existing Scheduled Wastes Storage (A 342) 8-26
Plate 8-8 Emergency Isolation Valve at Drainage within ICS 8-28
Plate 8-9 Emergency Isolation Valve at Scheduled Waste Storage Area 8-28
LIST OF CHARTS
Chart 1-1 Gross Domestic Product by Kind of Economic Activity, 2020 – 2025 1-5
Chart 1-2 Pahang Spatial Development Framework 1-6
Chart 1-3 Target for Oil, Gas & Petrochemical Industry in East Coast Economic
Region 1-8
Chart 3-1 Expected Global 2-EHAcid Market Based on CAGR of 6.3% (from 2020
to 2031) 3-1
Chart 3-2 Global Consumption of Plasticizers in 2017 3-2
Chart 3-3 Malaysia’s Economic Performance in 2020 3-3
Chart 3-4 One of the Key Strategic Initiatives of ECER Master Plan 2.0 3-3
Chart 5-1 Overall Process Diagram of 2-EHAcid Production 5-6
Chart 5-4 Project Implementation Schedule 5-16
Chart 6-1 Flood Risk Management Strategy 6-14
Chart 6-2 Location of Fishing Boats 6-18
Chart 6-3 Location of Sampling Point for Fisheries Survey in Sg. Balok 6-20
Chart 6-4 Location of Shrimp Hatchery from Project Site 6-21
Chart 6-5 Groundwater Monitoring Locations within the ICS 6-22
Chart 6-6 Direction of Groundwater Flow 6-27
Chart 6-7 Location of CAQM Stations Near Project Site 6-29
Chart 6-8 Biochemical Oxygen Demand (BOD) Trendline for Station 4CBLK002
from 2017 to 2020 6-49
Chart 6-9 Chemical Oxygen Demand (COD) Trendline for Station 4CBLK002
from 2017 to 2020 6-50
Chart 6-10 Dissolved Oxygen (DO) Trendline for Station 4CBLK002 from 2017 to
2020 6-50
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xxi

Chart 6-11 Total Suspended Solids (TSS) Trendline for Station 4CBLK002 from
2017 to 2020 6-51
Chart 6-12 Ammoniacal Nitrogen (NH3-N) Trendline for Station 4CBLK002 from
2017 to 2020 6-51
Chart 6-13 Biochemical Oxygen Demand (BOD) Trendline for Station 4CBLK001
from 2017 to 2020 6-53
Chart 6-14 Chemical Oxygen Demand (COD) Trendline for Station 4CBLK001
from 2017 to 2020 6-53
Chart 6-15 Dissolved Oxygen (DO) Trendline for Station 4CBLK001 from 2017 to
2020 6-54
Chart 6-16 Total Suspended Solids (TSS) Trendline for Station 4CBLK001 from
2017 to 2020 6-54
Chart 6-17 Ammoniacal Nitrogen (NH3-N) Trendline for Station 4CBLK001 from
2017 to 2020 6-55
Chart 6-18 Location of Nearest Disposal Facility (Tapak Pelupusan Jabor Jerangau)
from Project Site 6-68
Chart 6-19 Junction Locations and Existing Traffic Volume 6-73
Chart 6-20 Proportions of Population Age Structure in Mukim Sg. Karang 6-77
Chart 7-1 Noise Modelling Contour of the Project Boundary During Construction
Stage 7-12
Chart 7-2 Diagram on Discharge Flow from Project Site During Construction
Stage 7-14
Chart 7-3 Schematic Diagram of Mixing Model 7-14
Chart 7-4 Locations of ASRs surrounding Project Site 7-26
Chart 7-5 Locations of Stacks 7-27
Chart 7-6 Predicted MAIC of PM10 (24 Hour and Annual Averaging Time) during
Normal Operation 7-36
Chart 7-7 Predicted MAIC of NO2 (1-Hour and 24-Hour Averaging Time) during
Chart 7-8 Predicted MAIC of SO2 (1-Hour and 24-Hour Averaging Time) during
Chart 7-9 Predicted MAIC of CO (1-Hour and 8-Hour Averaging Time) during
Chart 7-10 Predicted MAIC of Cl2 and H2S (24-Hour Averaging Time) during
Chart 7-11 Predicted MAIC of HCl and Hg (24-Hour Averaging Time) during
xxii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Chart 7-12 Predicted MAIC of NH3 and NMVOC (24-Hour Averaging Time)
during Normal Operation 7-42
Chart 7-13 Predicted MAIC of 1-Butene and MeOH (1-Hour Averaging Time)
during Abnormal Operation 7-43
Chart 7-14 Predicted MAIC of Isoprene and MTBE (1-Hour Averaging Time)
Chart 7-15 Predicted MAIC of Pentane and Butane (1-Hour Averaging Time)
Chart 7-16 Predicted MAIC of Hydrogen and n/i-Butyraldehyde (1-Hour
Averaging Time) during Abnormal Operation 7-46
Chart 7-17 Predicted MAIC of 2-ethylhexanal (1-Hour Averaging Time) during
Abnormal Operation 7-47
Chart 7-18 GHG Emission Scenario 7-49
Chart 7-19 GHG Emissions in the ICS 7-51
Chart 7-20 Noise Modelling Contour of the Project Boundary During Operation
Stage 7-54
Chart 7-21 QRA Methodology 7-55
Chart 7-22 Event Tree Model for Small, Medium, and Large Release of Flammable
Liquid > 2 bar 7-71
Chart 7-23 Event Tree Model for Catastrophic Release of Flammable Liquid > 2 bar
7-71
Chart 7-24 Event Tree Model for Small, Medium, Large and Catastrophic Release
of Flammable Liquid < 2 bar 7-72
Chart 7-25 Event Tree Model for Small, Medium and Catastrophic Release of
Flammable Gas 7-72
Chart 7-26 Individual Risk (IR) Contour 7-78
Chart 7-27 Diagram on Discharge Flow from Project Site during Operational Stage
7-82
Chart 8-1 Source, Path and Receiver Control Options 8-6
Chart 8-2 Schematics of Underground Oil and Grease Type 8-8
Chart 8-3 Waste Management Hierarchy 8-11
Chart 8-4 Flowchart for Contractor Scheduled Waste Handling 8-14
Chart 8-5 An Example of Label for Scheduled Wastes Container 8-15
Chart 8-6 Sustainable Development Goals 8-19
Chart 8-7 Hierarchy of Noise Control 8-21
Chart 8-8 Source, Path and Receiver Control Option for Industrial Premises 8-22
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xxiii

Chart 8-9 Flowchart for E-Waste Handling 8-27
Chart 8-10 Best Practical Environmental Option Concept 8-33
Chart 9-1 Environmental Mainstreaming Tools Compliance Report 9-15
xxiv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

ES EXECUTIVE SUMMARY
INTEGRATED CHEMICAL SITE OF BASF PETRONAS
CHEMICALS, GEBENG, KUANTAN PAHANG
1 | INTRODUCTIO N
PROJECT BACKGROUND
BASF PETRONAS Chemicals Sdn. Bhd. (BPC) is a joint venture between BASF SE of Germany
and Malaysia’s PETRONAS Chemicals Group (PCG).
Incorporated in August 1997, the company operates an Integrated Chemical Site (ICS)
situated at the Gebeng Industrial Estate, Pahang, and currently has 14 fully integrated
plants, with key products include:
➢ Acrylic Monomers;
➢ Oxo Products;
➢ Highly Reactive Polyisobutene;
➢ Aroma Ingredients; and
➢ 2-Ethylhexanoic Acid (2-EHAcid).
The first 2-EHAcid plant is currently in operation after commissioned in Q4 of 2016. The
Project, which is a second 2-EHAcid plant, will be constructed right next to it.
4 March 2015 Q4 2016

Current
DEIA Approval for 2- Operation of 2-EHAcid
EIA for 2-EHAcid Plant II
EHAcid Plant I Plant I
PROJECT PROPONENT QUALIFIED PERSONS
BASF PETRONAS Chemicals Sdn. Bhd. ERE Consulting Group Sdn. Bhd.
Jalan Gebeng 2/1, (Member of the Aurecon Group)
Kawasan Perindustrian Gebeng, 9, Jalan USJ 21/6,
26080 Kuantan, Pahang Darul Makmur. 47630 Subang Jaya, Selangor Darul Ehsan.
Contact Person: Contact Person:

Ir. Muhammad Firdaus bin Kamaruddin Tan Yen Chen
(General Manager) (EIA Team Leader)
Tel : +609-5855377 Tel : +603-80242287
Fax. : +609-5835541 Fax. : +603-80242320
Email : MuhdFK@basf-petronas.com.my Email : tyc@ere.com.my
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-i

PROJECT LOCATION
The Project site is located within BPC’s
existing ICS at Gebeng Industrial Estate
(GIE), Kuantan. It will occupy a total area of
approximately 0.088 ha (0.217 ac).
The Project is accessible via East Coast

Expressway, Lebuhraya Pantai Timur (LPT), Legend
through Jabor exit, Gebeng Bypass and Jalan Project Site
Gebeng 1/11. ICS Boundary
Legend
Project Site (New 2-
EHAcid Plant
Existing 2-EHAcid
Plant
Points Longitude Latitude
A 103°22’04.39"E 3° 59’05.11"N
B 103°22’05.56"E 3° 59’05.48"N
C 103°22’05.95"E 3° 59’04.17"N
D 103°22’04.79"E 3° 59’03.81"N
LEGAL ASPECTS
Second Schedule Prescribed Activity
Activity 6(d) Petrochemicals: Production capacity of each product or combined
product of 50 tonnes or more per day
CONFORMANCE WITH POLICIES AND DEVELOPMENT PLANS

➢ Twelfth Malaysia Plan
➢ Rancangan Fizikal Negara 4
➢ Rancangan Struktur Negeri Pahang 2050
➢ Rancangan Tempatan Daerah Kuantan 2035 (Penggantian)
➢ East Coast Economic Region Master Plan 2.0
ES-ii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

2 | T ERMS OF REF ERENC E
ENDORSEMENT OF TOR
The Revised TOR & ESI Report was submitted to DOE HQ on 25th April 2022, and
it was endorsed on 27th May 2022 (Ref: JAS.600-2/9/3 Jilid 2 (4)).
3 March 2022 21 March 2022 25 April 2022 27 May 2022

TOR & ESI TOR Adequacy Revised TOR & TOR
Submission Check ESI Submission Endorsement
3 | STATEMENT OF NEED
Increasing Demand in 2-EHAcid Stimulating Local Economy

2-EHAcid is used in production of
synthetic lubricants, oil additives, Unique geographical advantage in
automotive coolants, plasticizers, imports and exports
stabilizers etc.
2-EHAcid is a high-quality specialty
Rise in demand for PVB plasticizers chemical which is expected to
and PVC stabilizers in Asia-Pacific contribute to the nation’s export
(57% of global demand in 2017) capacity
4 | PROJECT OPTIONS
No Project Option Technology Alternatives

May result in potential loss to
benefits, including: Electrochemical Catalytic
Synthesis of 2- Oxidation of
ethylhexanol 2-ethylhexanol
High capital investment
Downstream benefits
Catalytic
Service sector benefits Oxidation of
dehydrogenation
2-ethylhexanal
of 2-ethylhexanol
Macro-economic benefits
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-iii

5 | PROJECT DESCRIPTION
PROJECT CONCEPT
➢ New open air 2-EHAcid production plant (proposed max. production

capacity of 36,000 MT/a)
➢ Modification of an existing tank farm
➢ Replacement of existing residue tank with new organic residue tank
➢ Addition of new loading arm
➢ Addition of feed pump
➢ Utilizing existing infrastructures and utilities of the Oxo facilities
PROJECT LAYOUT AND KEY COMPONENTS
8 7
1 2 3 4 5 6
No. Key Components No. Key Components

1 Rectification Tower 5 Hydrogenation Reactor
2 Hexanal Tower 6 Oxidation Reactor
3 Stripping Column 7 Hexanal Buffer Drum
4 Hexanol Tower 8 Organic Residue Drum
ES-iv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

PROCESS DESCRIPTION
Chemical Reactions
Hydrogenation : C8H14O + H2 → C8H16O
(2-ethylhexenal) (hydrogen) (2-ethylhexanal)
Oxidation : C8H16O + ½ O2 → C8H16O2

(2-ethylhexanal) (oxygen) (2-ethylhexanoic acid)
OFF-GAS AND WASTE MANAGEMENT
Blended to existing Oxo oil 900 tank of

Organic residue
Oxo Complex
Off-gas containing H2 Bi-flare
Off-gas containing O2 Thermal Oxidizer
Process wastewater Existing Wastewater Treatment Plant
PLANT UTILITY
Steam and Condensate

Electricity
HP Steam Refrigeration
Low Voltage LP Steam
High Voltage Raw Condensate
Water
Boiler Feed Water Fire Fighting Water

Cooling Water Demineralized Water
Potable Water
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-v

PRINCIPAL PROJECT ACTIVITIES
Pre-Construction
Construction
Operation
i. Environmental i. Mobilization i. Raw materials and
Impact Assessment products
ii. Accessibility
transportation and
ii. Site reconnaissance iii. Foundation works storage
iii. Stakeholder iv. Civil and structural ii. Operation of 2-

engagement works EHAcid plant
v. Mechanical and
iv. Finalization of plant electrical works iii. Scheduled waste
layout and design management
work vi. Testing and
commissioning iv. Maintenance of
v. Agency approvals vii. Demobilization plant and equipment
PROJECT IMPLEMENTATION SCHEDULE

The construction of the Project is expected to be nineteen (19) months (from November
2022 to May 2024), followed by the commissioning stage (T&C) of two (2) months.
Pre-construction Stage
EIA, Finalization of plant layout and design, Agency approvals,
Equipment manufacturing and delivery
Construction Stage (19 mths)

Construction works, Equipment installation,
Mechanical and electrical works
T&C
(2
mnths)
Nov Mar Jul Nov Mar Jul Nov Mar Jul

‘21 ‘22 ‘22 ‘22 ‘23 ‘23 ‘23 ‘24 ‘24
6 | EXISTING ENVIRONMENT
PHYSICAL ENVIRONMENT
Topography & Terrain Geology & Soil

Project site is underlain by
Project site ranges from 10- predominantly unconsolidated
20m above MSL. It is already Quaternary alluvial sediments
prepared to platform level. and sits on peat soil.
ES-vi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

LAND USE AND SENSITIVE RECEPTORS
Existing Land Use Future Land Use Proposed Future Development
Existing land use surrounding the Project site The Kuantan Port City (KPC) Draft Masterplan
Land use within 5km radius of the Project site
is comprised mainly of industries, vacant has also propose several major developments
have been mostly gazette as industrial areas
lots and some residential areas in the within the vicinity of the Project site, such as
with a few residential areas down south.
southwest direction. the Kuantan Port City.
Land Use
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-vii

CLIMATE
Temperature Rainfall
Avg. annual rainfall: 2,975.3 mm
Avg. annual 24-hour temp.: 26.8˚C Avg. rain days: 186 days
Warmest months: May (avg. 27.8˚C) Most rain days: Nov (23 days)
Coolest months: Dec & Jan (avg. 25.5˚C) Least rain days: Feb (11 days)
Relative Humidity Surface Wind

Avg. annual 24-hour mean RH: 84.8% Predominant Wind: Northwest
Highest RH: Nov (88.4%) Annual mean speed: 1.6 m/s
Lowest RH: Jul & Aug (83.2%) Calm period: 0.3 m/s (17.8% of the time)
HYDROLOGY AND DRAINAGE
River Catchment
The Project Site is located within the Sg. Balok catchment. The nearest river, Sg. Balok,
is approximately 0.9km westward from the Project site, and will eventually discharge into
the South China Sea.
Drainage System
Treated wastewater is discharged to
PKNP drainage directly, then flow
into Sg. Balok.
Surface run-off from within the ICS is

collected via on-site drainage
channels into a retention pond at Legend
the south of the Project site. It then Project Site
discharges out into PKNP’s drainage, ICS Boundary
which flows into Sg. Balok.
ES-viii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Flood Prone Area
Existing Flood Risk Mitigation and Action Plans
Flood Risk Strategy National Flood Forecasting

Flood Disaster Risk
outlined in RTD Kuantan and Warning Program
Assessment
2035 (Penggantian) (PRAB)
GROUNDWATER
BH7
Sampling in 2014 Legend
BH8
• All BHs except for BH9 was
BH9 Groundwater Wells
not sampled due to damage Installed in 2001
• VOCs, SVOCs and TPH Groundwater Wells
compounds were not BH14
Installed in 2014
detected Project Site
BH6 ICS Boundary
• Fe levels at BH2 and B14
higher than SSLs (26,000 µg/l)
• As levels at BH2 and BH8 BH10 BH13
higher than SSLs (0.045 µg/l)
BH5A
Sampling in 2020 BH1A
• Conducted at BH4 and BH5A
BH4
• Heavy metals were all below
SSLs BH2
BH3A
• VOCs were all below 10 µg/l
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-ix

ENVIRONMENTAL QUALITY
A4
N2
N3
N1 N2 W7
W1
W5
W6
W2
W3 Kg.Selamat
Institut Latihan
Perindustrian
A1 Kuantan
Taman Perasing
A3 Kg. Berahi
W4 Balok Perdana
Legend
Kg.Seberang
A2 Balok ICS Boundary
Project Site
Water Quality Ambient Noise Level
Seven (7) samples in total were collected from Three (3) locations were selected to measure
Sg. Balok, PKNP drainage and stagnant points the ambient noise level.
within the ICS. Noise levels recorded at all stations during
daytime and nighttime are all within the
The baseline water quality sampling showed
permissible limits stipulated in the Guidelines
that generally the water quality fall within Class
for Environmental Noise Limits and Control (3rd
III limits of the NWQS.
Ed.).
Air Quality
Four (4) locations were selected to carry out monitoring for 23 pollutants (PM10, PM2.5, SO2, NO2,
CO, O3, H2S, Cl2, HCl, NH3, VOCs and heavy metals).
All parameters are well below the stipulated limits in MAAQS and Ontario Ambient Air Quality
Criteria throughout the monitoring period.
WASTE MANAGEMENT
Solid Waste Management Scheduled Waste Management

Nearest disposal facility is Tapak Managed according to an existing
Pelupusan Jabor Jerangau Scheduled Waste Management
(~4.3km from Project site) Plan (SWMP)
ES-x Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

EXISTING TRAFFIC CONDITION
Access roads – Gebeng Bypass, Jalan Pintasan Kuantan and Jalan Gebeng 1/11, all
have Level of Service (LOS) A.
SOCIO-ECONOMIC PROFILE
The mukim that the proposed Project is located is Sungai Karang, which has a projected
population of 69,312 in 2020.
Ethnic Group Distribution Household: 15,206

0.37% Living Quarters: 17,030
4.03% 1.77%
1.24% Malay
5.32% Chinese Age Group
< 15 37.45%
Indians
15 – 64 60.24%
Non-Malaysian ≥ 65 2.32%
Citizens
Others
87.27%
Other Bumiputeras Dependency Age Ratio
Sg. Karang 66.01%
Zone of Influence (ZOI)

The Zone of Influence (ZOI) covering within a 5km radius of the Project site involves residential
areas, institutions and public amenities.
Legend
ICS Boundary
Project Site
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xi

EXISTING PUBLIC HEALTH
Smoking Members in Household 0.2% 13.1%

0.2%
1.7%
No Yes Yes
41.9% 58.1% 35.0% No 84.7%
23.2%
No toilet (0.2%)
Pit latrine (13.1%)

Smoking
within house Bucket toilet (0.2%)
Pour-flush latrine (1.7%)
Flush toilet (84.7%)
7 & 8 | IMPACT ASSESSMENTS AND MITIGATION MEASURES
CONSTRUCTION STAGE
Environmental
Potential Impacts Proposed Mitigation Measures
Elements
▪ Erect hoarding or equivalent

barriers around the construction
area
Fugitive dust generation when
particulates are lifted into the air ▪ Regular water spraying of
from movement of construction construction site, particularly
vehicles and minor earthmoving along haul roads
activities ▪ Cover stockpiles and vehicles
carrying earth, sand or aggregate
to control fugitive dust emissions
Air Quality
Impact Magnitude: ▪ Impose speed limits within
Not Significant construction site
▪ Fuel-efficient and well-maintained
equipment to be used
▪ Avoid unnecessary revving of

engines and switch off equipment
when not required
Temporary increase in ambient ▪ Noisy equipment or activities
noise levels due to construction should be replaced by less noisy
works and increment of vehicular alternatives
movement
▪ Good maintenance of equipment
▪ Machines such as cranes should
Impact Magnitude: be shut down between work
Noise periods / throttled down to a
Not Significant
minimum
▪ Materials should be lowered
whenever practicable
ES-xii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Environmental
Elements
▪ Ensure that all mitigation

measures stipulated in ESCP
shall be implemented and
▪ River water pollution due to
maintained
surface runoff
▪ Accidental discharge or ▪ Sediment basins shall be
spillage of petroleum inspected and desilted on a
products and scheduled regular basis
wastes causing ▪ Denuded stretches must be re-
contamination of vegetated after construction
waterways works
▪ Sewage and sullage ▪ Proper housekeeping and
Water Quality generation from temporary hygiene to be maintained at all
toilet facilities times for toilet facilities
▪ Storage and handling of
Impact Magnitude:
scheduled wastes to be carried
Low
out according to the EQ
(Scheduled Wastes)
Regulations, 2005
Solid Waste
▪ Collection of water by wastes, Solid Waste
which will become breeding ▪ Development and
grounds for pests which implementation of suitable Waste
transmit diseases Management Plan is encouraged
▪ Illegal open burning will ▪ Management of waste according
cause air pollution to waste management
▪ Debris may potentially clog hierarchy: refuse, reduce, reuse,
drains, causing flash floods recycle, recover and disposal
during rainy seasons
Scheduled Waste
Scheduled Waste ▪ Management of scheduled waste
Waste ▪ Accidental spillage or in accordance with the Guidelines
Management leakages will deteriorate for Packaging, Labelling and
water quality of nearest river Storage of Scheduled Wastes in
▪ Illegal burning may expose Malaysia published by DOE
nearby receptors to ▪ Scheduled wastes to be stored
hazardous pollutants and managed according to the
existing Scheduled Waste
Impact Magnitude: Management Plan
Low
▪ Traffic congestion ▪ Develop a hotline/channel for

▪ Public safety and disturbance complaints
to routine daily travels ▪ Implement proposed mitigation
▪ Social unrest from incoming measures
foreign workers ▪ Implement Traffic Management
▪ Increase income to Plan
surrounding businesses and
▪ Prioritize locals for employment
Socio-Economic services
and business opportunities
Study
Impact Magnitude: ▪ Ongoing public involvement
Low from Project Proponent
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xiii

OPERATION STAGE
Environmental
Elements
▪ Oxygen concentration inside the

combustion chamber has to be
measured and controlled by
variation of air flow
▪ Thermal oxidizer (TOX) at Aroma
Complex has to be shut down if
Thermal treatment of off gases the flue gas oxygen content falls
containing mainly oxygen and below 2% vol.
hydrogen will be converted to
▪ During high organic load or high
combustion gases like nitrogen
amount of hydrogen containing
oxides, which can affect the
off gases, the natural gas flow
health of nearby population
has to be reduced to the
Air Quality
minimum required amount of
Impact Magnitude:
natural gas burner
Low
▪ Steam injection system shall be
installed for HP flare stack
▪ Preventive maintenance of HP
flare stack and Aroma TOX
components shall be carried out
regularly
BASF PETRONAS Chemicals

Sustainability Pillars
▪ Establish integrated energy
management dashboard
▪ Define pathway to net zero for
achieving target and incorporate
Emission of GHG from
plan into site development plan
combustion of fossil fuel
(natural gas) for the generation ▪ Collation of data from all OPEX
of steam projects related to climate
protection under one umbrella
Greenhouse Gas Impact Magnitude:
▪ Strategic analysis for every waste
Emission Not significant
created on site from 4R
perspective
▪ Review existing disposal
principles
▪ Focus on non-hazardous waste
management
Increase in ambient noise ▪ Provide proper enclosures for

levels from processing noisy equipment
equipment ▪ Regular maintenance of the
equipment
Impact Magnitude: ▪ Practice SOPs
Not significant ▪ Provide workers with PPEs
Noise
ES-xiv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Environmental
Elements
▪ Existing ICS’s ERP shall be

updated to address all potential
scenarios identified in the QRA
Risk of fire, explosion or ▪ Design changes during the
release of dangerous substances, engineering phases post EIA
such as 2-ethylhexanoic acid, 2- should be analysed to determine
ethylhexanal, 2-ethylhexanol, the severity of potential hazards
hydrogen, n-butanal, heptyl
formate and undecanol ▪ Safety report and ERP shall be
updated and submitted to the
Risk DOSH Major Hazard Division 3
Impact Magnitude:
Low months prior to commissioning
▪ Implementation of an effective
health and safety management
system
▪ Health impacts (mainly

secondary impacts) upon
▪ Preventive measures to be
the human community that
undertaken to control fugitive
emanate from primary
dust and vehicular emissions
impacts upon the physical
during construction stage
(air, water and soil), biological
▪ Control of disease vectors and
(Animals and plants) and
reservoirs should be carried out
social environment
during construction phase
▪ Main health impacts
▪ Contingency plan like plant
emanating from human
Health Impact shutdown and an emergency
exposure to air pollutants
Assessment response plan must be in place to
through direct inhalation
cater for abnormal Project
operation
Impact Magnitude:
Low
Wastewater generation from the ▪ Discharge to comply with

existing WWTP and accidental Standard B limits as prescribed in
leakage or spillages from the Environmental Quality
scheduled wastes will cause (Industrial Effluent) Regulation
deterioration of nearby 2009
waterways
▪ Operation of WWTP to strictly
Impact Magnitude: adhere to the existing WWTP
Water Quality
Low Manual
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xv

Environmental
Elements
Solid Waste
▪ Collection of water by wastes, Solid Waste
which will become breeding ▪ Development and
grounds for pests which implementation of suitable Waste
transmit diseases Management Plan is encouraged
▪ Illegal open burning will ▪ Management of waste according
cause air pollution to waste management
▪ Debris may potentially clog hierarchy: refuse, reduce, reuse,
drains, causing flash floods recycle, recover and disposal
during rainy seasons
Scheduled Waste
Scheduled Waste ▪ Management of scheduled waste
Waste ▪ Accidental spillage or in accordance with the Guidelines
Management leakages will deteriorate for Packaging, Labelling and
water quality of nearest river Storage of Scheduled Wastes in
▪ Illegal burning may expose Malaysia published by DOE
nearby receptors to ▪ Scheduled wastes to be stored
hazardous pollutants and managed according to the
existing Scheduled Waste
Impact Magnitude: Management Plan
Low
▪ Air and odour pollution from

factory
▪ Fire risk ▪ Effective safety measures in the
▪ Traffic congestion plant area to prevent accidents
▪ Public safety ▪ Implement proposed mitigation
▪ Increase income to measures
surrounding businesses and ▪ Use environmentally processes
services in the plant
▪ Addition and improvement of
▪ Setting of quotas for local
Socio-Economic infrastructure
employment
Study ▪ Encourage provision of public
services ▪ CSR program with nearby
residents / institutions
Impact Magnitude:
Low
PROJECT ABANDONMENT
In the event that the Project is abandoned, the following measures shall be taken:
Scheduled
Temporary site
wastes to be
facilities must
managed by
be
DOE licensed
demolished
Contractors
Solid wastes to
Submit Project
be disposed
Abandonment
off at
Plan to DOE
approved
Pahang
landfill
ES-xvi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

9 | ENVIRONMENTAL MANAGEMENT PLAN (EMP)
CONSTRUCTION STAGE
N2
N1 N3
W3
W5
W6
W4
Legend
W1
ICS Boundary
W2 Project Site
Water Quality
Ambient Noise Level
Performance Monitoring – Weekly monitoring
Impact Monitoring – Quarterly monitoring at
or after rainfall event of > 12.5mm for all ESCP
three (3) existing monitoring points (N1 to N3)
on site
Compliance Monitoring – Monthly monitoring
or after rainfall event of > 12.5 mm for silt trap
or sediment basin discharge; Quarterly Environmental Audit
monitoring for septic tank
To carry out once every four (4) months within
Impact Monitoring – Quarterly monitoring at
the Project site
six (6) existing monitoring points (W1 to W6)
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xvii

OPERATION STAGE
A2 N2
A3
N1 N3
A1 W3
W5
W6
W4
W1 Legend
ICS Boundary
W2
Project Site
Water Quality Ambient Noise Level

Performance Monitoring – Weekly monitoring for WWTP
Impact Monitoring –
Compliance Monitoring – Monthly monitoring for discharge
Quarterly monitoring at three
from WWTP
(3) existing monitoring points
Impact Monitoring – Quarterly monitoring at six (6) existing
(N1 to N3)
monitoring points (W1 to W6)
Air Quality
Compliance Monitoring – Quarterly monitoring at Citral TOX stack (XX-9680)
Impact Monitoring – Quarterly monitoring at three (3) existing monitoring points (A1 to A3)
Environmental Audit
To carry out annually within the Project site
10 | STUDY FINDINGS
Construction Stage
Impacts of air quality and noise are expected to be not significant, whereas impacts
of Project construction on water quality, waste management and socio-economic
are expected to be low
Operation Stage
Impacts of GHG and noise are expected to be not significant, whereas impacts of
Project operation on air quality, water quality, waste management, risk, health
and socio-economic are expected to be low
ES-xviii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

RE RINGKASAN EKSEKUTIF
CADANGAN PROJEK PEMBINAAN KILANG 2-EHACID II DI
KOMPLEKS PETROKIMIA BERSEPADU SEDIA ADA BASF
PETRONAS CHEMICALS DI KAWASAN PERINDUSTRIAN
1 | PENGENALAN
LATAR BELAKANG PROJEK

BASF PETRONAS Chemicals Sdn. Bhd. (BPC) adalah usahasama antara BASF SE dari Jerman
dan PETRONAS Chemicals Group (PCG) dari Malaysia.
Ia ditubuhkan pada tahun 1997 dan telah menghasilkan produk-produk kimia di Kompleks
Petrokimia Bersepadu sedia ada yang terletak di Kawasan Perindustrian Gebeng, Pahang.
Setakat ini, terdapat 14 kilang bersepadu sepenuh dalam kompleks yang menghasilkan
bahan-bahan seperti:
➢ Monomer Akrilik;
➢ Produk Oxo;
➢ Highly Reactive Polyisobutene;
➢ Bahan Aroma; dan
➢ 2-Ethylhexanoic Acid (2-EHAcid).
Kilang 2-EHAcid yang pertama kini sedang beroperasi selepas pertauliaan pada suku ke-
4 tahun 2016. Projek ini, iaitu kilang 2-EHAcid yang kedua, akan dibina di sebelah kilang
2-EHAcid pertama.
4 Mac 2015
Q4 2016 Sekarang
Kelulusan DEIA untuk
Operasi Kilang 2-EHAcid I EIA bagi Kilang 2-EHAcid II
Kilang 2-EHAcid I
PENGGERAK PROJEK JURUNDING EIA
BASF PETRONAS Chemicals Sdn. Bhd. ERE Consulting Group Sdn. Bhd.
Jalan Gebeng 2/1, (Member of the Aurecon Group)
Kawasan Perindustrian Gebeng, 9, Jalan USJ 21/6,
26080 Kuantan, Pahang Darul Makmur. 47630 Subang Jaya, Selangor Darul Ehsan.
Pegawai: Pegawai:
Ir. Muhammad Firdaus bin Kamaruddin Tan Yen Chen
(Pengurus Besar) (Ketua Pasukan EIA)
Tel : +609-5855377 Tel : +603-80242287
Faks : +609-5835541 Faks : +603-80242320
Emel : MuhdFK@basf-petronas.com.my Emel : tyc@ere.com.my
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA RE-i

LOKASI PROJEK
Tapak Projek terletak dalam kompleks
petrokimia bersepadu (ICS) sedia ada BPC
di Kawasan Perindustrian Gebeng, Kuantan. Ia
mempunyai keluasan kira-kira 0.088 ha (0.217
ek).
Projek ini boleh diakses melalui Lebuhraya Legenda

Pantai Timur (LPT) melalui susur keluar Jabor, Tapak Projek
Gebeng Bypass dan Jalan Gebeng 1/11. Sempadan ICS
Legenda
Tapak Projek (Kilang
2-EHAcid baru)
Kilang 2-EHAcid
Sedia ada
Points Longitude Latitude
A 103°22’04.39"E 3° 59’05.11"N
B 103°22’05.56"E 3° 59’05.48"N
C 103°22’05.95"E 3° 59’04.17"N
D 103°22’04.79"E 3° 59’03.81"N
ASPEK PERUNDANGAN
Jadual Kedua Perintah Kualiti Alam Sekeliling (Aktiviti Yang Ditetapkan)
Activiti 6(d) Petrokimia: Keupayaan pengeluaran setiap keluaran atau gabungan
keluaran sebanyak 50 tan atau lebih sehari
PEMATUHAN DASAR DAN RANCANGAN PEMBANGUNAN NEGARA

➢ Rancangan Malaysia Kedua Belas
➢ Rancangan Fizikal Negara 4
➢ Rancangan Struktur Negeri Pahang 2050
➢ Rancangan Tempatan Daerah Kuantan 2035 (Penggantian)
➢ Pelan Induk Wilayah Ekonomi Pantai Timur 2.0
RE-ii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

2 | TERMA RUJUKAN
PENGESAHAN TOR
Laporan TOR & ESI yang disemak telah dikemukakan kepada Ibu Pejabat JAS pada
25hb April 2022, dan telah disahkan pada 27hb Mei 2022 (Ruj: JAS.600-2/9/3 Jilid 2
(4))
25 April 2022
3 Mac 2022 21 Mac 2022
Pengemukaan 27 Mei 2022
Pengemukaan TOR Adequacy TOR & ESI yang Pengesahan TOR
TOR & ESI Check
disemak
3 | KEPERLUAN PROJEK
Peningkatan Permintaan 2-
Merangsang Ekonomi Tempatan
EHAcid
2-EHAcid digunakan dalam pengeluaran Kelebihan lokasi geografi dalam
pelincir sintetik, aditif minyak, pengimportan dan pengeksportan
penyejuk automotif, pemplastik,
penstabil dsb. 2-EHAcid adalah bahan kimia khusus
berkualiti tinggi yang dijangka akan
Peningkatan permintaan pemplastis PVB menyumbang kepada kapasiti eksport
dan penstabil PVC di rantau Asia-Pasifik
negara
(57% daripada permintaan global)
4 | PILIHAN PROJEK
Projek Tidak Dibangunkan Teknologi Alternatif

Boleh mengakibatkan potensi
kerugian daripada faedah tertentu: Sintesis Pengoksidaan
Elektrokimia 2- Bermangkin
ethylhexanol 2-ethylhexanol
Pelaburan modal yang tinggi
Faedah hiliran
Penyahhidrogen-
Faedah sector perkhidmatan Pengoksidaan
an Bermangkin
2-ethylhexanal
2-ethylhexanol
Faedah makroekonomi
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-iii

5 | HURAIAN PROJEK
KONSEP PROJEK
➢ Kilang baru bagi penghasilan 2-EHAcid (cadangan kapasiti

pengeluaran maksimum 36,000 MT/thn)
➢ Pengubahsuaian ladang tangki sedia ada
➢ Penggantian tangki sisa sedia ada dengan tangki sisa organic baru
➢ Penambahan lengan pemuatan baru
➢ Penambahan pam suapan
➢ Penggunaan infrastruktur dan utiliti sedia ada di Kompleks Oxo
PELAN SUSUNATUR PROJEK DAN KOMPONEN-KOMPONEN UTAMA
8 7
1 2 3 4 5 6
No. Komponen Utama No. Komponen Utama

1 Rectification Tower 5 Hydrogenation Reactor
2 Hexanal Tower 6 Oxidation Reactor
3 Stripping Column 7 Hexanal Buffer Drum
4 Hexanol Tower 8 Organic Residue Drum
RE-iv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

PENERANGAN PROSES
Reaksi Kimia
Penghidrogenan: C8H14O + H2 → C8H16O

(2-ethylhexenal) (hidrogen) (2-ethylhexanal)
Pengoksidaan : C8H16O + ½ O2 → C8H16O2

(2-ethylhexanal) (oksigen) (2-ethylhexanoic acid)
OFF-GAS DAN PENGURUSAN SISA
Dicampur di dalam tangka minyak

Sisa organik
Oxo 900 sedia ada di Kompleks Oxo
Off-gas yang mengandungi H2 Dwi-suar
Off-gas mengandungi O2 Pengoksida Terma
Air sisa dari proses Loji rawatan air sisa sedia ada
UTILITI PROJEK
Stim dan Kondensat

Elektrik
Stim HP
Voltan Rendah Stim LP Penyejukan
Voltan Tinggi Kondensat Mentah)
Air
Air suapan dandang Air pemadam kebakaran

Air pendingin Air terdemineralisasi
Air minum
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-v

AKTIVITI UTAMA PROJEK
Operasi
Pra-Pembinaan
Pembinaan
i. Penilaian Kesan Alam i. Mobilisasi i. Pengangkutan dan
Sekitar (EIA) penyimpanan bahan
ii. Jalan masuk mentah dan produk
ii. Peninjauan tapak iii. Kerja asasi
ii. Operasi kilang 2-
iii. Perjumpaan dengan iv. Kerja pembinaan EHAcid
pihak-pihak terlibat
v. Kerja mekanikal dan iii. Pengurusan sisa
iv. Pemuktamadan elektrikal terjadual
susunatur kilang dan
vi. Pengujian dan
kerja reka bentuk iv. Penyelenggaraan
pentauliahan
kilang dan peralatan
v. Kelulusan agensi vii. Demobilisasi
JADUAL PELAKSANAAN PROJEK

Pembinaan Projek dijangka mengambil selama sembilan belas (19) bulan (dari
November 2022 hingga Mei 2024), dan diikuti dengan pentauliahan (T&C) selama dua (2)
bulan.
Fasa Pra-Pembinaan
EIA, Pemuktamadan pelan susunatur dan reka bentuk kilang,
Kelulusan agensi, Pengilangan dan penghantaran peralatan
Fasa Pembinaan (17 bulan)

Kerja pembinaan, Pemasangan peralatan, Kerja-
kerja mekanikal dan elektrikal
T&C
(2 bln)
Nov Mac Jul Nov Mac Jul Nov Mac Jul

‘21 ‘22 ‘22 ‘22 ‘23 ‘23 ‘23 ‘24 ‘24
6 | PERSEKITARAN SEDIA ADA
PERSEKITARAN FIZIKAL
Geologi & Tanah

Topografi & Rupa Bumi
Tapak Projek didasari oleh
Tapak Projek berjulat dari 10-
sedimen aluvium Kuaternari
20m di atas paras laut. Ia telah
dan terletak di atas tanah
disediakan ke tahap platform.
gambut.
RE-vi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

GUNA TANAH DAN RESEPTOR SENSITIF
Guna Tanah Semasa Guna Tanah Zoning Cadangan Pembangunan
Guna tanah semasa di sekeliling tapak Projek Guna tanah zoning dalam radius 5km dari Draf Pelan Induk Bandar Pelabuhan Kuantan
terdiri terutamanya daripada industry, lot tapak Projek kebanyakkan telah diwartakan juga telah mencadangkan beberapa
kosong dan beberapa kawasan perumahan sebagai kawasan perindustrian dengan pembangunan utama di sekitar tapak Projek,
di kawasan barat daya. beberapa kawasan perumahan di selatan. seperti Bandar Pelabuhan Kuantan.
Land Use
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-vii

IKLIM
Suhu Rainfall
Purata suhu 24 jam tahunan: 26.8˚C Purata taburan hujan tahunan: 2,975.3 mm
Bulan paling panas: Mei (purata 27.8˚C) Purata hari hujan: 186 hari
Bulan paling sejuk: Dis & Jan (purata Bln paling banyak berhujan: Nov (23 hari)
25.5˚C) Bln paling sedikit berhujan: Feb (11 hari)
Kelembapan Relatif Angin Permukaan

Purata KR 24 jam tahunan: 84.8% Angin utama: Barat laut
KR Tertinggi: Nov (88.4%) Purata kelajuan tahunan: 1.6 m/s
KR Terendah: Jul & Aug (83.2%) Tempoh tenang: 0.3 m/s (17.8%)
HIDROLOGI DAN SALIRAN
River Catchment
Tapak Projek terletak di dalam kawasan tadahan Sg. Balok. Sungai yang terdekat, Sg.
Balok, adalah terletak kira-kira 0.9km ke arah barat dari tapak Projek, dan mengalir ke
Laut China Selatan.
Sistem Saliran
Air sisa yang dirawat akan dialirkan
ke saliran PKNP, kemudian ke Sg.
Balok.
Larian permukaan dari dalam ICS

akan dikumpulkan melalui saluran
saliran di tapak ke dalam kolam
tadahan di selatan tapak Projek. Ia
Legenda
kemudiannya akan dialirkan ke
Tapak Projek
dalam saliran air PKNP, dan
Sempadan ICS
mengalir ke Sg. Balok.
RE-viii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Kawasan Rawan Banjir
Pelan Tindakan dan Tebatan Risiko Banjir Sedia Ada
Strategi Risiko Banjir yang Program Ramalan dan Penilaian Risiko Bencana
ditetera di RTD Kuantan Amaran Banjir (PRAB) Banjir
2035 (Penggantian)
Legenda
AIR TANAH
Telaga air tanah
BH7
Persampelan pada tahun 2014 yang dipasang
BH8 pada 2001
• Semua BH diambil sampel
Telaga air tanah
kecuali BH9 disebabkan oleh BH9
yang dipasang
kerosakan telaga pada 2014
• Kompaun VOCs, SVOCs dan Tapak Projek
TPH tidak dikesan Sempadan ICS
BH14
• Tahap Fe dalam sampel BH2
BH6
dan B14 adalah lebih tinggi
daripada SSL (26,000 µg/l)
• Tapah As dalam sampel BH2
dan BH8 adalah lebih tinggi BH10 BH13
daripada SSLs (0.045 µg/l)
BH5A
Persampelan pada tahun 2020 BH1A
• Diambil daripada BH4 dan
BH4
BH5A
• Tahap logam berat semua
berada di bawah SSL BH2
BH3A
• Tahap VOCs di bawah 10 µg/l
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-ix

KUALITI PERSEKITARAN
A4
N2
N3
N1 N2 W7
W1
W5
W6
W2
W3 Kg.Selamat
Institut Latihan
Perindustrian
A1 Kuantan
Taman Perasing
A3 Kg. Berahi
W4 Balok Perdana
Legenda
Kg.Seberang
A2 Balok Sempadan ICS
Tapak Projek
Tahap Bunyi Bising Ambien

Kualiti Air
Tiga (3) lokasi telah dipilih untuk mengukur
Tujuh (7) sampel telah dikumpul dari Sg. Balok,
tahap bunyi bising ambien.
saliran PKNP dan saluran di dalam ICS.
Tahap bunyi bising yang direkodkan di semua
Persampelan kualiti air asas menunjukkan stesen pada waktu siang dan malam semuanya
bahawa secara amnya kualiti air berada dalam berada dalam had yang ditetapkan dalam the
had Kelas III NWQS. Guidelines for Environmental Noise Limits and
Control (3rd Ed.).
Kualiti Udara
Empat (4) lokasi telah dipilih untuk menjalankan pemantauan terhadap 23 bahan pencemar (PM10,
PM2.5, SO2, NO2, CO, O3, H2S, Cl2, HCl, NH3, VOCs dan logam berat).
Semua parameter adalah jauh di bawah had yang ditetapkan dalam MAAQS dan Ontario Ambient
Air Quality Criteria sepanjang tempoh pemantauan.
PENGURUSAN SISA
Pengurusan Sisa Pepejal

Pengurusan Sisa Terjadual
Kemudahan pelupusan sisa yang
Diuruskan mengikut Pelan
terdekat adalah Tapak Pelupusan
Pengurusan Sisa Terjadual sedia
Jabor Jerangau (~4.3km dari Tapak
ada
Projek)
RE-x Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

KEADAAN TRAFIK SEDIA ADA
Jalan masuk – Gebeng Bypass, Jalan Pintasan Kuantan dan Jalan Gebeng 1/11,
semua mempunyai Tahap Perkhidmatan (LOS) A.
PROFIL SOSIO-EKONOMIK
Projek ini terletak di kawasan Mukim Sungai Karang, yang mempunyai unjuran penduduk
sebanyak 69,312 pada tahun 2020.
Taburan Kumpulan Etnik Isi Rumah: 15,206

0.37% Tempat Tinggal: 17,030
4.03% 1.77%
1.24% Melayu
5.32% Cina
Kumpulan Umur
< 15 37.45%
India
15 – 64 60.24%
≥ 65 2.32%
Bukan Warganegara
Malaysia
87.27% Lain-lain
Umur Ketergantungan
Bumiputera Lain-lain Sg. Karang 66.01%
Zone of Influence (ZOI)

Zone of Influence (ZOI) yang meliputi dalam lingkungan 5km dari tapak Projek melibatkan kawasan
perumahan, institusi dan kemudahan awam.
Legenda
Sempadan ICS
Tapak Projek
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xi

KESIHATAN AWAM SEDIA ADA
13.1
Ahli Isi Rumah Yang Merokok 0.2%
%
0.2%
1.7%
Tidak Ya Ya
41.9% 58.1% 35.0% Tidak 84.7%
23.2%
Tiada tandas (0.2%)
Tandas lubang (13.1%)

Merokok
Dalam Tandas angkut/tong (0.2%)
Rumah Tandas curah (1.7%)
Tandas pam (84.7%)
7 & 8 | PENILAIAN IMPAK DAN LANGKAH MITIGASI
FASA PEMBINAAN
Aspek Alam
Impak Potensi Cadangan Langkah Mitigasi
Sekitar
▪ Mendirikan penimbunan atau

penghadang di sekitar kawasan
pembinaan
Penjanaan habuk buruan ▪ Semburan air secara kerap di
apabila zarah terangkat ke udara tapak pembinaan, terutamanya di
daripada pergerakan kenderaan sepanjang jalan pengangkutan
pembinaan dan aktiviti
▪ Tutup stok simpanan dan
pemindahan tanah yang minima
kenderaan yang membawa tanah,
pasir atau agregat
Kualiti Udara Magnitud Impak:
Tidak signifikan ▪ Mengenakan had laju di dalam
tapak pembinaan
▪ Peralatan diselenggara dengan
baik untuk penggunaan
▪ Elakkan putaan enjin dan

matikan peralatan apabila tidak
diperlukan
Peningkatan bunyi bising
secara sementara yang ▪ Peralatan atau aktiviti yanb dising
disebabkan oleh kerja hendaklah digantikan dengan
pembinaan dan pengerakan alternatif yang kurang bising
kenderaan ▪ Penyelenggaraan peralatan
▪ Mesin seperti kren hendaklah
dimatikan antara tempoh kerja
Bunyi Bising Magnitud Impak: / dikurangkan ke tahap
Tidak signifikan minimum
▪ Bahan pembinaan hendaklah
diturunkan
RE-xii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Aspek Alam
Sekitar
▪ Memastikan semua Langkah

mitigasi yang ditetapkan dalam
ESCP hendaklah dilaksanakan dan
▪ Pencemaran air sungai diselenggarakan
akibat air larian permukaan ▪ Sediment basin hendaklah
▪ Pelepasan atau tumpahan diperiksa dan diselenggara
produk petroleum dan sisa secara berkala
terjadual secara tidak sengaja
▪ Kawasan lapang mesti ditanam
boleh menyebabkan
semula selepas kerja-kerja
pencemaran saluran air
pembinaan
▪ Penjanaan kumbahan dan
sullage daripada kemudahan ▪ Penjagaan kebersihan untuk
Kualiti Air kemudahan tandas sepanjang
tandas sementara
masa
Magnitud Impak: ▪ Penyimpanan dan pengurusan
Rendah buangan terjadual hendaklah
dijalankan mengikut Peraturan
Kualiti Alam Sekeliling
(Buangan Terjadual) 2005
Sisa Pepejal
▪ Pengumpulan air dalam bahan Sisa Pepejal
buangan akan dijadikan ▪ Pembentukan dan pelaksanaan
tempat pembiakan perosak
Pelan Pengurusan Sisa yang
yang membawa penyakit
sesuai adalah digalakkan
▪ Sisa pembinaan mungkin akan
menyumbat longkang dan ▪ Pengurusan sisa mengikut
mengakibatkan banjir kilat hierarki pengurusan sisa: refuse,
semasa musim hujan reduce, reuse, recycle, recover dan
disposal
Sisa Terjadual
▪ Tumpahan atau kebocoran Sisa Terjadual
yang tidak sengaja akan ▪ Pengurusan sisa terjadual
Pengurusan merosot kualiti air sungai mengikut Guidelines for
Sisa terdekat Packaging, Labelling and
▪ Pembakaran haram boleh Storage of Scheduled Wastes di
mendedahkan reseptor Malaysia yang diterbitkan oleh JAS
berdekatan kepada bahan
pencemar berbahaya ▪ Sisa terjadual perlu diuruskan
mengikut Pelan Pengurusan Sisa
Magnitud Impak: Terjadual sedia ada
Rendah
▪ Kesesakan lalu lintas ▪ Memulakan talian hotline / saluran

▪ Keselamatan awam dan untuk aduan
gangguan kepada perjalanan ▪ Melaksanakan cadangan langkah
rutin harian mitigasi
▪ Pergolakan social daripada ▪ Melaksanakan Pelan Pengurusan
pekerja asing Lalulintas
▪ Peningkatan pendapatan
▪ Mengutamakan penduduk
kepada perniagaan dan industri tempatan untuk peluang pekerjaan
Sosio-Ekonomik perkhidmatan dan perniagaan
Magnitud Impak: ▪ Penglibatan awam yang berterusan
Rendah daripada Penggerak Projek
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xiii

FASA OPERASI
Aspek Alam
Sekitar
▪ Kepekatan oksigen dalam kebuk

pembakaran perlu diukur dan
dikawal dengan penukaran
aliran udara
▪ Pengoksida terma di Kompleks
Rawatan terma off gas yang Aroma perlu ditutup jika
mengandungi terutamanya kandungan gas serombong
oksigen dan hidrogen akan oksigen jatuh di bawah 2% vol.
ditukar kepada gas pembakaran ▪ Aliran gas asli perlu
seperti nitrogen oksida, yang dikurangkan kepada jumlah
boleh menjejaskan kesihatan minimum yang diperlukan untuk
penduduk berdekatan penunu gas asli semasa beban
Kualiti Udara
organic tinggi atau jumlah
Magnitud Impak: hidrogen off gas tinggi
Rendah ▪ Sistem suntikan wap hendaklah
dipasang untuk timbunan suar HP
▪ Penyelenggaraan pencegahan
bagi timbunan suar HP dan
komponen TOX Aroma hendaklah
dijalankan secara berkala
Tonggak Kelestarian BASF PETRONAS

Chemicals
▪ Mewujudkan papan pemuka
pengurusan tenaga bersepadu
▪ Tentukan laluan kepada sifar
bersih untuk mencapai sasaran dan
Pelepasan gas rumah hijau masukkan pelan ke dalam pelan
daripada pembakaran bahan pembangunan tapak
api fosil (gas asli) untuk ▪ Pengumpulan data daripada
penjanaan wap semua projek OPEX yang berkaitan
dengan perlindungan iklim di
Gas Rumah Magnitud Impak: bawah ‘satu payung’
Hijau Tidak signifikan ▪ Analisa strategik untuk setiap sisa
yang dihasilkan di tapak dari
perspektif 4R
▪ Semak semula prinsip pelupusan
sedia ada
▪ Fokus kepada pengurusan sisa
tidak berbahaya
Peningkatan tahap bunyi ▪ Sediakan enclosure yang sesuai

bising ambien daripada untuk peralatan yang bising
peralatan pemprosesan ▪ Penyelenggaraan peralatan
secara berkala
Magnitud Impak: ▪ Amalkan SOP
Tidak signifikan ▪ Penyediaan PPE kepada pekerja
Bunyi Bising
RE-xiv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Aspek Alam
Sekitar
▪ Pelan Tindak Balas Kecemasan

(ERP) ICS sedia ada hendalak
dikemaskini untuk menangani
semua scenario berpotensi yang
dikenalpasti dalam QRA
Risiko kebakaran, letupan atau ▪ Perubahan reka bentuk semasa
pelepasan bahan berbahaya, fasa kejuruteraan selepas EIA
seperti 2-ethylhexanoic acid, 2- perlu dianalisasi untuk
ethylhexanal, 2-ethylhexanol, menentukan keterukan potensi
hydrogen, n-butanal, heptyl bahaya
formate dan undecanol
Risiko ▪ Laporan keselamatan dan ERP
Magnitud Impak: hendaklah dikemaskini dan
Rendah diserahkan kepada Major Hazard
Division JKKP tiga bulan sebelum
pentauliahan
▪ Pelaksanaan sistem pengurusan
kesihatan dan keselamatan
yang berkesan
▪ Impak terhadap kesihatan

(terutamanya impak
▪ Langkah-langkah pencegahan
sekunder) ke atas komuniti
perlu diambil untuk mengawal
manusia yang berpunca
habuk buruan dan pelepasan
daripada impak utama ke atas
kenderaan semasa peringkat
fizikal (udara, air dan tanah),
pembinaan
biologi (haiwan dan
▪ Kawalan vektor penyakit dan
tumbuhan) dan persekitaran
takungan hendaklah dijalankan
▪ Impak terhadap kesihatan
semasa fasa pembinaan
utama yang terhasil daripada
▪ Pelan kontingensi seperti
Penilaian Impak pendedahan manusia kepada
penutupan loji dan pelan tindak
Kesihatan bahan pencemar udara
balas kecemasan mesti disediakan
melalui penyedutan
untuk menampung operasi Projek
yang tidak normal
Magnitud Impak:
Rendah
Penjanaan air sisa daripada

WWTP sedia ada dan kebocoran ▪ Pelepasan dari WWTP perlu
atau tumpahan secara tidak mematuhi had Standard B seperti
sengaja daripada sisa terjadual yang ditetapkan dalam Peraturan
akan menyebabkan pencemaran Kualiti Alam Sekeliling (Efluen
saluran air berdekatan Industri) 2009
▪ Operasi WWTP perlu mematuhi
Kualiti Air Magnitud Impak: Manual WWTP sedia ada
Rendah
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xv

Aspek Alam
Sekitar
Sisa Pepejal
▪ Pengumpulan air oleh bahan Sisa Pepejal
buangan akan menjadi tempat ▪ Pembentukan dan pelaksanaan
pembiakan perosak yang
Pelan Pengurusan Sisa yang
membawa penyakit
▪ Pembakaran terbuka secara
sesuai adalah digalakkan
haram akan menyebabkan ▪ Pengurusan sisa mengikut
pencemaran udara hierarki pengurusan sisa: refuse,
▪ Sisa pepejal mungkin akan reduce, reuse, recycle, recover dan
menyumbat longkang dan disposal
menyebabkan banjir kilat semasa
musim hujan
Sisa Terjadual
Sisa Terjadual ▪ Pengurusan sisa terjadual
Pengurusan ▪ Tumpahan atau kebocoran yang mengikut Guidelines for
Sisa tidak sengaja akan menyebabkan
Packaging, Labelling and
pencemaran kualiti air sungai
terdekat
Storage of Scheduled Wastes di
▪ Pembakaran secara haram akan Malaysia yang diterbitkan oleh JAS
menyebabkan pencemaran ▪ Sisa terjadual perlu diuruskan
udara mengikut Pelan Pengurusan Sisa
Magnitud Impak: Terjadual sedia ada
Rendah
▪ Pencemaran udara dan bau dari

kilang ▪ Langkah keselamatan yang
▪ Risiko kebakaran berksean di kawasan kilang untuk
▪ Kesesakan lalu lintas mengelakkan kemalangan
▪ Keselamatan awam
▪ Pelaksanaan cadangan langkah
▪ Peningkatan pendapatan
mitigasi
kepada perniagaan dan
perkhidmatan sekitar ▪ Pengunaan proses mesra alam
▪ Penambahan dan dalam kilang
penambahbaikan infrastruktur ▪ Penetapan kuota untuk
Sosio-ekonomik ▪ Penggalakkan penyediaan pekerjaan tempatan
perkhidmatan awam
▪ Program CSR Bersama penduduk
Magnitud Impak: / institusi berdekatan
Rendah
PENGABAIAN PROJEK
Sekiranya Projek terbengkalai, langkah-langkah berikut hendaklah diambil:
Kemudahan
Sisa terjadual
tapak
diuruskan oleh
sementara
kontraktor
mestilah
berlesen JAS
dirobohkan
Pengemukaan Sisa pepejal
Rancangan dilupuskan di
Pengabaian tapak
Projek kepada pelupusan
JAS Pahang yang disahkan
RE-xvi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

9 | PELAN PENGURUSAN ALAM SEKITAR (EMP)
FASA PEMBINAAN
N2
N1 N3
W3
W5
W6
W4
Legenda
W1
Sempadan ICS
W2 Tapak Projek
Kualiti Air
Bunyi Bising
Pemantauan Prestasi – Pemantauan mingguan
Pemantauan Impak – Pemantauan suku
atau selepas hujan > 12.5mm untuk semua
tahunan di tiga (3) lokasi pemantauan sedia ada
tebatan ESCP di tapak
ICS (N1 ke N3)
Pemantauan Pematuhan – Pemantauan
bulanan atau selepas hujan > 12.5 mm bagi
pelepasan silt trap atau sediment basin;
Pemantauan suku tahunan bagi tangki septik Audit Alam Sekitar
sementara
Pemantauan Impak – Pemantauan suku Dicadangkan untuk dijalankan empat (4) bulan
tahunan di enam (6) lokasi pemantauan sedia sekali
ada ICS (W1 ke W6)
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-xvii

FASA OPERASI
A2 N2
A3
N1 N3
A1 W3
W5
W6
W4
W1 Legenda
Sempadan ICS
W2
Tapak Projek
Kualiti Air Bunyi Bising

Pemantauan Prestasi – Pemantauan setiap minggu untuk WWTP
Pemantauan Impak –
Pemantauan Pematuhan – Pemantauan bulanan untuk
Pemantauan suku tahunan di
pelepasan dari WWTP
tiga (3) lokasi pemantauan
Pemantauan Impak – Pemantauan suku tahunan di enam (6)
sedia ada ICS (N1 ke N3)
lokasi pemantauan sedia ada ICS (W1 ke W6)
Kualiti Udara
Pemantauan Pematuhan – Pemantauan suku tahunan di cerobong Citral TOX (XX-9680)
Pemantauan Impak – Pemantauan suku tahunan di tiga (3) lokasi pemantauan sedia ada ICS (A1 ke A3)
Audit Alam Sekitar
Dicadangkan untuk dilaksanakan setiap tahun
10 | KESIMPULAN KAJIAN
Fasa Pembinaan
Kesan terhadap kualiti udara dan bunyi dijangka tidak signifikan, manakala kesan
pembinaan Projek terhadap kualiti air, pengurusan sisa dan sosio-ekonomi dijangka
rendah
Fasa Operasi
Kesan terhadap gas rumah hijau dan bunyi dijangka tidak signifikan, manakala kesan
operasi Projek terhadap kualiti udara, kualiti air, pengurusan sisa, risiko, kesihatan dan
sosio-ekonomi dijangka rendah
RE-xviii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

01 INTRODUCTION
Section 1
INTRODUCTION
SECTION 1 : INTRODUCTION
1.1 PROJECT TITLE

The proposed development is known as:
“Proposed 2-Ethylhexanoic Acid II Plant in Existing Integrated Chemical Site of

BASF PETRONAS Chemicals, Gebeng, Kuantan, Pahang”
Hereinafter referred to as “the Project”.
1.1.1 Project Background
BASF PETRONAS Chemicals Sdn. Bhd. is a joint venture between BASF SE of

Germany, one of the world’s largest chemical companies, and Malaysia’s state-
owned Petroleum Corporation Petroliam Nasional Berhad (PETRONAS).
Incorporated in August 1997, the company operates an Integrated Chemical Site (ICS)
situated at the Gebeng Industrial Estate, Pahang. Currently, there are 14 fully
integrated plants within the ICS, and key products include acrylic monomers, oxo
products, highly reactive polyisobutene, aroma ingredients and 2-ethylhexanoic acid.
The DEIA for the first 2-EHAcid plant was approved on 4 March 2015 (Ref. No.:
AS(PN)35/119/000/071 Jilid3(32) as attached in Appendix A). It was later
commissioned in Q4 of 2016, with a total annual capacity of 30,000 MT. It consists of
an open-air production plant and a production tank farm and shares some of the
treatment and utilities facilities within the ICS compound, namely:
• The centralized wastewater treatment plant;
• The control room, switch room and QC laboratory at the Butanediol (BDO)
complex; and
• The product loading and packaging facility at the ICS.
The approved maximum annual production capacity of existing 2-EHAcid plant is

30,000 MT. Over the years, through process optimization and by introducing
additional chilling capacity, the production efficiency and output had improved, and
the existing 2-EHAcid plant can achieve a maximum total annual production
capacity of 36,000 MT.
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA 1-1

The Project, which is a second 2-EHAcid plant, will be constructed right next to the
existing 2-EHAcid plant. Since the Project will be a mirror plant of the existing one,
the facilities, where the anticipated maximum total annual production capacity will
also be 36,000 MT. The production capacity of 2-EHAcid from both plants is expected
to cater for the Project Proponent’s customers increasing demands within the Asia-
Pacific region.
Previously, the existing 2-EHAcid plant channels its off-gas and process wastewater
to the BDO boiler. However, the BDO boiler is now no longer in operation since June
2021. Hence, the hydrogen off-gas are flared directly, and oxygen off-gas is currently
being vented directly to the atmosphere. The oxygen-rich off-gas is planned to be
sent to the thermal oxidizer at the Aroma complex once the piping to the Aroma
complex is completed. Meanwhile, the process wastewater from the existing 2-
EHAcid will be channeled directly to the wastewater treatment plant.
1.1.2 Project Location
The Project site is located on part of Lot 139, Phase III of Gebeng Industrial Estate
(GIE) in District of Kuantan, Pahang Darul Makmur. The GIE is zoned for chemical
and petrochemical industries and is strategically located within 5km from the
Kuantan Port.
The location of the Project site is shown in Figure 1-1 and Table 1-1 shows the
coordinates of the Project site. It is located within BPC’s existing Integrated Chemical
Site (ICS) and will occupy a total area of approximately 0.088 hectares (0.217 acres)
(Figure 1-2). Plate 1-1 shows the photo of the existing condition of the Project site
taken during site reconnaissance on 15 December 2021.
Table 1-1 Coordinates of the Project Site

Point Latitude Longitude
A 103° 22' 04.39" E 03° 59' 05.11" N
B 103° 22' 05.56" E 03° 59' 05.48" N
C 103° 22' 05.95" E 03° 59' 04.17" N
D 103° 22' 04.79" E 03° 59' 03.81" N
1-2 Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Plate 1-1 Project Site
Source: BASF PETRONAS Chemicals Sdn. Bhd. (2021)
The Project site is accessible via East Coast Expressway, Lebuhraya Pantai Timur
(LPT), through Jabor exit, Gebeng Bypass and Jalan Gebeng 1/11.
1.2 PROJECT PROPONENT AND QUALIFIED PERSONS
1.2.1 Project Proponent
The Project Proponent is BASF PETRONAS Chemicals Sdn. Bhd.
Enquiries about the Project may be direct to:
BASF PETRONAS Chemicals Sdn. Bhd.

Jalan Gebeng 2/1,
Kawasan Perindustrian Gebeng,
26080 Kuantan,
Pahang Darul Makmur.
Tel.: +609-5855377
Fax.: +609-5835541
Email: MuhdFK@basf-petronas.com.my
Contact Person : Muhammad Firdaus bin Kamaruddin

Position : General Manager

1.2.2 EIA Consultant
The Consultant undertaking the EIA study is:
ERE Consulting Group Sdn. Bhd.

(Member of the Aurecon Group)
9, Jalan USJ 21/6,
47630 Subang Jaya,
Selangor Darul Ehsan.
Tel : 03-8024 2287

Fax : 03-8024 2320
Email : tyc@ere.com.my
Contact Person: Mr. Tan Yen Chen (EIA Team Leader)
1.3 LEGAL FRAMEWORK

The Project is classified under the following prescribed activity in the Second
Schedule of the Environmental Quality (Prescribed Activities) (Environmental
Impact Assessment) Order 2015:
Second Schedule
Activity 6(d) Petrochemicals: Production capacity of each product or combined
product of 50 tonnes or more per day
An EIA report is required to be submitted to the Director General of Environmental

Quality for review and approval prior to the Project implementation.
1.4 CONFORMANCE WITH POLICIES AND

DEVELOPMENT PLANS
1.4.1 Twelfth Malaysia Plan
One of the priorities in driving Malaysia’s economy will be through the

manufacturing sector. As Malaysia progresses towards embracing the National
Fourth Industrial Revolution (4IR) Policy, the manufacturing sector will continue to
focus on shifting into higher value-added, diverse and complex products. Among
the key industries that will drive growth are electrical and electronics products,
chemicals and chemical products, and aerospace. By 2025, this sector is expected to
expand by 5.7% per annum led by the export-oriented subsector (Chart 1-1).

Chart 1-1 Gross Domestic Product by Kind of Economic Activity, 2020 – 2025
The development of this Project is complementary to the focus area of the Twelfth
Malaysia Plan, as it has the potential to attract and spur quality investments by
meeting their customers’ needs within the Asia-Pacific region. The product, 2-
EHAcid, is also a specialty chemical which are less vulnerable to market downturn
where margins are more attractive. This is also part of the government’s strategy to
ensure that the oil and gas subsector within the country is sustainable and
progressive.
1.4.2 Rancangan Fizikal Negara 4
This plan has outlined the spatial development for Pahang to manage growth areas
more efficiently as well as facilitate the application of any proposed development to
the future land use development. In order to stimulate balanced and strong economic
growth, the role of the city as a catalyst for development needs to be strengthened
and integrated development in rural areas needs to be encourage.
The East Coast Conurbation area (Kuantan-Gambang-Pekan) has been identified as

one of the important economic catalyst hubs in the Region as well as in the national
context. The proposed Project will further intensify the development in the East
Coast Conurbation area, where the main focuses for industrial estates are on
petrochemical industries, biotechnology industries, technology parks, electrical and
electronic industries, ICT, renewable energy sector and the halal hub (Chart 1-2).
Chart 1-2 Pahang Spatial Development Framework
Source: Rancangan Fizikal Negara 4 (2022)

1.4.3 Rancangan Struktur Negeri Pahang 2050
The development of this Project is in line the principle listed in the Rancangan Struktur
Negeri Pahang 2050, which is Teras 2: Ekonomi Berdaya Maju.
One of the strategies listed under Teras 2, which is Strategy DI1-S1, is to develop
Pahang into a successful industrial hub in the East Coast region. An implementation
initiative for this strategy is to encourage high-tech industrial activities that brings
increased value products, such as the automotive industry, chemical and
petrochemical industry, oil and gas industry, electric and electronics industry,
renewable energy industry, biotechnology, medical equipment and pharmaceutical
industry, and the halal hub. These industries are expected to be the driving force for
Pahang to move towards its goal in becoming a thriving industrial hub.
1.4.4 Rancangan Tempatan Daerah Kuantan 2035 (Penggantian)
The Project is in line with Strategy 4.1 of the Rancangan Tempatan Daerah Kuantan 2035
(Penggantian) which is to strengthen Kuantan as the main city and trade centre of the
East Coast region. The Gebeng Integrated Petrochemical Complex (GIPC), which is
where the Project is located at, is part of the Kuantan Port City (KPC) development,
and one of the suggested methods to achieve this strategy is via the development of
KPC.
Hence, the of this Project will support the establishment of KPC so that it can pave a
way for Kuantan to become an integrated terminal and logistics hub for
petrochemicals, palm oil, automotive markets as well as major industrial and
manufacturing zones.
1.4.5 East Coast Economic Region Master Plan 2.0
The East Coast Economic Region (ECER) is an economic development region based
on the east coast of the Peninsular Malaysia which covers Kelantan, Terengganu,
Pahang, and the district of Mersing in northeast Johor. ECER has a Master Plan which
aims to identify projects and programmes to reduce regional socio-economic
disparities, eradicate poverty and improve income and wealth distribution in a
sustainable manner.
The ECER Master Plan 2.0 aims to achieve new growth targets with greater focus on
downstream activities and the strengthening of its existing industrial parks, and the
introduction of new ones to attract more private investment. This strategy will
increase export value for downstream products, spur greater job creation and
opportunities for SMEs, reduce dependency on imported products, and optimize
natural resources.

The Project is situated in the Gebeng Integrated Petrochemical Complex (GIPC)
which is part of the Gebeng Industrial Estate (GIE). The GIPC is a self-contained
complex comprising propylene-based petrochemical plants and centralized utility
facilities. It is one of the facilities under the oil, gas and petrochemical (OGP) sector
in ECER, and the target for this sector by 2025 is to obtain RM 3 billion of estimated
private investment, create 1,300 job opportunities with a total of 70 entrepreneurs
(Chart 1-3).
The launch of the Project is in line with the ECER Master Plan 2.0 where it focuses on
the production of specialty chemicals which can attract potential investors and
increase export value for downstream products.
Chart 1-3 Target for Oil, Gas & Petrochemical Industry in East Coast
Economic Region
Source: ECER Master Plan 2.0 (2018)

1.5 SCOPE OF EIA STUDY
The EIA report is comprised of ten sections as follows:
• Introduction
• Terms of Reference of EIA Study
• Statement of Need
• Project Option
• Project Description
• Existing Environment
• Evaluation of Environmental Impacts
• Proposed Mitigation Measures
• Environmental Management Plan
• Study Findings

This page has been intentionally left blank.

South
Terengganu China
Sea
Pahang !
Gebeng
!
Balok
Beserah
!
B
A
C
D
2
Gate
BPC
1
Gate
BPC
Ja la
nG
eb
en
g
1/
11
o
LEGEND Date 20-06-2022
Project Site Label X-Coordinate Y-Coordinate Project No EJ 727
Major Road A 103° 22' 04.39" E 03° 59' 05.11" N Produced by HMZ
Revision A
1:7,000 @ A4 size paper Minor Road B 103° 22' 05.56" E 03° 59' 05.48" N
0 100 200
C 103° 22' 05.95" E 03° 59' 04.17" N Project Location Plan
Meters
D 103° 22' 04.79" E 03° 59' 03.81" N FIGURE 1-1
Coordinate System:
GCS WGS 1984
Map Units: Degree
Disclaimer: This map is produced solely for its intended purpose only. All reasonable care has been taken to ensure that the information presented here is accurate, subject to the availability and quality of data sources used. There is however no guarantee that this map is free from errors or omissions. Its use for any other purposes is therefore at the sole risk of the user.
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 1-1 Location Plan)
Source: ERE Consulting Group (2022), Maxar
30 250 35 250 35 250 30 71
30
A800 B800 C800

D800
150
30
A700 B700 C700 D700

150
30
A600 B600 C600

D600
150
E=651.000
E=936.000
30
N=1704.000 9.10 9.10 N=1704.000 N=1704.000 9.10

6th STREET 7.98
CULVERT TEMPORARY DRAIN 1:600
7.95
7.98 8.38
8.01 C519 HR-PIB Flare Gate barrier N=1690.000

8.47
E=920.000
C
C
TEMPORARY DRAIN 1:800
C500 D500
DOOR FAP TABLE
NOTE-1
Glass / Wooden
Partition
C575
DOOR
Server
Generator Control
DCS
Burner Control
Turbine Control
Marshalling
Future Space
Future Space
DOOR
LDB01
C517 BF3-Storage
N=1650.00
FUTURE
DUMMY
N=1652.600
FUTURE
FUTURE
FUTURE
DUMMY
FUTURE
B500
O/G
O/G
DUMMY
O/G
I/C 2
I/C 2
E=9361.000
11kV SWITCHGEAR
DUMMY
BPT
E=691.900
E=763.800
B/C
E=651.000
AVENUE C
BPT
DUMMY
ENTRANCE GATE
I/C 1
I/C 1
O/G
DUMMY
O/G
O/G
FUTURE
C512 SR/RR
BATTERY ROOM
FUTURE
DUMMY
FUTURE
FUTURE
FUTURE
9.35
Q
C515 Production Building
150
A500
A500 N
C574
C514 FFP
25000.0000
749.6728
500.0000
Gate barrier
N=1600.00
CULVERT
5500.0000
5500.0000
8000.0000
N=1600.600
7499.5667
E
A
G
1
S
T
E
T
A
G
S
D E
S
T
A
G
R
D
2
N 3
Sluice Gate
E
S
T
A
G
1
S
4999.8500
E
T
A
G
S E
S
T
A
G
2
N
D 3
R
D
S
E
T
A
G
TK3503
1
S
T
E
G E
A
G
4999.8500
T
A
S
2
N
D S
T
3
R
D
TK3515 TK3535
4050.1012
3100.3018
TK3530
C572
3399.5977
2175.0965
C573
5149.6997
C510
Tank Farm
2300.0000
TK3526 TK3546 TK3504
6000.0000
3000.0000
N=1550.00
E=670.000
E=775.000
10600.0000
8699.5967
8800.2287
4999.8637
7.83
C505 Truck Loading
7.94
E=651.000
E=936.000
7.74
30
7.71
CULVERT CULVERT
N=1524.000 8.94 N=1524.000 N=1524.000 8.94

5th STREET
7.60
7.59
8.34 7.98
N=1500.00
D400
C400
B400
150
A400
DOMESTIC WATER TANK

2" OUTLET
2" INLET
SUMP PIT
CHILLER/
EXISTING ROAD
HEATER 1
WAREHOUSE
CENTRAL
AREA
A410
CHILLER/
HEATER
CHILLER/
HEATER 2
Premix
68.2 M XSurface
16.2 M
Drain
WAY
g Main
WALK
1 2 3 4 5 6 7 8 9 10 Existin
30
CAR PARK
Existing Main Drain

WALKWAY
EXISTING ROAD
A300
LOGISTICS
AREA
B300
A300 C300
150
Maintenance
7x15m
TBPR
LOGISTICS D300
30
FALL 1 : 500
DP M.SENGR'S
TO STANCHION
DETAILS
1M x 1M CONC. SUMP
EAVE ABOVE
DESTILLATION
COLUMN
STATIC F611
LOAD : 1.5 TON
D = 273í
H = 9720 DEHYDRATOR /GUARD BED UNIT
F361
EL EL
STATIC STATIC
í375
H = 3000
LOAD : 2 TON LOAD
H = 3260
: 2 TON
DC
F371
+0.50m
150í
REFIGERATION UNIT DRAIN PIPE STEEL
STAINLESS F641B
F381 CAST INTO PLINTH
F611
REBOILER UNIT STATIC
STATIC LOAD : 10 TON
CO2 LOAD : 1 TON H = 9000 NH3 COMPRESSOR CO2
H = 1600 STATIC
LOAD : 5 TON
H = 2000
F335
F410A F641A
F611
C200
EL EL
REINFORCED
CONCRETE FLOOR
TO ENGR'S DETAILS
DP
A200 D200
WAREHOUSE
150
A245
MOTOR
WAREHOUSE
AA/AE OXO/SYNGAS
TVE JLM
EXIST. TEMPORARY BUILDING EXIST. TEMPORARY BUILDING
FEMALE
UPC
30
A100
ADMIN.
150
150#-600# 150#Type526 1D2
N4
N1 L1
V1
N3 D1 B
MH N2
L2
B100

2-EHAcid Plant II Production Existing 2-EHAcid Plant Project No EJ 727
N Site (Project Site) I Production Site
Produced By HMZ
Additional Components and Revision -
Supporting Equipment
Member of the Aurecon Group
Existing ICS Buildings and

0 100 200
Components to be Used
During Project Operation
Overall Layout Plan
Boundary of Integrated
FIGURE 1-2
Meter
Chemical Site (ICS)
Source: ERE Consulting Group Sdn Bhd
\\192.168.1.13\ere data\ERE Projects\EJ 727 2- Ethylehaxanoic Acid BASF\Drawings\1. TOR\Fig 2-2 Overall Layout Plan.dwg
02 TERMS OF REFERENCE
Section 2
TERMS OF REFERENCE
SECTION 2 : TERMS OF REFERENCE
2.1 INTRODUCTION
The Terms of Reference (TOR) and Environmental Scoping Information (ESI) Report
was submitted to the Department of Environment Headquarters (DOE HQ) on 3rd
March 2022 and the TOR Adequacy Check (TORAC) meeting was held on
21st March 2022.
Subsequently, the Revised TOR & ESI Report was submitted to DOE HQ on
25th April 2022, following which the TOR was endorsed by DOE HQ on 27 May 2022
via endorsement letter reference JAS.600-2/9/3 Jilid 2 (4), attached in Appendix B.
2.2 ENDORSEMENT OF TERMS OF REFERENCE

Table 2-1 and Table 2-2 lists down the various comments received during the TOR
review, and the EIA Consultant’s and Project Proponent’s corresponding responses.
The comments received consists of:
a) Written Comments from Agencies, Technical Departments and Appointed

Individuals and Official TORAC Meeting Minutes from DOE HQ as attached
in Appendix B1 (Table 2-1)
b) Conditions stated in DOE HQ’s TOR Endorsement Letter (Table 2-2)
The EIA study has been carried out taking into consideration all the comments
received and conditions contained in the TOR endorsement letter.

Table 2-1 Written Comments from Agencies, Technical Departments and Appointed Individuals and Meeting Minutes
Reply from Project Reference in the EIA DOE
No. Items in TOR Proponent / EIA Consultant Report Comments
Bil. Perkara dalam “TOR” Maklumbalas Penggerak Rujukan dalam Ulasan
Projek / Jurunding EIA Laporan EIA JAS
Bahagian Penilaian, JAS HQ
Guidelines and environmental legislation: EIA Guidelines for Petrochemical
The preparation of EIA also
can be listed and referenced for this proposed Project. Section 7.1
refers to the EIA Guidelines for
1 Introduction
Petrochemical published by
Guidelines and environmental legislation: EIA Guidelines for Petrochemical boleh pg. 7-1
DOE.
disenaraikan dan dirujuk bagi cadangan projek ini.
The Project will not involve
additional construction of new
raw material and product tank,
and all the processess are
above ground. As such, the
potential of groundwater
There is need to conduct studies for groundwater quality and compare with contamination from the Project
groundwater quality standards published by the Department of Environment. is very low. Thus, the Section 6.6
2 Consultant in the opinion that Groundwater
Keperluan menjalankan kajian bagi kualiti air tanah dan dibandingkan dengan groundwater contamination pg. 6-22 to 6-27
standard air tanah yang dikeluarkan oleh Jabatan Alam Sekitar. study is not required.
Groundwater sampling
conducted by the Project
Proponent only include
parameters such as heavy
metals, VOCs, SVOCs and

TPH. Hence, they are only able
to be compared with the Dutch
Intervention Values (DIV) and
Malaysian Recommended Site
Screening Levels for
Contaminated Land for
Tapwater (SSLs).
There was no statement regarding the placement of workers during the Table 5-9 Activities
construction phase. The construction workers will During Construction
3
be accommodated offsite. Stage
Tiada kenyataan berkenaan penempatan pekerja semasa fasa pembinaan. pg. 5-29
Section 7.5.1 Air
Quality
pg. 7-23 to 7-47
The impacts assessment for air,

The study should take into account the cumulative impact of critical water and Section 7.5.4 Risk
water and risk assessment
air issues including risk assessment due to the increase in plant capacity. pg. 7-54 to 7-80
have taken account the
4
cumulative impact from the
Kajian hendaklah mengambil kira cumulative impact bagi isu kritikal air dan udara Appendix H
existing plant and also from
termasuk risk assessment kerana pertambahan kapasiti kilang. Quantitative Risk
the Project.
Assessment
Section 7.5.5 Water

Quality

pg. 7-81 to 7-88
Table 5-1 Key
Components for
Identify the infrastructure, equipment and facilities that will be involved in List of equipment for the Project and Existing
existing and new proposed development. Project site (new plant) and 2-EHAcid Plant
5 upgrade of existing plant is pg. 5-5
Mengenalpasti infrastruktur, peralatan dan kemudahan yang akan terlibat dalam included in the EIA.
cadangan pembangunan yang baru dan sediada. Figure 5-1 Project
Layout Plan
pg. 5-33
To inform Pahang DOE on changes to be implemented to the existing facilities.
The Project Proponent has
6 -
taken note.
Memaklumkan kepada JAS Pahang bagi perubahan fasiliti sediada.
3rd Party Environmental
Compliance Audit was carried
out on 19th to 20th January
Submit the latest 3rd party audit report and take into account of the issues 2022. No non-compliance and
raised in the report in the EIA study. observations were raised in
7 accordance with the DEIA -
Mengemukakan laporan 3rd party audit terkini dan mengambilkira isu dibangkitkan approval conditions. Eight
dalam laporan tersebut dalam kajian EIA. good management practice
were also identified in this
audit.

JAS Gebeng has also carried
out an audit on 23/3/2022.
Statement of need should be evidenced by statistical data or other data related
Section 3.1.1
to the increase in demand in the use of 2-EHAcid. The increasing demand in 2-
Increasing Demand in
8 EHAcid is detailed with data
2-EHAcid
Statement of need perlu dibuktikan dengan data statistik atau lain-lain data berkaitan in Section 3.1.1
pg. 3-1 to 3-2
pertambahan permintaan dalam penggunaan 2-EHAcid.
JKR Pahang's officer has been
engaged about the Project
details and the officer is in the
opinion that more information
on the existing traffic is
required before the
To refer to the relevant agency for the need on Traffic Impact Assessment. department can make a
Section 6.9 Existing
decision. The existing traffic is
9 Traffic Condition
Keperluan untuk merujuk kepada agensi yang berkaitan bagi Traffic Impact referred from secondary data
pg. 6-72 to 6-74
Assessment. and addressed in Section 6.9 of
the EIA report. According to
the study, the current level of
service for Gebeng Bypass,
Jalan Pintasan Kuantan and
Jalan Gebeng 1/11 all have
LOS A.

The WWTP design is based on
the incoming COD loading,
where the maximum COD
concentration that can be
Section 5.3.4 Existing
treated by the WWTP is 600 kg
Wastewater
COD/h. The current
Treatment Plant
utilization of the existing
Proof that additional 0.4 m3/hr of wastewater from the new plant can be pg. 5-21 to 5-26
WWTP is about 93.5% with
treated in the WWTP.
10 maximum contribution of
Table 5-5 Wastewater
COD load from the existing
Pembuktian tambahan 0.4 m3/hr bagi loji baru dapat mampu dirawat oleh WWTP. Generation from
sources within the ICS. The
Plants Within the ICS
maximum COD load expected
pg. 5-22
from the Project is only
4kgCOD/h, which contributes
to about 0.67% COD loading to
the total COD load that the
existing WWTP can treat.
The Consultant is aware that
the Project site is located Section 6.5.3.1
Scope of flood risk in the development area should be taken into account. within the flood risk area. Existing Flood Risk
11 However, as the increase of Mitigation and
Mengambilkira skop risiko banjir di kawasan pembangunan. wastewater generation from Action Plans
Project (0.04 m3/hr) is small, pg. 6-13 to 6-16
there is no potential for the

Project’s activities to cause
flooding to the surrounding.
Nonetheless, the Consultant

has checked with JPS Pahang
and was informed that there
were currently no flood
mitigation programs
specifically for Sg. Balok. Even
so, existing flood risk
mitigations and action plans to
mitigate flood issues on both
national and regional levels are
detailed.
Chart 5-2 Overall
Mass Balance for
Average Production
Submit a mass balance for each process involved, detailing the quantity of
Capacity of 30,000
input, output, products, raw materials, as well as waste emissions.
Overall mass balance can be MT/a
12
referred in Charts 5-2 and 5-3. pg. 5-7
Mengemukakan mass balance bagi setiap proses terlibat bagi memperincikan kuantiti
input, output, produk dan bahan mentah serta pelepasan buangan.
Chart 5-3 Overall
Mass Balance for
Maximum

Production Capacity
of 36,000 MT/a
pg. 5-9
The framework of the
abandonment plan for the
Project is outlined in Section
Submit an abandonment plan for the proposed Project. Section 8.5 Project
8.5.
13 Abandonment
Mengemukakan abandonment plan bagi cadangan projek. pg. 8-32 to 8-34
Abandonment Plan for the
Project will be provided
during the EMP stage.
Oxygen and hydrogen off
gases from the proposed
Project will be sent to the
thermal oxidizer and flare
Review the need of air pollution controls including the stacks used in existing
system respectively. Section 5.3.5 Air
and new facilities.
Pollution Control
14
Flare and thermal oxidizer are Systems
Menyemak keperluan peralatan kawalan udara termasuk cerobong yang digunakan di
in fact systems used to control pg. 5-27
dalam fasiliti sediaada dan baru.
air pollution by burning
unwanted gases or destroying
hazardous air pollutants and
converting them into

oxides (NOx), CO2 and steam.
Based on engagement with JPS
officer, it was informed that Section 6.5.4
there is fishing area and caged Beneficial Use
fish farming at the mouth of pg. 6-17 to 6-21
Sg. Balok. Sg. Balok
conservation program is also Appendix D DOF
being implemented in 2016 Pahang Response
until now, and JPS Pahang Letter
would like to maintain the
Engage with the Department of Irrigation and Drainage for Pahang State. cleanliness of the river. Pantai Section 6.7.2 Water
15 Balok is also a recreational area Quality
Menjalankan sesi libat urus bersama Jabatan Pengairan dan Saliran Negeri Pahang that needs to be taken care of. pg. 6-42 to 6-67
Based on DOF Pahang’s input, Section 7.5.5 Water

the nearest aquaculture Quality
activity is a shrimp farm, pg. 7-80 to 7-88
which is located at about 8km
away from the Project site Section 8.4.5 Water
(Section 6.5.4 and Appendix Quality
D). pg. 8-22

Baseline water quality
monitoring for the nearby
PKNP drainage and Sg. Balok
is also conducted and the
monitoring results can be
referred in Section 6.7.3.
The impact of worst-case

scenario discharge on the river
quality is assessed using a
mixing model to determine the
effect of discharge into Sg.
Balok. The assessment data is
compared with the baseline
results, and then mitigation
measures are formulated to
reduce the impact of the
Project to Sg. Balok.
EIA approval conditions and
Review and refer to the conditions of EIA approval that has been issued to the related approvals have been Appendix A Existing
project proponent for the same proposed Project, in addition to any approval referred in the TOR and will be 2-EHAcid Plant DEIA
16
that has been obtained from DOE. referred in the EIA study. The Approval
approval conditions can be
referred in Appendix A and

Menyemak dan merujuk syarat kelulusan EIA yang pernah dikeluarkan kepada the appealed condition for Appendix A1
penggerak projek bagi cadangan projek yang sama selain menyatakan sebarang noise limits can be referred in Appealed Noise
kelulusan yang pernah diperolehi daripada JAS. Appendix A1. Limits
Appointed Individual (Ir. Dr. Zulkifli Abdul Rashid)
In Table T-5, the consultants informed the potential hazards from the study
plant are the risk of fire and explosion from the pipeline and storage of 2-
EHAcid, hydrogen, Oxo oil, ethanal and n/Isobutanol. However, we found
that the production process of 2-EHAcid involves 4 stages namely
a) Selective hydrogenation of 2-ethylhexenal (Ehexenal) to 2-ethylhexanal
Table 7-25 List of
(Ehexanal);
Scenarios
b) Purification of EHexenal;
pg. 7-59 to 7-60
c) Oxidation of Ehexenal to 2-ethylhexanoic acid (EHAcid); and
d) Purification of the finished product Level of consequences for all
Appendix H
1 Involving hydrogenation reactor, hexanol tower/column, oxidation reactor, related process units are
Quantitative Risk
please refer to the detailed information of the components in Table 2-2. included in Table 7-25.
Assessment (1.4.4.2
Therefore, the consultant is required to include all operating units as in Table
Risk Classification)
2-2 that have the potential to result in a major hazard accident within the scope
pg. 20 to 22 of
or method for risk assessment.
Appendix H
Di Table T-5, pihak perunding memaklumkan potensi bahaya dari loji kajian adalah
risiko kebakaran dan letupan dari pipeline and storage of 2-EHAcid, hydrogen, Oxo
oil, ethanal and n/Isobutanol. Walaubagaimanapun, kami mendapati proses
pengeluaran 2-EHAcid melibatkan 4 peringkat iaitu

a) Selective hydrogenation of 2-ehtylhexenal (Ehexenal) to 2-ethylhexanal
(Ehexanal);
b) Purification of EHexenal;
c) Oxidation of Ehexenal to 2-ethylhexanoic acid (EHAcid); and
d) Purification of the finished product
Membabitkan hydrogenation reactor, hexanol tower/column, oxidation reactor, mohon
rujuk maklumat terperinci komponen di Table 2-2.
Oleh yang pihak perunding dikehendaki memasukkan kesemua unit operasi seperti
dalam Table 2-2 yang berpotensi mengakibatkan kemalangan bahaya besar di dalam
skop atau method penilaian analisa risiko
From comment 1 above, the consultant is also required to include all the The engineering drawings are
information of the vessel dimension engineering drawing, reactor pipeline iso proprietary design
drawing, PID with stated lengths, diameters etc. to be referenced in the information, hence they are not
evaluation, and attach each engineering drawing and PID. included in the EIA report.
2 Nevertheless, relevant data -
Dari komen 1 di atas, perunding juga dikehendaki memasukkan kesemua maklumat and details were referred and
lukisan kejuruteraan dimension vessel, reactor pipeline iso drawing, PID nyatakan extracted from the drawing for
length, diameter dll yang akan dirujuk di dalam penilaian, dan diserta lampiran setiap use as basis in the consequence
lukisan kejuruteraan, PID, diatas modelling.
Appendix H
SDS information for 2-ethylhexenal, 2-ethylhexanoic acid and other chemicals Data used for each chemical in
Quantitative Risk
involved in the production process in this plant, which has flammable, the EFFECTS Software (based
3 Assessment
explosive or potentially toxic characteristics, shall be clearly provided in the on the software database) are
(Appendix 1-F
TOR. Some sections in the SDS attached seems incomplete with missing data included in the QRA report.
Chemical Data

on physical and chemical properties for substances such as 2-ethylhexenal, 2- Extracted from
ethylhexanoic acid, and all that are applicable. EFFECTS)
pg. 72 to 84 of
Maklumat SDS untuk 2-ethylhexenal, 2-ethylhexanoic acid, dan lain bahan kimia Appendix H
yang terlibat dalam proses pengeluaran produk loji ini yang bersifat mudah terbakar,
meletup, potensi toksik hendaklah dikemukakan dalam jadual dengan jelas di TOR,
memandangkan maklumat di dalam sebahagian SDS yang dilampirkan tidak lengkap
dan tiada data sifat-sifat bahan fizikal dan kimia yang lengkap seperti 2-ethylhexenal,
2-ethylhexanoic acid, dll berkenaan.
For comment no. 3, the complete information should include the following:
- Critical pressure
- Critical temperature
Data used for each chemical in
- Gas density Appendix H
the EFFECTS Software (based
- Boiling point Quantitative Risk
on the software database) are
- Flash point Assessment
included in the QRA report.
- Freezing point (Appendix 1-F
4 - Heat capacity (at constant pressure) Chemical Data
Some properties are not
- Heat capacity (liquid constant pressure) Extracted from
available in the SDS. Hence,
- Heat combustion EFFECTS)
comparison of data are done
- LEL dan UEL pg. 72 to 84 of
against CIMAH Regulations
- Vapour pressure Appendix H
1996.
- Autoignition
- LFL dan UFL
- EPRG, AEGL for toxicity

For toxicity, please check the toxicity section in the SDS and compare with the
toxic criteria in First Schedule of CIMAH 1996
Bagi komen no. 3, maklumat yang lengkap sekurang-kurangnya ialah seperti dibawah:
- Critical pressure
- Critical temperature
- Gas density
- Boiling point
- Flash point
- Freezing point
- Heat capacity (at constant pressure)
- Heat capacity (liquid constant pressure)
- Heat combustion
- LEL dan UEL
- Vapour pressure
- Autoignition
- LFL dan UFL
- EPRG, AEGL untuk toksik
Untuk toksik mohon buat semakan di dalam SDS section toksik dan bandingkan
dengan kriteria toksik dalam jadual satu CIMAH 1996
If information on the important parameters is available for 2-ethylhexenal, 2- Data used for each chemical in Appendix H
ethylhexanoic acid, and other chemicals involved in the production process of the EFFECTS Software (based Quantitative Risk
5
this plant that are flammable, potentially toxic or explosive in the proposed on the software database) are Assessment
tno effect software, please attach the data. included in the QRA report. (Appendix 1-F

Chemical Data
Jika maklumat parameter penting ada di dalam untuk 2-ethylhexenal, 2-ethylhexanoic Extracted from
acid, dan lain bahan kimia yang terlibat dalam proses pengeluaran produk loji ini yang EFFECTS)
bersifat mudah terbakar, meletup potensi toksik di dalam software perisisian effect tno pg. 72 to 84 of
yang dicadangkan mohon sertakan lampiran data. Appendix H
Table 7-27 Listing of
Release and Outcome
Events for
Consequence
Analysis
pg. 7-62 to 7-68
In the TOR, the main raw materials used are 2-ethylhexenal, hydrogen gas,
oxygen gas and potassium hydroxide, whereas the product is 2-ethylhexanoic Section 7.5.4.4 Event
acid. Potassium hydroxide has toxic characteristics, with reference to the SDS. All potential hazardous Tree Analysis
6 scenarios and impact are pg. 7-70 to 7-72
Di dalam TOR tersebut main raw materials used are 2-ethylhexenal, hydrogen gas, discussed in the QRA
oxygen gas and potassium hydroxide, whereas the product is 2-ethylhexanoic acid, Section 7.5.4.5
potassium sifatnya toksik jika lihat dalam SDS klh chem Consequence
Analysis
pg. 7-72 to 7-76
Appendix H
Quantitative Risk
Assessment (1.4.5

Representative
Release Scenarios,
1.5.3 Event Tree
Analysis, and 1.6
Consequence
Analysis)
pg. 23 to 28 and 31 to
36 of Appendix H
In Table T-6, the consultant needs to include the review of the existing safety
and risk planning and also management to minimize risks of fire and
Section 8.4.4 Risk
explosion as a result of accidental events in BASF PETRONAS, with the
pg. 8-21
addition of the new plant. Please suggest methods for evaluation of ERP and BASF PETRONAS is already
preventive safety management system for the new plant. implementing PSM and this
Appendix H
7 facility is already under the
Quantitative Risk
Dalam Jadual T-6, perunding dalam method perlu review existing Safety and risk perview of DOSH as it is a
Assessment (1.9
planning and management to minimise risks of fire and explosion as a result of Major Hazard Installation.
Recommendations)
accidental events di BASF PETRONAS dan juga kepada loji. Mohon cadangkan
pg. 39 of Appendix H
kaedah untuk penilaian preventive dan ERP, safety management system di loji produk
baru ini.
Toxic potential of chemicals such as potassium hydroxide and its impacts Table 7-27 Llisting of
should be included in Section 6.6.4.1 Potential Impact. All potential hazardous Release and Outcome
8 scenarios and impact are Events for
Potensi toksik dari bahan kimia 6.6.4.1 Potential Significant, tambahan potassium discussed in the QRA Consequence
hydroxide dan kesan dalam pengeluaran produk untuk hasil EHAcid Analysis

pg. 7-62 to 7-68
Section 7.5.4.4 Event

Tree Analysis
pg. 7-70 to 7-72
Section 7.5.4.5
Consequence
Analysis
pg. 7-72 to 7-76
Appendix H
Quantitative Risk
Assessment (1.4.5
Representative
Release Scenarios,
1.5.3 Event Tree
Analysis, and 1.6
Consequence
Analysis)
36 of Appendix H
In page 6-12, data collection can detail the proposed meteorological stations, Meteorological data use in the Appendix H
9
data to be taken, topography information and landuse. Please state the source QRA is obtained from the Quantitative Risk

(which agency) from which the data is obtained and the data to be collected. nearest meteorological station Assessment (1.2.5
Will ARCGIS be used as the software to obtain laduse data? Is the ESRI (Kuantan Meteorological Meteorological Data)
compatible with the TNO effect software and risk curve? State the Station) operated by the pg. 12 to 14 of
methodology in a process flow chart. Malaysian Meteorological Appendix H
Service (MMS) Department.
Dalam page 6-12, data collection boleh perincikan cadangan stesen meteorologi, data
yang akan diambil, information topography dan landuse. Boleh nyatakan dari agensi
mana data-data diperolehi dan data yang akan diambil, adakah penggunaan perisian
untuk data landuse menggunakan ARCGIS? ESRI yang compatible dengan software
effect tno dan risk curve? Nyatakan method proses carta alir.
Section 7.5.4.1 Hazard
Hazard identification is Identification
Hazard identification
conducted by reviewing the pg. 7-55 to 7-56
PFD and chemicals that are
The evaluation techniques to be used and their suitability in this study can be
part of the process and storage. Appendix H
10 stated.
Quantitative Risk
The chemicals involved are Assessment (1.4.5
Boleh nyatakan teknik penilaian yang akan digunakan dan kesesuaian dalam kajian
reviewed to determine if it is Hazardous
ini
hazardous or non-hazardous. Substances)
Frequency analysis The UK HSE Failure Rate and Section 7.5.4.3
Event Data for Use Within Risk Frequency Analysis
11
State the database used and state the reason for its suitability in this study Assessment (2019) is used. This pg. 7-68 to 7-70
is to be consistent with the data

Nyatakan database yang digunakan dan nyatakan sebab kesesuaian dalam kajian ini used by other plants within Appendix H
BASF Chemicals Malaysia. Quantitative Risk
Assessment (1.5
Frequency Analysis)
pg. 29 to 33 of
Appendix H
Section 7.5.4.5
Consequence
Analysis
pg. 7-72 to 7-75
Risk curve TNO consequences modelling is not used to assess potential

Section 7.5.4.7 Risk
physical hazards and to quantify risk, please recommend a suitable software
Summation
for this. EFFECTS is used for
pg. 7-76 to 7-78
Risk curve to complete QRA analysis is not for consequence analysis. Consequence Modelling and
12
RISKCURVES is used for Risk
Appendix H
Risk curve tno consequences modelling ini bukan asses potential physical hazards and Contour generation.
Quantitative Risk
quantify, mohon cadangkan software.
Assessment (1.6
Risk curve untuk lengkapkan QRA analysis bukan tujuan consequences analysis.
Consequence
Analysis, 1.7 Risk
Summation)
pg. 34 to 37 of
Appendix H

Section 7.5.4.8 Salient
Findings
FN curve is not plotted as the pg. 7-79 to 7-80
Data for FN curve IR contours of the proposed
13 project remains within the Appendix H
Data untuk FN curve established industrial Quantitative Risk
development. Assessment (1.8
Conclusion)
Method of estimation for population data for the calculation of FN curve or
societal risk as a result of exposure boundary red zone impact, or lethality on
Findings
the map. Will the map be able to read and integrate population data overlay
FN curve is not plotted as the pg. 7-79 to 7-80
from the threat zone, explosion footprint, toxic dispersion, fire, and
IR contours of the proposed
consequence analysis?
14 project remains within the Appendix H
established industrial Quantitative Risk
Bagaimana data populasi diestimate untuk pengiraan FN curve atau societal risk hasil
development. Assessment (1.8
exposure boundary red zone impact, or lethality atas map. Adakah map mampu read
Conclusion)
and intgate data populasi overlay from threat zone footprint explosion, toksik
dispersion, fire software consequence analysis software
Take into account the population projection over a period of five (5) or six (6) The QRA has taken into
years for the expected impact that will occur in the risk assessment simulation. account future surrounding
Findings
15 land use type only and
pg. 7-79 to 7-80
Mengambilkira unjuran populasi (projection) dalam tempoh lima (5) atau enam (6) population.
tahun bagi jangkaan impak yang akan berlaku dalam simulasi penilaian risiko.

IR contours of the proposed Appendix H
project remains within the Quantitative Risk
established industrial Assessment (1.8
development. Conclusion)
The application of methodology shown in Figure 5-14. As a result, a numerical
The QRA study is conducted
representation of the frequency and extent of a specified level of exposure or
based on the methodology
16 harm, to specific people or the environment are produced to quantify the risk -
prescribed in the EIA
akan ikut EIA Guidelines Waste Treatment and Disposal – Scheduled Waste-section
Guideline for risk Assessment.
QRA published 2020 DOE?
Recommend safe or standard operating procedures should be established. The This project is identical to
recommendations in general should be available for safe operation of critical BASF’s existing 2-EHAcid
equipment of this new plant (EIA guidelines 2020). Plant. The critical equipment
17 safe operation for this project -
Cadangan safe or standard operating procedures should be established. Boleh nyatakan shall be identical to measures
cadangan secara umum yang perlu ada pada critical equipment safe operation dalam which are already been
loji baru ini (EIA guideline 2020) practiced for the existing plant.
This project is identical to
Propose to establish an Emergency Response Plan (ERP) as a tool for effective BASF’s existing Acid Plant.
Appendix J
disaster or emergency management in case of an incident or accident for all The emergency measures for
Emergency Reponse
18 hazards and risks that will be identified in the study for this new plant (EIA this project shall be identical to
and Preparedness
guidelines 2020). measures which are already
Plan
been practiced.

Cadangan Establish an Emergency Response Plan (ERP) as tool for effective disaster The current site ERP has been
or emergency management in case of an incident or accident bagi semua hazard dan evaluated by DOSH as the
risiko yang akan dikenalpasti dalam kajian loji unit baru ini (EIA guidelines 2020). current site is a Major Hazard
Installation.
Section 7.5.4.3
Frequency Analysis
The UK HSE Failure Rate and
pg. 7-68 to 7-70
State the justification for the use of UK Health and Safety Executive (HSE), Event Data for Use Within Risk
TNO Effects and TNO Risk Curves in the assessment to be conducted. Assessment (2019) will be
Appendix H
19 used. This is to be consistent
Quantitative Risk
Menyatakan justifikasi pemakaian UK Health and Safety Executive (HSE), TNO with the data used by other
Assessment (1.5
Effects dan TNO Risk Curves dalam penilaian yang akan dijalankan. plants within BASF Chemicals
Frequency Analysis)
Malaysia.
pg. 29 to 33 of
Appendix H
Appointed Individual (Dr. Yusri)
Locations of the nearest Chart 6-7 Location of
CAQM stations to the Project CAQM Stations Near
site namely Balok Baru and Project Site
Section 4.7.1.2 Continuous Air Quality Monitoring (CAQM) Kuantan stations have been pg. 6-29
1 The location of the CAQM with respect to the site should be highlighted to included in the report. Balok
show the relevance in including the station in the study Baru CAQM station is located Section 6.7.1.1
about 3.2km from the Project Monitoring Location
site. and Parameters
pg. 6-28 to 6-29

The purpose of referring to the
nearest CAQM station in the
TOR report is to get indication
on the existing ambient air
quality conditions within the
Study area.
Section 7.4.1 Air
Quality
Assessment for the air quality
pg. 7-7 to 7-3
Section 4.7.1.2 Emission calculations impact for both construction
2
The emission calculation should be included in the document and operation phases are
Section 7.5.1 Air
detailed in Section 7.
Quality
pg. 7-23 to 7-47
Section 7.4.1 Air
Quality
Section 4.7.1.2 Emission source specifications
pg. 7-7 to 7-3
The specifications or the method used to acquire the information, such as Emission source specifications
3
source height, exhaust temperature and velocity, etc., should be added to the are detailed in Section 7.
Section 7.5.1 Air
document.
Quality
pg. 7-23 to 7-47
Section 4.7.1.1 Post EIA Compliance Monitoring Figure 6-12 refers to the Table 6-6 Ambient
The air monitoring stations are at the boundary of the plant. Other sensitive existing monitoring conducted Air Quality Sampling
4
receptors within at least 5km of the plant should be identified and monitored for BPC’s existing Integrated Locations and
too, for example, the locations listed in Table 4-1 or Table 4-11. Chemical Site (ICS). Methodology

pg. 6-28
Proposed air sampling locations could not be found in the document. What is Ambient air quality were
the air monitoring strategy for the project? measured at four (4) locations, Figure 6-11 Baseline
which are at sensitive receptors Sampling Locations
surrounding the Project site, as for Water Quality, Air
shown in Table 6-6 and Figure Quality and Noise
6-11. Levels
pg. 6-95
Section 7.4.1 Air
Quality
Assessment for the air quality
Section 6.6.1 Air Quality pg. 7-7 to 7-3
impact for both construction
5 Emissions calculations should be studied and reported. The assumptions used
and operation phases are
should also be listed. Section 7.5.1 Air
detailed in Section 7.
Quality
pg. 7-23 to 7-47
Oxygen and hydrogen off
gases from the proposed
Project will be sent to the
Section 5.3.5 Air
thermal oxidizer and flare
Section 6.6.1 Air pollution control Pollution Control
6 system respectively.
Control technology should be detailed and studied Systems
pg. 5-27
Flare and thermal oxidizer are
in fact systems used to control
air pollution by burning

unwanted gases or destroying
hazardous air pollutants and
converting them into
oxides (NOx), CO2 and steam.
Section 6.7.1 Air
Quality
pg. 6-27 to 6-34
MAAQS Standard 2020 limit is

Section 7.4.1 Air
used to compare relevant
7 MAAQS cited should be for the year 2020 and not 1989 or 2013. Quality
ambient air quality
pg. 7-7 to 7-3
parameters.
Section 7.5.1 Air

Quality
pg. 7-23 to 7-47
PLANMalaysia@Pahang
Based on the Kuantan District Local Plan 2035 (Replacement), under BPK 3.1:
Gebeng, it was found out that the proposed site is located within the industrial Section 6.3.3 Future
zone. Land Use Within 5
1 -
km of the Project Site
Berdasarkan Rancangan Tempatan Daerah Kuantan 2035 (Penggantian), di bawah pg. 6-10
BPK 3.1: Gebeng, didapati tapak cadangan terletak di dalam zon gunatanah industri.

The proposed Project is listed in the cluster industry proposal for the district
of Kuantan, namely for the chemical and petrochemical cluster in the State of
Pahang (Table 7.2, page 7-24). This proposed Project is also in line with the
policy outlined in the Pahang State Structure Plan 2050 under Thrust 2: Viable
Economy and Thrust 4: Environmental Sustainability (Environment and
Natural Resources). The details of the policies and strategies that support this
application are as follows:
Principle RSC- Pahang as a High Impact Industrial

DI1 Hub at the regional and national levels
(pg. 7-22) Section 1.4.3
Strategy DI1-S1 Pahang State as an additive and high Rancangan Struktur
2 -
yield East Coast Industrial Hub (pg. 7- Negeri Pahang 2050
22) pg. 1-7
Implementation I1S1-P1 Encourage high-tech industrial
Initiatives activities that lead to increased added
value (pg. 7-22)
I1S1-P2 Attract investment from the world's
leading industry-based companies to
develop Pahang into an East Coast hub
(pg. 7-22)
I1S1-P3 Attract more investment in high-tech
industries especially in the iron steel,
chemical and petrochemical, oil and

gas, automotive and engineering
sectors (pg. 7-23)
Principle RSC- Conservation and Management of

DE1 Environmentally Sensitive Areas and
Natural Resources (pg. 9-1)
Strategy DE1-S2 Consideration of Environmental Issues
Implementation When Planning, Developing and
Initiatives Implementing Land Use Development
(pg. 9-11)
E1S2-P1 Enforce regulations, guidelines and
laws related to the environment in an
integrated manner, including the
enforcement of Development
Guidelines in Hilly Areas (pg. 9-11)
E1S2-P3 Enforce the preparation of EIA in all
development projects based on the
Environmental Quality (Prescribed
Inisiatif Activities) (Environmental Impact
Pelaksanaan Assessment) Order 2015 or any recent
changes to this order (pg. 9-11)
E1S2-P4 Taking into account the overall
environmental impact from the

beginning to the end of the project is
carried out, while considering the
approval of development applications
- Establish a sustainability
committee (implementation
and monitoring) consisting of
various relevant agencies in
monitoring development
conditions in an integrated
manner (pg. 9-11)
Cadangan projek ini adalah tersenarai di dalam cadangan industri kluster bagi daerah
Kuantan iaitu untuk kluster kimia dan petrokimia di Negeri Pahang (Jadual 7.2, muka
surat 7-24). Cadangan ini juga adalah selaras dengan dasar yang digariskan di dalam
Rancangan Struktur Negeri Pahang 2050 di bawah Teras 2: Ekonomi Berdaya Maju
dan Teras 4: Kelestarian Alam Sekitar (Alam Sekitar dan Sumber Jaya Asli). Perincian
dasar dan strategi yang menyokong permohonan ini adalah seperti berikut:
Dasar RSC- Pahang Sebagai Hab Perindustrian Berimpak

DI1 Tinggi di Peringkat Wilayah, Nasional dan
Serantau (m/s 7-22)
Strategi DI1-S1 Negeri Pahang Sebagai Hab Perindustrian
Pantai Timur Berdaya Tambah dan
Keberhasilan Tinggi (m/s 7-22)

Inisiatif I1S1-P1 Menggalakkan aktiviti industri berteknologi
Pelaksanaan tinggi yang membawa kepada peningkatan
nilai tambah (m/s 7-22)
I1S1-P2 Menarik pelaburan syarikat berteraskan
industri terkemuka dunia untuk menjadikan
Negeri Pahang sebagai hab Pantai Timur
(m/s 7-22)
I1S1-P3 Menarik lebih banyak pelaburan industri
berteknologi tinggi terutama dalam sektor
iron steel, kimia dan petrokimia, minyak dan
gas, automotif dan kejuruteraan (m/s 7-23)
Dasar RSC- Pemeliharan dan Pengurusan Kawasan Sensitif

DE1 Alam Sekitar dan Sumber Semulajadi (m/s 9-1)
Strategi DE1- Pertimbangan Isu Alam Sekitar Semasa
S2 Merancang, Membangun dan Melaksanakan
Pembangunan Guna Tanah (m/s 9-11)
E1S2- Menguatkuasakan peraturan, garis panduan
P1 dan undang-undang yang berkaitan alam
sekitar secara bersepadu termasuk
penguatkuasaan Garis Panduan Pembangunan
di Kawasan Bukit (m/s 9-11)
Inisiatif E1S2- Menguatkuasakan penyediaan EIA dalam
Pelaksanaan P3 semua projek pembangunan berdasarkan

Perintah Kualiti Alam Sekeliling (Aktiviti yang
ditetapkan) (Penilaian Kesan Kepada Alam
Sekitar) 2015 atau sebarang perubahan terkini
terhadap perintah ini (m/s 9-11)
E1S2- Mengambil kira impak alam sekitar secara
P4 menyeluruh dari awal hingga akhir pelaksanaan
projek dijalankan, semasa mempertimbangkan
kelulusan permohonan pembangunan
- Mewujudkan jawatankuasa
kelestarian (pelaksanaan dan
pemantauan) yang terdiri daripada
pelbagai agensi berkaitan dalam
memantau syarat pembangunan
secara bersepadu (m/s 9-11)
Te Department in principle, has no objection to this TOR Report provided the
following conditions:
a) Comply with all provisions of existing laws, guidelines and planning
standards in force in the State of Pahang; and
b) Implement and monitor the mitigation measures proposed in this report The Project Proponent has
3 -
and ensure that environmental sustainability can be maintained throughout taken note.
the project implementation period
Sehubungan dengan itu, Jabatan pada dasarnya tiada halangan dengan Laporan TOR
ini dengan syarat seperti berikut:

a)Mematuhi segala peruntukan undang-undang, garis panduan dan piawaian
perncangan sedia ada dan berkuatkuasa di Negeri Pahang; dan
b) Melaksana dan memantau langkah-langkah mitigasi yang dicadangkan di
dalam laporan ini dan memastikan kelestarian alam sekitar dapat dipelihara
sepanjang tempoh pelaksanaan projek
Kementerian Kesihatan Malaysia
Agree with the methodology proposed in the Health Impact Assessment
(HIA) in Terms of Reference (TOR).
1 - -
Bersetuju dengan metadologi yang dicadangkan dalam Health Impact Assessment
(HIA) dalam terma rujukan.
Based on one of the site
Section 6.5.4.2
reconnaisance activities, some
Recreational Use and
fishing boats were found near
Section 4.3 Land Use and Sensitive Receptors Fishing Activities
the Sg. Balok estuary.
pg. 6-17 to 6-18
Consultants are advised to identify aquaculture activities along Baluk River,
Based on feedback from
2 which is involved in the Project area, so as not to affect the water source. Section 6.5.4.3
Department of Fisheries
Commercial Use
Pahang, the nearest
Perunding disaran mengenalpasti aktivi akuakultur di sepanjang sungai Baluk yang pg. 6-18 to 6-21
aquaculture farm is the shrimp
terlibat dengan kawasan projek supaya tidak menjejaskan sumber air tersebut.
hatchery which is located
Appendix D DOF
approximately 8km from the
Response Letter
Project site.

The Standard Operating
Procedure (SOP) for WWTP
prescribes detailed measures
Section 8.4.5 Water
Section 6.6.6 Water Quality for continuous monitoring of
Quality
final effluent discharge with
pg. 8-23
Baluk River will receive the final effluent discharge, so there is a need to troubleshooting measures can
simulate a worst case scenario if this WWTP fails to treat the wastewater before be referred in Appendix L. No
Appendix L
it is being discharged into the river. This is because the results of this water previous incidents of plant
Wastewater
3 quality modelling will affect the HIA study. failure was recorded, as
Treatment Plant
confirmed with the Project
Supervisory Manual
Sungai Baluk akan menerima final effluent discharge, oleh itu adakah terdapat Proponent.
keperluan simulasi worst case scenario jika WWTP ini mengalami kegagalan untuk
Section 7.5.5 Water
merawat sebelum dilepaskan ke sungai. Ini kerana, hasil dari water quality modelling The impact of raw discharge
Quality
ini akan mempengaruhi kajian HIA. from WWTP to Sg. Balok
pg. 7-81 to 7-88
during worst case is assessed
using a mixing model in
Section 7.5.5.
Section 6.5.4 Waste Management
Waste generated during Section 7.5.6 Waste

The consultant is requested to state in detail the waste material generated as a
4 operation stage is identified Management
pollutant from this Project. This is necessary to identify health hazards
and quantified in Section 7.5.6 pg. 7-89 to 7-93
resulting from the waste material and potentially affecting health.

The consultant also needs to identify, characterize and evaluate contaminants
that have potential exposure pathways on receptors. This is because there is a
recreational area downstream of the Project, namely Pantai Baluk, which has
the potential to affect the health of visitors if there is contamination of surface
water and so on.
Perunding diminta menyatakan dengan terperinci waste material yang terhasil

sebagai bahan pencemar daripada projek ini. Perkara ini perlu bagi mengenalpasti
health hazard yang terhasil daripada waste material tersebut dan berpotensi memberi
kesan kepada kesihatan.
Perunding juga perlu mengenalpasti, mencirikan dan menilai bahan pencemar yang
mempunyai potensi exposure pathway ke atas reseptor. Ini kerana terdapat kawasan
rekreasi di downstream projek iaitu Pantai Baluk yang berpotensi memberi kesan
kesihatan kepada pengunjung jika terdapat contamination of surface water dan
sebagainya.
Detail the method of placement for 200 workers during the construction stage,
Table 5-9 Activities
including water resources and sewage treatment methods.
The construction workers will During Construction
5
be accommodated offsite. Stage
Memperincikan kaedah penempatan pekerja seramai 200 orang semasa tempoh
pg. 5-29
pembinaan termasuk sumber air dan kaedah rawatan kumbahan.
Raw effluent from every Section 5.3.4 Existing
Explain the statement on page 2-21, which states that raw effluent from the
6 process plant will enter a Wastewater
process plants and sewage within the ICS compound will be tested for COD
temporary wastewater storage Treatment Plant

loading first prior to discharging to the WWTP. Explain on the frequency of tank located within their pg. 5-21 to 5-26
test. respective plant areas to be
tested for COD loading. The
Menjelaskan pernyataan pada mukasurat 2-21, yang menyatakan raw effluent from frequency of test is dependent
process plants and sewage within the ICS compound will be tested for COD loading on the COD loading of the raw
first prior to discharging to the WWTP. Keperluan menjelaskan berapakah frekuensi effluent. If the COD load meets
yang akan diambil. the required limits to enter the
WWTP, then it will be pumped
into the WWTP. If the
wastewater does not meet the
COD loading criteria, then it
will be mixed within the
temporary storage tank first
until the COD loading meets
the requirements before it is
discharged into the WWTP for
treatment.
Bahagian Kawalan Penyakit
Detail the information on the potential impact of water pollution on public
Section 7.5.8 Health
health as Balok River and Pantai Balok function as water receiving bodies as Details on public health impact
1 Impact Assessment
well as public recreational locations. included.
pg. 7-116 to 7-130

Memperincikan maklumat potensi kesan pencemaran air kepada kesihatan awam
memandangkan Sungai Balok dan Pantai Balok berfungsi sebagai badan penerima air
serta lokasi rekreasi awam.
Balok River and Pantai Balok are the main recipients of industrial effluent from
Gebeng area. Although discharges from the Project is minimal, but collectively
it will increase the pollution burden in Balok River and subsequently in Pantai
Balok. It is proposed that the scope of the HIA can be detailed with the carrying HIA related to Sg. Balok is
capacity information of the water body. conducted based on the water Section 7.5.8 Health
2 quality parameters to be Impact Assessment
Memaklumkan Sungai Balok dan Pantai Balok merupakan penerima utama aliran generated by the water quality pg. 7-116 to 7-130
industri di kawasan Gebeng. Walaupun pelepasan daripada Penggerak Projek minima assessment team.
tetapi secara kolektifnya akan menambah beban pencemaran di Sungai Balok dan
seterusnya di Pantai Balok. Dicadangkan skop bagi HIA dapat diperincikan dengan
maklumat daya tampung badan air tersebut.
Jabatan Kesihatan Negeri Pahang
Agree with the comments expressed by the representative from Kementerian
Kesihatan Malaysia Bahagian Kawalan Penyakit, on the need to state the
probability of the effects of water pollution on public health because there are
locations of public recreation, fishing activities and etc. Section 7.5.8 Health
Details on public health impact
1 Impact Assessment
included.
Bersetuju dengan ulasan yang dinyatakan oleh wakil Kementerian Kesihatan pg. 7-116 to 7-130
Malaysia Bahagian Kawalan Penyakit di mana keperluan menyatakan kebarangkalian
kesan pencemaran air daripada kesihatan awam kerana terdapat lokasi rekreasi awam,
tangkapan ikan dan sebagainya.

a) Surface water Section 6.7.3 Water
Water quality sampling is conducted Quality
a) The study for surface water sampling was last conducted in 2014. by the Project pg. 6-42 to 6-67
There is no recent study for groundwater well sampling. Proponent on a
b) Groundwater well sampling needs to be done for now and after the quarterly basis. Latest Section 6.6
project is carried out as there are people around who still use water surface water Groundwater
resources from underground wells. sampling (for baseline pg. 6-22 to 6-27
c) Water sampling in the area around the beach near the project should monitoring) can be
also be done and not subject to the beach at the end of Balok river only. referred in Section Section 7.5.5.1
Residents in the area around the project use the beach a lot for fishing, 6.7.3. Meanwhile, Potential Impact
bathing and leisure. latest groundwater pg. 7-81
d) Details related to VOC (Volatile Organic Compounds), heavy metals sampling was
2
and TPH (Total Petroleum Hydrocarbon) in water sampling should be conducted by the Table 6-4
described. Project Proponent on Groundwater
e) To further facilitate response action in the event of groundwater August 2020 (Section Sampling Results for
discharge contamination, further studies should be considered to 6.6). Groundwater Wells
estimate potential chemical migration travel times into groundwater b) Latest groundwater BH4 and BH5A (Total
from hazardous chemical sources from the project site to the project sampling was Petroleum
site boundary. conducted on August Hydrocarbon and
2020 (Section 6.6). Heavy Metals)
Kualiti air c) Water sampling pg. 6-25
a) Kajian untuk surface water sampling dilakukan kali terakhir pada tahun around the beach area
2014. Tiada kajian terbaru untuk groundwater well sampling. has exceeded the 5km Table 6-5a
study boundary zone. Groundwater

b) Groundwater well sampling perlu dilakukan untuk pada masa sekarang dan Nonetheless, river Sampling Results for
selepas projek dijalankan memandangkan terdapat penduduk sekitar yang water sampling has Groundwater Wells
masih menggunakan sumber air dari telaga bawah tanah. been conducted and BH4 and BH5A
c) Water sampling di kawasan sekitar pantair berhampiran projek juga perlu the water quality (Volatile Organic
dibuat dan tidak tertakluk kepada pantai di hujung aliran Sungai Balok impact assessment has Compounds)
sahaja. Penduduk di kawasan sekitar projek banyak menggunakan pantai discussed on the pg. 6-25
untuk menangkap ikan, mandi dan riadah. potential impact from
d) Perincian berkaitan VOC (Volatile Organic Compounds), logam berat dan the Project towards Table 6-5b
TPH (Total Petroleum Hydrocarbon) dalam persampelan air perlu Pantai Balok (Section Groundwater
dihuraikan. 7.5.5.1). Sampling Results for
e) Untuk memudahkan lagi tindakan tindak balas sekiranya berlaku d) Details related to Groundwater Wells
pencemaran pelepasan ke bawah permukaan tanah, kajian lanjutan harus VOC, heavy metals BH4 and BH5A
dipertimbangkan untuk menganggarkan potential chemical migration travel (Volatile Organic
and TPH in
times ke dalam air bawah tanah daripada sumber bahan kimia berbahaya dari
groundwater Compounds)
tapak projek kepada sempadan tapak projek.
sampling is described pg. 6-25
in Tables 6-4 to 6-5e.
e) The Project will not Table 6-5c
involve additional Groundwater
construction of new Sampling Results for
raw material tank, and Groundwater Wells
all the processess are BH4 and BH5A
above ground. As (Volatile Organic
such, the potential of Compounds)
groundwater pg. 6-26

contamination from
the Project is very low. Table 6-5d
Thus, the Consultant Groundwater
in the opinion that Sampling Results for
groundwater Groundwater Wells
contamination study is BH4 and BH5A
not required. (Volatile Organic
Compounds)
pg. 6-26
Table 6-5e
Groundwater
Sampling Results for
Groundwater Wells
BH4 and BH5A
(Volatile Organic
Compounds)
pg. 6-26
Food chain pollution especially fish in rivers and seas Section 7.5.6.2
Based on the estimated
a) Chemical contamination in water can cause bioaccumulation in fish Scheduled Wastes
quantity of scheduled wastes
and cause health risks when the fish are consumed. pg. 7-90 to 7-93
3 generated, majority of the
b) A thorough study needs to be done in this aspect.
scheduled waste is made up of
Section 8.4.6.2
waste catalyst that will be
Pencemaran rantaian makanan terutamanya ikan di sungai dan laut Scheduled Wastes

a) Pencemaran bahan kimia dalam air boleh menyebabkan bioaccumulation disposed once in every four pg. 8-23 to 8-29
dalam ikan dan menyebabkan risiko kesihatan apabila ikan-ikan tersebut years.
dimakan.
b) Perlu dilakukan kajian teliti dalam hal ini. Based on the toxicity and
ecological information from
the SDS of the catalyst,
bioaccumulation in organisms
is not to be expected.
Nonetheless, best management
practices for scheduled wastes
generated during the
operation stage is discussed in
Section 8.4.6.2.
Sahabat Alam Malaysia (SAM)
The Consultant understand
that climate change and rain
intensity are both major
Section 6.5.3.1
influence in flood. The risk
Existing Flood Risk
Assessment on the risk of flooding should take into account climate change assessment of flooding for the
1 Mitigation and
and the increase in rain intensity surrounding Project site (or
Action Plans
specifically the entire flood
pg. 6-13 to 6-16
prone area) is beyond the EIA
study scope as there are also
other stakeholders involved in

the flood prone area. Flooding
risk should be viewed and
assessed at macro level.
Nonetheless, the Consultant

has checked with JPS Pahang
and was informed that there
were currently no flood
mitigation programs
specifically for Sg. Balok. Even
so, existing flood risk
mitigations and action plans to
mitigate flood issues on both
national and regional levels are
detailed.
The risk assessment of the
radioactive waste dump site
has been prepared and should
be addressed in the EIA report
The need to evaluate the possible worst-case scenario of the compounding risk
2 of the said facility. The risk -
and hazard from the nearby radioactive waste dump site
assessment outcome is
reviewed as reference. At this
point of time, as Project
Proponent did not use

groundwater as source of
water, therefore there is no
concern of radioactive residue
at the Project site.
JAS Pahang
Chart 5-2 Overall
Mass Balance for
Average Production
Chart 2-5, pg. 2-15 for Overall Process Flow. Capacity of 30,000
Please include the total mass, whereas for disposal, state the type and location MT/a
of disposal in detail. pg. 5-7
Overall mass balance can be
1
referred in Charts 5-2 and 5-3.
Chart 2-5, m/s 2-15 bagi Overall Process Flow. Chart 5-3 Overall
Mohon disertakan jumlah jisim, manakala bagi disposal, dinyatakan jenis dan lokasi Mass Balance for
disposal secara terperinci. Maximum
Production Capacity
of 36,000 MT/a
pg. 5-9
Chart 2-6 Oxidation of Ehexanal and Chart 2-7 EHAcid Purification Process Chart 5-2 Overall
Flow Mass Balance for
Please include the total mass. Overall mass balance can be Average Production
2
referred in Charts 5-2 and 5-3. Capacity of 30,000
Chart 2-6 Oxidation of Ehexanal dan Chart 2-7 EHAcid Purification Process Flow MT/a
Mohon disertakan jumlah jisim. pg. 5-7

Chart 5-3 Overall

Mass Balance for
Maximum
Production Capacity
of 36,000 MT/a
pg. 5-9
Table 5-2 Mass

Balance for Average
2-EHAcid Production
Capacity of 30,000
MT/a
pg. 5-8
Table 5-3 Mass

Balance for
Maximum 2-EHAcid
Production Capacity
of 36,000 MT/a
pg. 5-10
Table 2-4, pg. 2-20 Wastewater Generation from Existing Plants Within the Sources of wastewater from Table 5-5 Wastewater
3 ICS, as much as 50 m3/h is generated from utilities. Please provide the details. utilities are detailed in Table 5- Generation from
5 Plants Within the ICS

Table 2-4 m/s 2-20 Wastewater Generation from Existing Plants Within the ICS, pg. 5-22
sebanyak 50 m3/h dijana dari utilities. Mohon berikan perincian.
Chart 2-9 Project Implementation Schedule should include preparation of EIA
Chart 5-10 Project
and EMP. EIA and EMP preparation and
Implementation
4 approval schedules are
Schedule
Chart 2-9 Project Implementation Schedule, perlu dimasukkan bagi item penyediaan included
pg. 5-32
EIA dan EMP.
Figure 2-2 Overall Layout Plan does not show indications for the existing 2-
EHAcid Plant II Production Site, which is said to be adjacent to the Project Site,
“will be constructed right next to the existing 2-EHAcid plant”. Refer to pg. 2-
Figure 1-2 Overall
2. The existing 2-EHAcid plant is
5 Layout Plan
indicated
pg. 1-12
Figure 2-2 Overall Layout Plan tidak menunjukkan petunjuk bagi existing 2-EHAcid
Plant II Production Site yang dikatakan bersebelahan dengan Project Site, “will be
constructed right next to the existing 2-EHAcid plant” rujuk m/s 2-2.
Figure 2-3 Project Layout Plan does not show all legends detailed in the plan.
Figure 5-1 Project
All legends has been indicated
6 Layout Plan
Figure 2-3 Project Layout Plan, tidak menunjukkan keseluruhan petunjuk yang in Figure 5-1
pg. 5-33
dikemukakan dalam pelan.
No layout for water, air and noise sampling points provided. Existing water, air and noise Figure 6-12 Existing
7 sampling points can be Monitoring Stations
Tiada pelan water, air dan noise sampling points dikemukakan. referred in Figure 6-12 pg. 6-96
Please submit the approval for disposal at Jabor-Jerangau Landfill. Referring Approval to dispose solid
8
to Chart 4-4 Location of Nearest Disposal Facility (Tapak Pelupusan Jabor waste to Tapak Pelupusan

Jerangau) from Project Site, provide the transportation route that will be used Jabor Jerangau can be referred Section 6.8 Waste
from the landfill to the Project site. in Appendix G. Management
pg. 6-68 to 6-72
Mohon kemukakan kelulusan disposal facility di Tapak Pelupusan Jabor Jerangau. Transportation route is shown
Merujuk Chart 4-4 Location of Nearest Disposal Facility (Tapak Pelupusan Jabor in Chart 6-18 Chart 6-18 Location
Jerangau) from Project Site, kemukakan dari pintu masuk ke laluan yang akan of Nearest Disposal
digunakan untuk ke tapak pelupusan dari tapak projek. Facility (Tapak
Pelupusan Jabor
Jerangau) from
Project Site
pg. 6-50
Appendix G License
for Solid Waste
Disposal
In pg. 4-6, Kg. Berahi is 3.5km away, but in pg. 4-25, it is 3.2km away. This is
the same for the distance for Taman Balok Perdana. Please provide
Typo in distances for
justification for the different. There is no mentioning of Taman Balok Makmur Table 6-1 Key
residential within 5km have
which is a nearby residential area on pg. 4-6. There is a need to ensure the Landmarks Within
been amended, and all
9 consistency in distances in the report. 5km Radius of the
residential areas within the
Project Site
5km radius has been listed in
Di m/s 4-6, Kg. Berahi ialah 3.5 km manakala di m/s 4-25 menunjukkan 3.2km. Begitu pg. 6-4 to 6-9
Table 6-1
juga perbezaan jarak dengan Taman Balok Perdana. Mohon berikan justifikasi
perbezaan tersebut. Tidak diceritakan penempatan Taman Balok Makmur yang

merupakan penempatan berhampiran di m/s 4-6, Perlukan keseragaman jarak
keseluruhan laporan.
Figure 4-5 Proposed Future Development in Kuantan does not refer to the site. Figure 6-5 Proposed
Both boundaries of the Project
Future Development
11 site and ICS is shown in Figure
Figure 4-5 Proposed Future Development in Kuantan tidak merujuk petunjuk kepada in Kuantan
6-5
tapak. pg. 6-89
Table 5-2, pg. 5-9. Referring to the Proposed Sampling Locations and
Methodology, the listed proposed air sampling points does not take into The air quality monitoring Figure 6-11 Baseline
account of the nearest residential areas or institution from the Project site locations shown in Figure 6-11 Sampling Locations
(referring to pg 4-5 and 6-4). Please justify. has taken into consideration for Water Quality, Air
12
the nearest residential areas Quality and Noise
Table 5-2, m/s 5-9. Merujuk kepada Proposed Sampling Locations and Methodology, and institutions nearest to the Levels
senarai proposed air sampling points tidak mengambilkira penempatan paling hampir Project site. pg. 6-95
atau institusi berdekatan projek. Rujuk m/s 4-5 dan m/s 6-4. Mohon justifikasi.
Referring to Figure 5-1 Proposed Baseline Sampling Locations for Water Both boundaries of the Project
Figure 6-11 Baseline
Quality, Air Quality and Noise Levels, please provide the waterways or river site and ICS is shown in Figure
Sampling Locations
layers for water monitoring, and Project site boundary needs to be shown. 6-11. Project site boundary can
for Water Quality, Air
13 be seen in zoomed figure on
Quality and Noise
Merujuk Figure 5-1 Proposed Baseline Sampling Locations for Water Quality, Air the upper left. Water bodies
Levels
Quality and Noise Levels, sila kemukakan aliran air atau sungai bagi persampelan air, are shown and indicated in the
pg. 6-95
dan boundary tapak projek hendaklah dikemukakan. legend.
The effects and mitigation measures for emergencies involving fire should be This project is identical to
Appendix J
14 taken into account in the report. BASF’s existing Acid Plant.
Emergency Reponse
The emergency measures for

Kesan dan langkah mitigasi bagi kecemasan melibatkan kebakaran perlu diambilkira this project shall be identical to and Preparedness
dalam laporan. measures which are already Plan
been practiced.
Table 7-27 Listing of
The current site ERP has been Release and Outcome
evaluated by DOSH as the Events for
current site is a Major Hazard Consequence
Installation. Analysis
pg. 7-62 to 7-68
All potential hazardous
scenarios and impact are also Section 7.5.4.4 Event
discussed in the QRA Tree Analysis
pg. 7-70 to 7-72
Section 7.5.4.5
Consequence
Analysis
pg. 7-72 to 7-76
Appendix H
Quantitative Risk
Assessment (1.4.5
Representative
Release Scenarios,

1.5.3 Event Tree
Analysis, and 1.6
Consequence
Analysis)
36 of Appendix H
Table 6-2 Study Boundaries and Sensitive Receptors, stated to take into
account within a radius of 2km, however the nearest project receptors for
placements exceed 2km. Please justify. Table 7-2 Summary of
15 Study boundary is 5km. Impacts
Table 6-2 Study Boundaries dan Sensitive Recptors, dinyatakan mengambilkira dalam pg. 7-4 to 7-5
radius 2km, namun reseptor terdekat projek bagi penempatan melebihi 2km. Mohon
justifikasi.
Section 7.4.3.2
Assessment
6.5.3.2 Scope of Assessment, what is meant by mixing model for water quality.
Details on mixing model can pg. 7-13 to 7-17
16 be referred in Sections 7.4.3.2
6.5.3.2 Scope of Assessment, apakah yang dimaksudkan dengan mixing model bagi
and 7.5.5.2 Section 7.5.5.2
water quality.
Assessment
pg. 7-81 to 7-86
Chart 5-9a Mass
Provide WWTP process flow and plan involved for WWTP. Process flow for existing
Balance for
17 WWTP is shown in Charts 5-9a
Wastewater
Kemukakan aliran proses WWTP dan pelan terlibat bagi WWTP. and 5-9b.
Treatment Process of

Existing Wastewater
Treatment Plant
pg. 5-24
Chart 5-9b Mass

Balance for
Dewatering Process
of Existing Wastwater
Treatment Plant
pg. 5-25
Urusetia JAS HQ
Explain the proposed distance of 2km radius compared to the distance of 5km
radius for the boundary of the study to be conducted. Table 7-2 Summary of
1 Study boundary is 5km. Impacts
Menjelaskan cadangan jarak 2km radius berbanding jarak 5km radius bagi sempadan pg. 7-4 to 7-5
kajian yang akan dijalankan.
The time for the document processing period of TOR is 30 days. Please update
the project timeline.
It was taken note and updated
2 -
in the TOR report.
Mengemaskini garis masa projek memandangkan bagi skop terma rujukan tempoh
memproses dokumen yang tepat adalah 30 hari.
In the list of consultants, it is stated that Mr. Tan Poh Aun will conduct an odor List of EIA
Scope for consultant, Mr. Tan
3 quality assessment but there is no such section in the proposed terms of Consultants Involved
Poh Aun, has been amended.
reference. in the EIA Study

The scope only includes noise
Semakan pada senarai jurunding, Encik Tan Poh Aun akan menjalankan kajian assessment.
berhubung odour quality assessment namun tiada bab tersebut dalam terma rujukan
yang dicadangkan.
Bahagian Penguatkuasa JAS HQ
Based on the presentation, the department finds that the terms of reference of
the study are adequate for the scope of effluent, sewage, domestic waste and
scheduled waste management.
1 - -
Berdasarkan kepada pembentangan, Bahagian ini mendapati terma rujukan kajian
adalah mencukupi bagi skop pengurusan sisa efluen, kumbahan, sisa domestik dan
buangan terjadual.
Bahagian Air Marin JAS HQ
The WWTP that has been built is to treat wastewater and sewage. Does th Since WWTP for the premise is
construction of this plant take into account the Malaysian Standard for sewage to treat both wastewater and
Section 5.3.4 Existing
produced by SPAN? sewage, the standards as listed
Wastewater
1 in the Fifth Schedule of the
Treatment Plant
WWTP yang telah dibina ini adalah untuk treat wastewater dan sewage. Adakah Environmental Quality
pg. 5-21 to 5-26
pembinaan loji ini telah mengambilkira Malaysian Standard untuk kumbahan yang (Industrial Effluent)
dikeluarkan oleh SPAN. Regulations 2009 is referred.
Bahagian Bahan Berbahaya JAS HQ
Consultant to list the scheduled waste codes that are generated and that will List of scheduled wastes that is Section 7.4.4.2
1 be disposed in the EIA according to the Project phases. expected to be generated is Scheduled Wastes
included in Section 7.4.4.2 for pg. 7-19

Mohon jururunding menyenaraikan kod buangan terjadual yang terhasil dan yang construction stage and Section
akan dilupuskan daripada projek EIA mengikut fasa. 7.5.6.2 for operation stage. Section 7.5.6.2
Secheduled Wastes
pg. 7-90 to 7-93
Generation quantity is Chart 5-2 Overall
indicated in the mass balance Mass Balance for
tables and flow chart. Average Production
Capacity of 30,000
For scheduled wastes MT/a
Each process that produces scheduled wastes is recommended to be indicated generated, the quantity varies pg. 5-7
in the process flow chart, including the quantity generated. based on the technologies and
Do also state the scheduled waste generated for each phase (construction and methodologies available for Chart 5-3 Overall
operation). each section. However, the Mass Balance for
total quantity of SW to be Maximum
2
Dicadangkan supaya setiap proses yang menghasilkan buangan terjadual dinyatakan generated during construction Production Capacity
dalam bentuk carta proses (process flow) termasuk kuantiti penjanaan. stage is anticipated to be low as of 36,000 MT/a
most sources will come from pg. 5-9
Nyatakan juga buangan terjadual yang terhasil bagi setiap fasa (pembangunan dan machinery maintenance
operasi) works. Table 7-37 Estimated
Maximum Quantity
Estimation of quantity of of Potential
scheduled wastes generated Scheduled Wastes
during operation stage is Generated During
detailed in Table 7-37. Operation Phase

pg. 7-90 to 7-92
The Scheduled Waste Storage Management Plan should be shown in this

report. The management plan should refer to the Guidelines for Packaging,
Labelling and Storage of Scheduled Wastes in Malaysia. The existing scheduled waste Section 8.3.4.2
3 management plan is referred Scheduled Waste
Pelan Pengurusan Penstoran buangan terjadual perlu ditunjukkan di dalam laporan in this report. pg. 8-13 to 8-14
ini. Pelan Pengurusan perlu merujuk kepada Guidelines for Packaging, Labelling and
Storage of Scheduled Wastes in Malaysia.
Section 8.3.4.2
Management of scheduled wastes should comply with the Environmental Management of scheduled Scheduled Waste
Quality (Scheduled Wastes) Regulations 2005. wastes is detailed in both pg. 8-13 to 8-14
4 Section 8.3.4.2 for construction
Pengurusan berkenaan dengan buangan terjadual mestilah mematuhi Peraturan- stage and Section 8.4.7.2 for Section 8.4.7.2
Peraturan Kualiti Alam Sekeliling (Buangan Terjadual) 2005. operation stage. Scheduled Wastes
pg. 8-23 to 8-29
Appointed Individual (Ts. Dr. Azizul Azri Mustaffa)

Chart 2-3 Chart 5-1 Overall
(i) Meaning of aq. and org.
- Specify meaning of aq. and org. Process Diagram of 2-
1 has been added in the
- What is 35- in the oxidation process EHAcid Production
notes
- What is the function of KOH makeup? pg. 5-6

- What is K-Recycle? (ii) Details for oxidation has
- Detailed process description needs to be provided been amended Section 5.3.2 Main
(iii) Function of KOH Production Processes
makeup is described in pg. 5-12 to 5-13
the detailed description
in Section 5.3.2.2
(iv) K-Recycle has been
explained in the notes
(v) Detailed process
description can be
referred in Section 5.3.2
Since the BDO complex is no
longer in operation, there is
excess hydrogen produced on
site which can be used for the
new 2-EHAcid plant.
Does the 2-Ethylhexenal and hydrogen produced from the Oxo complex
2 As for the 2-ethylhexenal -
sufficient to meet the demand and at the same time supplied to this new plant?
produced from the OXO
complex, it will be sufficient
for the production in the new
2-EHAcid plant. In case of any
increase in the production of 2-
EHAcid, the production of 2-

EHol will be reduced as the
current sales for 2-EHol is very
limited.
Chart 5-2 Overall
Mass Balance for
Average Production
Capacity of 30,000
MT/a
pg. 5-7
Chart 5-3 Overall

Mass Balance for
A detailed mass and energy balance calculations need to be provided so that
Maximum
the content of each of the process streams with their amounts are visible and Overall mass balance can be
3 Production Capacity
transparent. This need to be included later in the EIA report. Currently, only referred in Charts 5-2 and 5-3.
of 36,000 MT/a
general descriptions are provided.
pg. 5-9
Table 5-2 Mass

Balance for Average
2-EHAcid Production
Capacity of 30,000
MT/a
pg. 5-8

Table 5-3 Mass
Balance for
Maximum 2-EHAcid
Production Capacity
of 36,000 MT/a
pg. 5-10
Chart 5-4 Selective
Chart 2-4
Composition of recycled liquid Hydrogenation
4 Why Ehexanal is recycled back to reactor? It should also include the unreacted
stream is as listed in Chart 5-4 Process
reactant.
pg. 5-13
(i) It is heated through a
thermosiphon reboiler
Chart 2-5
using 23 barg steam.
- How is the sump of the tower being heated via the evaporator? Section 5.3.2.2
(ii) The separation of
- How does the lights (water, butanal and butanol) are being produced Purification of
component is based on
from the process? Ehexanal
its boiling temperature.
- Why there is a bypass condensate stream into the coalescer? pg. 5-13 to 5-15
Lights is collected at the
5 - Why does the organic phase being recycled?
top of the column,
- How does the tower operate? What is the mechanism for the Chart 5-5 Overall
whereas Ehol and
purification of Ehexanal? Process Flow for
heavies are collected at
- Diverse Heavies – What is Ehol? EHexanal Purification
the sump.
- Are there still some hydrogen off-gases from the hexanol tower? pg. 5-15
(iii) Chart 5-5 amended to
Where is the source of it?
reflect written
description. Both

condensate from heat
exchanger and post
condenser will be sent
through coalescer.
(iv) Organic phase from
phase separator still
contains Ehexanal which
can be extracted. The
separation concept is
using standard
distillation column
design where reflux is
required for the
separation.
(v) The 2-Ethylhexanal
column will opearate at
a slight vacuum by
withdrawing the off-gas
via the vacuum unit.
The separation concept
is using standard
distillation column
design where reflux is

required for the
separation.
(vi) EHol is Ethylhexanol.
Full name is added and
introduced in Section
5.3.2.2 and as listed in
the list of abbreviations
in page vi
(vii) The organic phase
recycled back to the 2-
Ethylhexanal
column/diverse heavies
into the 2-Ethylhexanol
column contains some
light residue, mainly
low boilers, i.e., butanol,
butylraldehyde,
heptane, heptene.
(i) Potassium is recycled to
Chart 2-6 Section 5.3.2.3
the oxidation reactor so
- Why is potassium recycled into the oxidation reactor? Oxidation of
that potassium
6 - The reaction heat is removed via two external chilled water coolers. EHexanal to EHAcid
ethylhexanoate is
But these coolers cannot be seen from the figure. pg. 5-17 to 5-18
generated. Potassium
- Draw a diagram showing the two reactions and retention time zones.
ethylhexanoate acts as a

modulator of the Chart 5-6 Diagram of
ethylhexanal oxidation Oxidation Reactor
and suppresses pg. 5-17
undesired side reactions.
(ii) Chart 5-7 has been Chart 5-7 Oxidation
amended to include of Ehexanal
chilled water coolers pg. 5-18
(iii) Diagram of the
oxidation reactor is
shown in Chart 5-6.
(i) The sump is heated via a
falling film evaporator
Chart 2-7
which runs with 23 barg
- How is the sump being heated via the falling film evaporator?
steam. Section 5.3.2.4
- What is the function of KOH?
(ii) A small quantity of KOH EHAcid Purification
- What is the function of the recuperator? Any output out of it?
is added to the tower pg. 5-19
- “The lights (i.e., trace of water, 3-heptylformate, 3-heptanon, 3-
feed to make up for the
7 heptanol, saturated and unsaturated C8-lactons) are taken off at the
potassium losses through Chart 5-8 EHAcid
top of the tower” – this cannot be seen from the figure. Lights only
the rectification tower Purification Process
comes out from the evaporator.
sump discharge. KOH Flow
- Highlight how the lights component are being generated.
acts as an inhibitor to the pg. 5-20
- The flow of EHAcid is not clear. Need to provide descriptions which
reaction so higher
is in accordance with the given chart.
percentage of selectivity
can be achieved.

(iii) Amendments has
been made to Chart 5-8
(iv) Separation of
component is based on
boiling temperature that
occurs within the tower.
(v) Section 5.3.2.4 has been
restructured for better
flow
Chart 5-9a Mass
Balance for
Wastewater
Treatment Process of
Existing Wastewater
Treatment Plant
Chart 2-8 Process flow for existing
pg. 5-24
8 The materials in and out at the equalization tank are not balanced – recheck WWTP is shown in Charts 5-9a
values and calculations and 5-9b.
Chart 5-9b Mass
Balance for
Dewatering Process
of Existing Wastwater
Treatment Plant
pg. 5-25

Chart 5-2 Overall
Mass Balance for
Average Production
Capacity of 30,000
MT/a
Section 6 pg. 5-7
Overall mass balance can be
9 When determining impacts to the environment, specify the exact amount of
referred in Charts 5-2 and 5-3.
the chemicals being released in the output streams Chart 5-3 Overall
Mass Balance for
Maximum
Production Capacity
of 36,000 MT/a
pg. 5-9

Table 2-2 Comments from TOR Endorsement
Reply from Project Proponent / Reference in the
No. Items in TOR EIA Consultant EIA Report DOE Comments
Bil. Perkara dalam “TOR” Maklumbalas Penggerak Projek / Rujukan dalam Ulasan JAS
Jurunding EIA Laporan EIA
Section 6.3.2
Ensure policy issues are finalized prior to the submission of the EIA Existing Land
report. The approved EIA report must be in accordance with the Local Use Within 5 km
Plan as specified in Section 34A(4)(a), Environmental Quality Act (EQA) of the Project Site
The EIA report is in line with the
1974. pg. 6-3
Local Plan as specified in Section
1
34A(4)(a), Environmental Quality
Memastikan isu-isu polisi dimuktamadkan terlebih dahulu sebelum Section 6.3.3
Act (EQA) 1974.
pengemukaan Laporan EIA. Laporan EIA yang diluluskan perlu selaras Future Land Use
dengan Rancangan Tempatan Daerah (RTD) sebagaimana yang dinyatakan Within 5 km of
dalam Seksyen 34A(4)(a), Akta Kualiti Alam Sekeliling (AKAS) 1974. the Project Site
pg. 6-10
All requirements from agencies and Appointed Individuals (AIs)
submitted, including the comments either in writing or discussed during Table 2-1 Written
the meeting shall be considered in the EIA Report. The format of Comments from
feedback for the comments is as per Lampiran 1. Agencies,
Comments from agencies and AIs Technical
2 Kesemua keperluan daripada agensi-agensi dan Individu Yang Dilantik are replied according to the format, Departments and
(Appointed Individuals, AIs) yang dikemukakan kepada pihak tuan termasuk and can be referred in Table 2-1 Appointed
ulasan sama ada secara bertulis atau yang dibincangkan semasa mesyuarat Individuals and
hendaklah diberikan perhatian yang sewajarnya dalam Laporan EIA. Format Meeting Minutes
maklumbalas kepada ulasan bertulis yang akan diterima kelak adalah seperti di pg. 2-2 to 2-62
Lampiran 1.

The EIA team leader must ensure that the team member is a consultant
registered with the Department of Environment, and ensure that the
List of EIA
registration is still valid.
EIA consultant registration for all Consultants
3
team members are still valid. Involved in the
Ketua pasukan kajian EIA perlu memastikan ahli pasukan merupakan
EIA Study
jururunding yang berdaftar dengan Jabatan Alam Sekitar dan masih belum
tamat tempoh sahlaku.
Ensure that the information and data (Figure, Table) provided are
consistent in the EIA report.
Information and data provided are
4 -
checked for consistency.
Memastikan maklumat dan data (Figure, Table) yang disediakan adalah selaras
di dalam laporan EIA yang disediakan.

Section 7.4.1 Air
Quality
pg. 7-7 to 7-8
Section 7.4.3
Water Quality
pg. 7-12 to 7-17
The EIA for this proposed Project should emphasize on the 3 main
Section 7.4.4
components, namely water, air and waste management. The proposed
Waste
pollution control measures should also be explained in detail for the The three main components, water,
Management
critical issues identified. air and waste management
pg. 7-17 to 7-19
5 impacts and pollution control
Kajian EIA bagi cadangan projek ini hendaklah memberikan penekanan kepada measures are detailed in the EIA
Section 7.5.1 Air
3 komponen utama kajian iaitu air, udara, dan pengurusan sisa serta langkah- report.
Quality
langkah kawalan pencemaran yang dicadangkan juga perlu dijelaskan dengan
pg. 7-23 to 7-47
spesifik dan terperinci bagi isu-isu kritikal yang dikenalpasti.
Section 7.5.5
Water Quality
pg. 7-80 to 7-88
Section 7.5.7
Waste
Management

pg. 7-89 to 7-93
The EIA should also take into account key issues such as: Impact assesments for health,
a) Health Impact Assessment (HIA) as Sungai Balok and Pantai quantitative risk, socio-economic
Balok function as water receiving bodies as well as public study, water quality, air quality,
recreational locations; noise and waste management are
b) Quantitative Risk Assessment, which includes the risk of fire detailed in Section 7
and exposion arising from pipeline and storage of 2-EHAcid, a) Health Impact Assessment
hydrogen, Oxo oil, ethanol and n/Iso-butanol during the can be referred in Section
operation stage; 7.5.8
c) Socio-economic study of local residents and aquaculture farms b) Quantitative Risk
involved; and Assessment can be
Section 7
d) Study on the impact on water quality, air quality, noise, and referred in Section 7.5.4
Evaluation of
6 waste management, especially the area around the coast and and Appendix H
Impacts
also the Project site. c) Socio-economic study can
pg. 7-1 to 7-130
be referred in Sections
Kajian EIA juga perlu mengambilkira isu-isu utama seperti: 7.4.5 and 7.5.7
a) Kajian Health Impact Assessment (HIA) memandangkan Sungai d) Water quality impact
Balok dan Pantai Balok berfungsi sebagai badan penerima air serta assessments can be
lokasi rekreasi awam; referred in Sections 7.4.3
b) Quantitative Risk Assessment antaranya merangkumi risk of fire and and 7.5.5. Air quality
explosion arising from pipeline and storage of 2-EHAcid, hydrogen, impact assessments can be
oxo oil, ethanol and n/Iso-butanol di peringkat operasi; referred in Sections 7.4.1
c) Kajian sosio-ekonomi penduduk setempat dan penternak akuakultur and 7.5.1. Noise impact
yang terlibat; dan assessments can be

d) Kajian berkenaan impak terhadap kualiti air, kualiti udara, bunyi referred in Sections 7.4.2
bising dan pengurusan sisa bungan terutamanya di kawasan sekitar and 7.5.3. Waste
pantai dan tapak projek. management impact can
be referred in Sections
7.4.4 and 7.5.6.
Impact assessments and mitigation measures that include the following:
a) Buffer zones with sensitive receptors, such as populated
dwellings, water bodies, etc., shall be identified and given prime
attention during project planning and construction stage to
maintain sustainable conditions and implementation of effective
Section 7
pollution control measures;
Evaluation of
b) Take into account the current situation and future conditions
Impacts
with the addition of future phases;
pg. 7-1 to 7-130
c) Propose appropriate pollution control measures and pollution Impact assessments and mitigation
7 control equipment to reduce impact based on impact assessment measures are detailed in Sections 7
Section 8
modelling carried out based on the worst case scenario; and and 8.
Proposed
d) State the impact based on the worst case scenario, including the
Mitigation
cumulative impact from the proposed Project.
Measures
pg. 8-1 to 8-36
Kajian impak dan langkah-langkah kawalan yang merangkumi perkara-perkara
berikut:
a) Zon penampan dengan kawasan penerima sensitif seperti kediaman
berpenduduk, badan air, dan lain-lain hendaklah dikenalpasti dan
diberi perhatian utama semasa kerja-kerja perncangan dan pembinaan

projek bagi memelihara keadaan yang lestari dan pelaksanaan langkah-
langkah kawalan pencemaran yang berkesan.
b) Mengambilkira keadaan semasa (current) dan keadaan akan datang
dengan pertambahan bagi fasa-fasa akan datang;
c) Mencadangkan langkah kawalan pencemaran dan alat kawalan
pencemaran yang bersesuaian untuk mengurangkan impak
berdasarkan kepada ramalan rawatan impak (modelling) dalam
keadaan worst case scenario; dan
d) Menyatakan impak dalam keadaan worst case scenario termasuk
cumulative impact daripada cadangan projek.
The baseline study should be based on the current situation at the site,
which is the existing sensitive receptor and from existing data (process
develop from the primary and secondary data). The expected impact
must take into account the worst case scenario (no control) and the worst
Baseline studies can be referred in Section 6 Existing
weather conditions.
8 Section 6. Environment
pg. 6-1 to 6-105
Kajian garisdasar hendaklah berdasarkan keadaan semasa di tapak yang
merupakan penerima sensitif sedia wujud dan dari data-data sediada (process
develop from the primary and secondary data). Jangkaan impak perlu
mengambilkira worst case scenario (no control) dan keadaan cuaca terburuk.
The information and data used in the EIA study must be current and
take into account the need for the use of data over the recent years as a
9 Information used are up to date -
comparison.

Maklumat dan data yang digunakan di dalam kajian EIA perlulah terkini
(current data) dan mengambilkira keperluan penggunaan data-data sepanjang
tahun kebelakangan sebagai perbandingan.
Each findings from the environmental impact study conducted must
have a proposal/plan of control measures and the method for
implementation to ensure that there is no environmental impact towards Section 8
the existing policies and conditions. Mitigation measures for the Proposed
10 potential impacts can be referrd in Mitigation
Setiap penemuan dari kajian impak alam sekitar yang dijalankan hendaklah Section 8 Measures
mempunyai cadangan/pelan langkah kawalan dan kaedah langkah kawalan pg. 8-1 to 8-36
tersebut dilaksanakan untuk memastikan tiada impak alam sekitar terhadap
garisdasar dan keadaan sediada.
The Consultant is aware that the
Project site is located within the
flood risk area. However, as the
Seeing that the area is located in the Flood Prone Area as per the Flood increase of wastewater generation
Section 6.5.3.1
Prone Area map in the Rancangan Tempatan Daerah Kuantan 2035 from Project (0.04 m3/hr) is small,
Existing Flood
(Penggantian), flood risk should be considered. there is no potential for the
11 Risk Mitigation
Project’s activities to cause
and Action Plans
Risiko banjir memandangkan kawasan adalah terletak dalam peta Flood Prone flooding to the surrounding.
pg. 6-34 to 6-37
Area dari Rancangan Tempatan Daerah Kuantan 2035 (Penggantian).
Nonetheless, the Consultant has
checked with JPS Pahang and was
informed that there were currently

no flood mitigation programs
specifically for Sg. Balok. Even so,
existing flood risk mitigations and
action plans to mitigate flood
issues on both national and
regional levels are detailed.
Findings related to the latest environmental audit under the Latest environmental audit by
requirements of Section 33A of the Environmental Quality Act. third party conducted from 19 – 20
12 January 2022 reported a total of 8 -
Penemuan berkaitan dengan audit alam sekitar yang terkini di bawah keperluan good practices and 0 non-
Seksyen 33A Akta Kualiti Alam Sekitar. compliances and observations.
Based on the latest directives, the implementation of this Project should Table 2-1 Written
take into account all the needs and requirements of the relevant agencies, Comments from
and the details should be stated in the EIA report and updated in the Agencies,
The needs and requirements of the
EMP document. Technical
relevant agencies are taken note
13 Departments and
and details are stated in the EIA as
Berdasarkan arahan terkini, pelaksanaan projek ini hendaklah mengambilkira Appointed
per the replies in Table 2-1.
semua keperluan dan kehendak agensi-agensi yang berkaitan, dan perkara Individuals and
tersebut hendaklah dinyatakan di dalam Laporan EIA dan dikemaskini di dalam Meeting Minutes
dokumen EMP. pg. 2-2 to 2-63
Table 2-1 Written
Taking into account comments from the Ministry of Health Malaysia and Comments from Ministry of
Comments from
14 other comments from agencies, NGOs and Appointed Individuals. Health Malaysia and all other
Agencies,
comments from agencies, NGOs
Technical

Mengambilkira ulasan daripada Kementerian Kesihatan Malaysia dan lain-lain and Appointed Individuals are Departments and
ulasan agensi, NGO dan Individu yang Dilantik. taken into account. Appointed
Individuals and
Meeting Minutes
pg. 2-2 to 2-63
The EIA prepared must also follow the Environmental Impact
Assessment Guidelines in Malaysia 2016 published by the Department
of Environment. The EIA preparation follows the Section 1.5 Scope
15 Environmental Impact Assessment of EIA Study
Kajian dan laporan EIA yang disediakan juga perlu mengikut garispanduan Guidelines in Malaysia 2016 pg. 1-9
Environmental Impact Assessment Guidelines in Malaysia 2016 yang
diterbitkan oleh Jabatan Alam Sekitar.
For all EIA reports that are being evaluated, the complete EIA report
must be made available on the official website of this Department.
Therefore, a copy of the CD containing a softcopy of the EIA report in Executive
Softcopy reports are prepared and
pdf format must be submitted to the Headquarters of Department of Summary
burned in a CD in pdf format.
Environment and a copy to the Pahang State Department of pg. ES-i to ES-xviii
Environment. The Executive Summary infographics, in softcopy format,
16 Executive Summary and Ringkasan
must also be submitted separately with the softcopy of the EIA report Ringkasan
Eksekutif are prepared containing
for display purposes on the Department’s official website. In addition to Eksekutif
the relevant information and
the summary of the issues and results of the study, the contents of the pg. RE-i to RE-
details.
Executive Summary should also contain the following: xviii
• Name/title of Project
• Name of the Project Proponent

• Name of the EIA Consultant (firm)
• Location of the project (including where applicable, coordinates,
lot numbers, mukim and district name)
• Relevant maps showing project location and sensitive receptors
• Summary of impacts, mitigating measures and implementation
method
Dimaklumkan bahawa Laporan EIA yang lengkap bagi semua Laporan EIA
yang sedang dinilai perlu dipaparkan di dalam web rasmi Jabatan ini. Oleh yang
demikian, sesalinan CD yang mengandungi ‘soft copy’ Laporan EIA berkenaan
(format pdf) hendaklah dikemukakan kepada Jabatan Alam Sekitar Ibu Pejabat
dan sesalinan kepada Jabatan Alam Sekitar Negeri Pahang. Di samping itu,
infografik Ringkasan Eksekutif dalam bentuk ‘soft copy’ juga hendaklah
dikemukakan secara berasingan dengan ‘soft copy’ Laporan EIA untuk tujuan
paparan di laman web rasmi Jabatan ini. Selain daripada ringkasan isu dan
keputusan kajian, kandungan Ringkasan Eksekutif hendaklah juga
mengandungi perkara-perkara berikut:
• Name/title of Project
• Name of the Project Proponent
• Name of the EIA Consultant (firm)
• Location of the project (including where applicable, coordinates, lot
numbers, mukim and district name)
• Relevant maps showing project location and sensitive receptors

• Summary of impacts, mitigating measures and implementation
method
All raw data used as input in the EIA study must also be submitted in
hardcopy format in the EIA main report or as an appendix. A copy of the
CD containing a softcopy of the data must also be submitted to the
Headquarters of Department of Environment. Only analysis conducted
by SAMM accredited laboratories are accepted in the EIA study and the Raw data are attached as appendix
results shall be included in the EIA report. and provided in softcopy in CD. Appendix F
Baseline
17
Pihak tuan juga hendaklah mengemukakan semua data mentah (raw data) yang Lab report from SAMM accredited Monitoring
digunakan sebagai imput di dalam kajian EIA, dalam bentuk ‘hard copy’ di laboratory can be referred in Report
dalam ‘EIA Main Report’ atau sebagai apendiks. Manakala sesalinan CD yang Appendix F.
mengandungi ‘soft copy’ data berkenaan hendaklah dikemukakan kepada
Jabatan Alam Sekitar Ibu Pejabat. Hanya analisa yang dijalankan oleh makmal
yang mempunyai Sijil Akreditasi (SAMM) diterima di dalam kajian EIA dan
keputusannya hendaklah dimasukkan ke dalam Laporan EIA.

03 STATEMENT OF NEED
Section 3
STATEMENT OF NEED
SECTION 3 : STATEMENT OF NEED
3.1 NEED FOR THE PROJECT
3.1.1 Increasing Demand in 2-EHAcid
The Project aims to produce an additional maximum of 36,000 MT/year of 2-

ethylhexanoic acid which is widely used in the production of synthetic lubricants, as
well as oil additives. It is also used for functional fluids like automotive coolants,
metal salts for paint dryers, plasticizers, stabilizers, catalysts, and other applications
in various industries. With the addition of this plant, the Project Proponent is
expecting to respond to their customers’ growing demands in Asia-Pacific. The
global 2-ethylhexanoic acid market was valued over US$ 908.6 Mn in 2020 and is
anticipated to expand at a compound annual growth rate (CAGR) of 6.3% from 2021
to 2031 (Chart 3-1).
Chart 3-1 Expected Global 2-EHAcid Market Based on CAGR of 6.3%

(from 2020 to 2031)
2031
2020 US$ 1,779 Mn
6.3%
US$ 908.6 Mn (forecast value)
Source: Transparency Market Research, 2020
This is driven by the rise in the demand for PVB plasticizers and PVC stabilizers,
where the Asia-Pacific region accounted for about 57% of global demand for
plasticizers in 2017 (Chart 3-2). With the growth rate of 3.2% per year for plasticizers,
the demand of 2-EHAcid in this region is expected to rise to about 6 million tonnes
by the end of 2024. This is mainly driven by the rise in the number of automotive and
construction activities. Also, the use of plasticizer in wall and floor coverings,
consumer goods, coated fabrics, film and sheet, among others is boosting the demand
in the region.

Chart 3-2 Global Consumption of Plasticizers in 2017
1.4% 1.4%
1.6% 1.3%
1.6% China
3.6%
Western Europe
3.6%
United States
India
4.0%
Japan
4.0% 42.0%
Eastern Europe
5.0% South Korea
Middle East
11.0% Brazil
Central/South America
14.0% Africa
Thailand
Source: Sheikh and Beg, 2019
3.1.2 Stimulating Local Economy
Malaysia is a developing country which adopts an open economy system. The

economic structure of Malaysia is namely based on three main pillars, namely
industry, agriculture and service industries. Even though the Malaysian economic
performance contracted by 5.6% in 2020 compared to 4.4% in the preceding year due
to the measures to curb the spread of the COVID-19 pandemic, the national economy
is expected to rebound in 2022 as activities in the manufacturing, services and
agriculture sectors have picked up (Chart 3-3).
Due to Malaysia’s unique geographical advantage in imports and exports, Malaysia

is seen to have the potential to expand in the service industry and prompt the growth
of GDP. Main export products are found to be electronics and electrical appliances,
petrochemical, chemical products, palm oil and its processed products, liquefied
natural gas, and mechanical equipment and accessories.
With the production of a high-quality specialty chemical like 2-EHAcid, this Project
is expected to contribute to the achievement in Malaysia’s economic growth by
increasing the export capacity. This is also in line with one of the key strategic
initiatives of the East Coast Economic Region (ECER) Master Plan 2.0 (Chart 3-4).

Chart 3-3 Malaysia’s Economic Performance in 2020
Chart 3-4 One of the Key Strategic Initiatives of ECER Master Plan 2.0
Source: ECER Master Plan 2.0


04 PROJECT OPTIONS
Section 4
PROJECT OPTIONS
SECTION 4 : PROJECT OPTIONS
4.1 INTRODUCTION
The following Project alternatives have been identified and assessed in the process
of establishing the optimum design:
• No Project Alternative
• Technology Alternative
The alternatives are briefly described below and will be further discussed in the EIA
report.
4.2 NO PROJECT ALTERNATIVES

In the event where the Project will not be developed, the site will remain unoccupied.
Potential benefits in social, economic and technology which may be lost includes:
• High capital investment;

• Downstream benefits – products will open up numerous possibilities for
downstream projects in Malaysia;
• Service sector benefits – Project will stimulate local and national
service/supply industries such as maintenance services, telecommunications,
transport, shipping, port handling, freight, insurance, warehousing, banking
and financial services, etc.; and
• Macro-economic benefits – A large proportion of output will be exported
generating incremental export revenues.
4.3 TECHNOLOGY ALTERNATIVES
4.3.1 Production Method
2-Ethylhexanoic acid can be produced through a few different methods using

different raw materials. A comparison summary of the production methods can be
referred in Table 4-1.

Table 4-1 Comparison of 2-Ethylhexanoic Acid Production Methods
Main Raw
Method Advantages1,2,3,4 Disadvantages1,2,3,4,5
Material
Requires supporting
• Significantly less electrolytes to carry the
energy requirement current which can be
Electrochemical
2-ethylhexanol • Less hazardous expensive or even
synthesis
process become a pollutant if
• Process is simpler not recovered or
recycled
• Lower product
• High-selective
Catalytic yield
2-ethylhexanol method
Oxidation • More by-products
• Efficient process
produced
• Can be produced • Lower product
under atmospheric yield
Catalytic
2-ethylhexanol pressure • Lower selectivity
dehydrogenation
• Relatively high • More by-products
product purity produced
• Short reaction
• Highly dependent
period
on the aldehyde
• Less by-products
structure
• Lower cost
Oxidation 2-ethylhexanal • Highly exothermic
• Higher product
reaction, so efficient
yield
temperature control
• Higher product
is critical
purity
Sources:
1. China Patent No. CN1410407A, 2001
2. Weinberg, 2002
3. Rudik, Avrutskaya, & Fioshin, 1987
4. Li Hong-ya et al., n.d.
5. Vanoye et al., 2015
The manufacturing of 2-EHAcid from oxidation of 2-ethylhexanal is preferred due

to its advantages over the other production methods.

05 PROJECT DESCRIPTION
Section 5
PROJECT DESCRIPTION
SECTION 5 : PROJECT DESCRIPTION
5.1 PROJECT CONCEPT

The scope of this Project includes:
• An open-air 2-EHAcid production plant with proposed maximum
production capacity of 36,000 MT/a;
• Modification of an existing tank farm (Plate 5-1);
• Replacement of existing residue tank with 170m3 organic residue tank (Plate
5-2);
• Addition of new loading arm at Bay 6 (Plate 5-3);
• Addition of feed pump at oxo tank farm (Plate 5-4); and
• Addition of new equipment in existing 2-EHAcid plant (Plant I).
This proposed Project will utilize the existing infrastructures and utilities of the
existing Oxo facilities, such as the control room. Rack room and MCC room of C300
blockfield will be shared for both existing 2-EHAcid plant and the Project (new 2-
EHAcid plant). This Project will also be sharing treatment facilities such as the ICS’s
centralized wastewater treatment plant, and the product loading and packaging
facility at the ICS (Plates 5-6, 5-7 and 5-8).
Plate 5-1 Existing Tank Farm Plate 5-2 Existing Residue Tank
Source: BASF PETRONAS Chemicals Sdn. Bhd.

Source: BASF PETRONAS Chemicals Sdn. Bhd.
(2021)
(2021)

Plate 5-3 New Loading Arm at Bay 6
Plate 5-4 Existing Oxo Tank Farm

Plate 5-5 Centralized Wastewater Treatment Plant at ICS
Plate 5-6 Product Loading Facility at ICS (Drums)

Plate 5-7 Product Loading Facility at ICS (Gantry)
5.2 PROJECT COMPONENTS

The proposed Project comprises of the four key processes where the Project layout
can be referred in Figure 5-1:
a) Selective hydrogenation process;
b) EHexanal purification process;
c) Oxidation process; and
d) EHAcid purification process.
A list of key components for the Project and new equipment to be added to the
existing 2-EHAcid plant can be referred in Table 5-1.

Table 5-1 Key Project Components
Plant Process Key Components
Steam provision
• Condensate buffer drum
Existing Plant system
• Desuperheater
(2-EHAcid (supplementary
• Flash Condenser
Plant I) system)
Oxidation process • Stripping column
• Hydrogenation reactor
Selective
• Chilled water cooler
hydrogenation
• Water cooler
process
• Liquid gas separator
• 2-Ethylhexanal column
• Falling film evaporator
• Water cooler
• Heat exchanger
• Coalescer
• Post condenser
• Hexanal column phase separator
EHexanal
• Water cooler
purification process
• Hexanal buffer drum
• Organic residue drum
Project Site • 2-Ethylhexanol column
(2-EHAcid • Chilled water cooler
Plant II) • Hexanol column overhead drum
• Cooler
• Oxidation reactor
• Chilled water cooler
Oxidation process • Chilled water cooler
• Oxidation product drum
• 2-EHAcid stripping column
• 2-EHAcid dividing wall column
• Recuperator
• Water cooler
EHAcid purification
• Post condenser
process
• 2-EHAcid Column Overhead Drum (1)
• 2-EHAcid Column Overhead Drum (2)
• Water cooler
• 2-EHAcid product tank

5.3 PROCESS DESCRIPTION
The process for the production of 2-EHAcid consists of four steps as mentioned in
Section 5.2. The production of 2-EHAcid involves two main chemical reactions:
Hydrogenation : C8H14O + H2 → C8H16O

(2-ethylhexenal) (hydrogen) (2-ethylhexanal)
Oxidation : C8H16O + ½ O2 → C8H16O2

(2-ethylhexanal) (oxygen) (2-ethylhexanoic acid)
Chart 5-1 shows the overall diagram of the process.
Section 5.3.2 details the 2-EHAcid production process based on the four main steps.
Chart 5-1 Overall Process Diagram of 2-EHAcid Production
Lights
H2 off-gas (aq. + org.) O2 off- Lights
H2
gas
EHexanal Purification
EHAcid Purification
EHAcid
Hydrogenation
EHexenal EHexanal EHAcid

EHexanal
Oxidation
>99.5%
Selective
~96% ,>99% ~95%

~95%
O2
Heavies
KOH make Heavies & Heavies
up K-Recycle purge
Note:
1. Source: BASF PETRONAS Chemicals Sdn. Bhd. (2021)
2. Detailed process description can be referred in Section 5.3.2
3. aq. represents aqueous, and org. represents organic
4. K-Recycle represents the potassium ion (K+) recycling stream

5.3.1 Raw Materials, Modulator and Products
The main raw materials used are 2-ethylhexenal, hydrogen gas, and oxygen gas. The
modulator used in this process is potassium hydroxide, whereas the product is 2-
ethylhexanoic acid.
The characteristics of the raw materials, modulator and product are described in the
following sections and their safety data sheets (SDS) are appended in Appendix C.
5.3.1.1 2-Ethylhexenal
2-Ethylhexenal will be supplied by the Oxo complex located adjacent to the existing
2-ethylhexanoic acid plant. The 2-Ethylhexenal is produced from aldolization of n-
butyraldehyde. 2-ethylhexenal is an aldehyde which is a colorless to yellowish liquid
with pungent odour. It has a very low solubility in water of 2 g/l at 20˚C.
5.3.1.2 Hydrogen
Hydrogen gas will be supplied by the pipeline from the Syngas Complex to the
Project Site. At standard temperature and pressure, hydrogen is a colorless, odorless,
tasteless, non-toxic, nonmetallic, highly combustible diatomic gas with the molecular
formula H2.
5.3.1.3 Oxygen
Generally, oxygen is the third-most abundant element in the universe after hydrogen
and helium. It is colorless, odorless and tasteless. Oxygen gas (O2) will be unloaded
and vaporized from an ISO tank truck into a 50m3 tank and supplied to the process.
5.3.1.4 Potassium Hydroxide
Potassium hydroxide is an inorganic compound with the formula of KOH,

commonly called as caustic potash. It is highly basic, forming strongly alkaline
solutions in water.
5.3.1.5 2-Ethylhexanoic Acid
2-Ethylhexanoic acid is the organic compound with the formula

CH3(CH2)3CH(C2H5)CO2H. It appears as a colorless to yellow liquid. The melting
point of 2-ethylhexanoic acid is about -59˚C while the boiling temperature is between

226 and 229˚C. It will be sold and transported in the forms of iso-tank truck or in
drums.
5.3.2 Main Production Processes
5.3.2.1 Selective Hydrogenation of EHexenal to EHexanal
2-EHexenal is fed to the circulation stream of the hydrogenation reactor which is

filled with a fixed bed catalyst. This combined liquid stream and hydrogen are
introduced to the top of the reactor. After passing through the reactor, the gas and
liquid phases are separated from each other in the liquid gas separator.
The gaseous discharge is cooled down via the chilled water cooler and sent to the off-
gas treatment (flare). A major part of the liquid product collected in the liquid gas
separator is circulated via a pump back to the reactor. The reaction heat is efficiently
removed via the water cooler. A small part of the liquid crude product is directly
released from the liquid gas separator into the 2-Ethylhexanal column for
purification.
5.3.2.2 Purification of EHexanal
The crude EHexanal from the hydrogenation is purified in the 2-Ethylhexanal

column. The feed is introduced to the lower part of the column. The sump of the
column is heated via evaporator. The column will operate at a slight vacuum by
withdrawing the off-gas via the vacuum unit.
The lights are removed overhead from the column then condensed in a water cooler
before further cooled by a heat exchanger. The cooled condensate and the condensate
of the post condenser will be further sent through a coalescer and collected in the
hexanal column phase separator, where the organic phase and the aqueous phase are
separated from each other.
The aqueous phase will be sent to the wastewater treatment plant (WWTP) or
collected in a wastewater drum. Majority of the organic phase returns as reflux to the
tower. A small purge of the organic phase is taken off and collected in the organic
residue drum. Pure EHexanal (>99% purity) is withdrawn in liquid form as a side
stream and is cooled via water cooler before it is collected in the hexanal buffer drum.
The sump of 2-Ethylhexanal column containing diverse heavies is introduced to the

lower part of the 2-Ethylhexanol column.
The products, EHexenal, EHexanal, and Ethylhexanol (EHol), are taken off from the
top, condensed via a chilled water cooler and collected in the hexanol column

overhead drum. A part of these products returns to the column as reflux, while the
rest is planned to be sent back via the cooling water plate heat exchanger to the
hydrogenation step of the 2-ethylhexanol process in the Oxo-complex.
The bottom stream of the 2-Ethylhexanol column is taken off and cooled down. A
part of the sump product is sent as sealing liquid to the vacuum units of both the
current and existing 2-EHAcid Plants (Plant I and Plant II). The rest is sent to organic
residue drum, where it will be sent to Oxo oil 900 for blending. The 2-Ethylhexanol
column operates at a slight vacuum.
If the 2-Ethylhexanol column is not in service, the sump of the 2-Ethylhexanal column
containing diverse heavies is sent to the 2-Ethylhexanol column’s cooler directly.
5.3.2.3 Oxidation of EHexanal to EHAcid
Purified EHexanal from the hexanal buffer drum is pumped into the first circulation
loop.
The potassium containing recycle stream from the bottom of the column is fed into
the first circulation loop. Potassium ethylhexanoate suppresses undesired side
reactions. The reaction heat is removed via the two external chilled water coolers.
After passing through the retention time zone, which is at the top of the oxidation
reactor, the crude production of the oxidation flows to the oxidation product drum,
where the off-gas is separated from the liquid product. The off-gas is released and
forwarded to the citral cluster airbox of thermal oxidizer at the Aroma complex.
The liquid product is sent to the 2-EHAcid stripping column for removal of traces of
unreacted oxygen. In the 2-EHAcid stripping column, nitrogen gas is introduced as
the stripping agent to remove the unreacted oxygen from the liquid stream. The
stripper off-gas is sent to off-gas disposal. From the stripper bottom, the liquid
product is sent to the dividing wall column for final purification.
5.3.2.4 EHAcid Purification
The crude liquid EHAcid from the bottom of the 2-EHAcid stripping column is
pumped to the dividing wall column and pre-heated in the recuperator. The 2-
EHAcid dividing wall column is operated at a vacuum. A small quantity of aqueous
potassium hydroxide is added to the tower feed to make up for the potassium losses
through the dividing wall column sump discharge.
The off-gas is withdrawn the by a vacuum unit and sent to the airbox of thermal
oxidizer for off-gas disposal.

Separation of component is based on boiling temperature that occurs within the
column. The lights are taken off at the top of the column, condensed via water cooler
and collected in the 2-EHAcid column overhead drum (1). Organic condensate is
taken off from the drum at a side nozzle. The majority of the condensate returns to
the column as reflux, a minor stream is purged and collected in organic residue drum.
If the condensate is rich in water, a heavy phase may form which can be discharged
from the overhead 2-EHAcid column overhead drum (1) via the bottom outlet.
The trace amount of water containing off-gas of water cooler is sent to the post
condenser E 4511 which is operated with chilled water. The condensate is collected
the 2-EHAcid column overhead drum (2) and purged to organic residue drum.
The sump is heated via falling film evaporator. A major part of the bottom stream is
recycled to the oxidation reactor for recycling of potassium. In order to prevent the
heavies from accumulating in the column and in the oxidation reactor, a small purge
is taken off from the bottom stream of the dividing wall column and sent to the Oxo
complex for blending into Oxo Oil 900.
Pure EHAcid (>99.5%purity) is withdrawn in liquid form as side stream (controlled

via level in the tower) and cooled via the recuperator, which has heat integration
with the feed stream to the dividing wall column. Then it is sent to the product tank
after further cooling down via water cooler.
5.3.3 Off-Gas & Waste Disposal
Off-gas containing H2 from hydrogenation reactor, 2-Ethylhexanal column and 2-

Ethylhexanol column are combined and sent to an H2 off-gas separator, and this will
further go to the bi-flare.
Off-gas containing O2 from the oxidation reactor and stripper column are combined
and sent to the airbox of thermal oxidizer.
Aqueous phase from the phase separator which contain dissolved organic
compounds like butanal or butanol will be sent to the wastewater treatment plant
(WWTP) or collected in wastewater drum temporarily.
The potassium-free organic residues are collected in the organic residue drum. From
there, they will be blended to the Oxo Oil 900 tank of the Oxo Complex. The Project
Proponent uses the concept of circular economy to efficiently manage material flows
within the Integrated Chemical Site, and the by-products coming from one plant
often serve as feedstocks for another plant, avoiding wastes. Hence, the Project
Proponent has been studying the option to blend organic residues generated from
the Project with the existing Oxo oil 900 and found out that this option is viable. This

will help to further reduce their demand for primary resources, and at the same time,
help to reduce waste generation through better recycling. This is part of their plan to
reduce solid and liquid waste on site. Potassium-containing organic residue is sent
to the Oxo oil 900 tank at the Oxo Complex directly.
5.3.4 Existing Wastewater Treatment Plant
Process wastewater will be pumped to the existing wastewater treatment plant

(WWTP) within the ICS compound. The existing WWTP is designed to treat both
sewage and process wastewater via aerobic process. Since the wastewater treated is
a mixture of sewage and process wastewater, the mixed effluent quality is subjected
to the standard limits (Standard B) stipulated in the Fifth Schedule of the
Environmental Quality (Industrial Effluent) Regulations 2009.
The total amount of wastewater generated from the Project (2-EHAcid Plant II) only
contributes to 0.67% COD loading to the total COD load that the existing WWTP can
treat.
Raw effluent from process plants and sewage within the ICS compound will be tested
for COD loading first prior to discharging to the WWTP. The frequency of the test is
dependent on the COD loading of the raw effluent. If the wastewater does not meet
the COD loading criteria, it will be mixed within the temporary wastewater storage
tank first until the COD loading meets the requirements before it is discharged into
the WWTP for treatment. The raw effluent will go through a bar screen for removal
of solids and then to the equalization tank to equalize the flowrate of the incoming
wastewater.
It then passes through the neutralization tank where the pH level of the wastewater
is preconditioned into aerobic pH requirement of 7. The wastewater will then be
channeled to the primary sedimentation tank where the liquid and solid streams are
separated. The liquid stream will go to the aeration tanks and then the secondary
sedimentation tank for further separation of solids before effluent is discharged. The
solid streams from both primary and secondary sedimentation tank will go to the
sludge thickener tank. Sludge is then transferred to the belt press where filtrate is
pressed out and remaining sludge will form sludge cake. The filtrate is recycled back
into the equalization tank of the wastewater treatment plant, while the sludge cake
is then disposed as a scheduled waste (SW 204).

5.3.5 Air Pollution Control Systems
5.3.5.1 Flare
Off-gas containing H2 from the production process will be sent to the flare, where it
is ignited by the pilot light from the flame front generator. Instrument air and fuel
gas flow through a mixer/ignition box and are sent to one of the pilots by opening a
solenoid valve on the appropriate line. The flow of air and gas are controlled by the
pressure-control valve (PCV) on each line. Once the pilot is ignited, the lines are
closed, but fuel gas continues to feed the flame through a separate line drawn off
upstream of the ignition box.
5.3.5.2 Thermal Oxidizer
Off-gas containing O2 from the production process will be sent to the airbox of the
existing thermal oxidizer at the Aroma plant. The purpose of the thermal oxidizer is
for proper oxidation of off-gases, where they will be destroyed by exposing them to
high temperatures for sufficient time. The high temperatures were reached by means
of natural gas combustion. The thermal oxidizer was designed in a manner that the
residence time of the off-gases within the high temperature area does not drop below
the minimum required temperature.
5.4 PLANT UTILITY
5.4.1 Electricity Consumption
Both low voltage and high voltage electrical power are required for this Project. Low
voltage electricity is required in both the new 2-EHAcid plant (Project Site) and some
addition at the tank farm.
5.4.2 Steam and Condensate Consumption
Low-pressure steam, high-pressure steam and raw condensate are used in the 2-
EHAcid production process.
5.4.3 Water Consumption and Refrigeration
Water consumption for the Project includes boiler feed water, cooling water, potable
water, fire-fighting water and demineralized water. Chilled water is also used for
refrigeration for the production of 2-EHAcid.

5.5 PRINCIPAL PROJECT ACTIVITIES
5.5.1 Pre-Construction Phase
During the pre-construction phase, a list of the following activities will be carried out:
• Environmental impact assessment;
• Site reconnaissance;
• Stakeholder engagement;
• Finalization of plant layout and design work; and
• Agency approvals.
Pre-construction planning will also involve the negotiation of utilities supply, for
instance, electricity and water supply with the respective agencies and infrastructure
provision of the area.
Stakeholder engagement was undertaken as an opportunity to create an

understanding about the Project among likely affected or interested parties, and to
learn how these external parties view the Project and its attendant risks, impacts,
opportunities, and mitigation measures.
5.5.2 Construction Phase
The development of the Project takes a period of twenty-one (21) months (from
November 2022 to July 2024). The construction works will take nineteen (19) months
and equipment installation will take six (6) months. The commissioning stage will
take two (2) months. There will be a total of approximately 250 workers during this
stage.
An overall project implementation schedule can be referred in Chart 5-2.
The construction phase will involve the following activities (Table 5-2):
Table 5-2 Activities During Construction Stage

Activity Description
Setting up of site office, sanitary facilities and other facilities
Mobilization of required for the construction works will be carried out during this
workers and stage. Approximately 250 personnel are expected to be involved
machineries during the construction stage. These construction workers will be
accommodated offsite.

Activity Description
Since work areas are located within and near operating facilities
within the ICS, a dedicated and secured access will be provided for
Accessibility the movement of construction vehicles and the workers. This
dedicated access will be removed upon completion of the
construction and installation stage.
Some soil and foundation improvement works are anticipated
especially at areas to be loaded with plant’s component.
Earthworks will be very minimal. Typical foundation work
Foundation works includes piling. Piling will be done by jack-in methodology which
does not have vibration and noise issue. At some areas, micro-
piling will also be done to facilitate the Piling near existing plant
area.
Civil and structural works involve framework, casting and
building components of the proposed project. Storm water
Civil and structural drainage system will be installed surrounding the site to collect
works runoff water and for proper conveying to discharge points.
Structural steel work may include fabrication, erection, and
painting.
Mechanical works, equipment and electrical works are necessary
Mechanical and during installation of all the plant equipment and components.
electrical works These will include necessary piping, electricity, material, and water
supply connection with external sources.
Components of the plant will be commissioned as they are
completed. Various load tests and performance tests will be
Testing and
conducted once all the associated plant’s components are
commissioning
commissioned. During this testing and commissioning period the
operation mode will be fine -tuned and optimized where necessary.
Demobilization of On the completion of the development of the project, all temporary
workers and facilities will be removed from site, and these shall include any
temporary facilities excess of construction materials and waste.
5.5.3 Operational Phase
After the completion of the Project, the following activities will be carried out during
the operational phase:
• Raw materials and products transportation and storage;

• Operation of the 2-EHAcid plant;
• Storage of chemicals and product;
• Scheduled waste management; and
• Maintenance of plant and equipment.

No additional workforce will be added for the operation of this plant, and the plant
is expected to operate for an average of 8,000 hours in a year and a maximum of 8,280
hours in a year with maintenance on an annual basis.

Chart 5-2 Project Implementation Schedule
2021 2022 2023 2024
Works
11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7 8 9 10 11 12 1 2 3 4 5 6 7
EIA Preparation and Approval
EMP Preparation and Approval
Detail engineering design
Manufacturing and delivery of equipment
Procurement of other equipment
Construction works
Equipment installation
Construction E&I works
Commissioning

AVENUE-C 7M WIDE ROAD
E-651.000
Project Site
PROJECT SITE WM-02 WM-02
N-1220.000
NEW ELECTRICAL CABLE-TRENCH ELECTRICAL
ELECTRICALCABLE
CABLETRENCH
TRENCH
14 13 12 11 10 9 8 CABLE-TRENCH BURIED BURIED BURIED 7 6 5 4 3 2 1
6M WIDE ROAD
FOR PLANT II
N-1267.500
N-1180.000
A A 'B'
D-4551
P-4682 D-4615
D 3614
P-4700B P 3713A
P 3713A S 3601 P 3682
7M WIDE ROAD
S-4601
SS
SS
D-4670
S-4603
D 3670
S 3603
P-4680A P 3680A
D 3551
D-4680 D 3680
D-4230
D-4614
D 3230
FS
FS
S-4602 P-4700A P 3700
P 3700 S 3602
Z-3700
Z-4700
TOG EL. 99.605 SS P-4550A TOG EL. 99.605
S-4605 FS FS
S 3605 SS
D 3690
'C'
D-4685
TOS EL.+103000 D 3685 1a
P 3550A
'B' SS FS FS SS
P-4685A SSHOW P 3551A SSHOW P 3685A
472902 372902
B B
IBC
SSHOW 'C' SSHOW
SSHOW CONTAINER
472901 372901
372901
P-4210A
P-4500A
P-4511A
P-4211A
P 3505A
P-4520A
P-4505A
P-4230A
P-4430A
P 3500A
P 3520A
'D'
(NOTE-6)
P-4510A
P 3211A
(NOTE-6)
P-4440A
P-4670A
P-4200A
P 3230A
P 3510A
P 3210A
P-4310A
P-4110A
P-4300A
P 3670A
P 3440A
P 3200A
'D' 'D'
P 3110A
P 3511A
'D'
12 11 10 9
TOG. EL. 107900
13 12
C 11 10 9
D-4110
F-4110
E-4210
C C TOG EL+120000
TOG EL+105425
NEW INTER CONNECTION TOG EL+105425
PROPOSED PIPE RACK 'C' B
E-4211
E-4212
NEW STORM DRAIN TOG EL+105425 TOG EL+105425
'C' D-3710
SSHOW
SSHOW
P-4420A
P 3420A
P 3410A
T-4200
T-4500
P-4410A
T 3200
T 3500
R-4400
R 3400
472904
372904
NOTE-6
P 3430A
P 3300A
P 3200A
TOS. EL. 105425 E-4311
TO BE CONNECTED
TO EXIST. PLTF. P-3715A FS
FS SS
D 3110
SSHOW TOS. EL. 105425 Z-4400 Z-3400 Z-3400 SSHOW D
SSHOW
P-3720A
P-3720B
472908 TO BE CONNECTED 372908
472906
R-4100
SS FS
TO EXIST. PLTF. DOOR OPENING
D D 'F' 'F' TOG EL+125100 TOG EL+123000
D-4110
R-4400
E-4410
E-4500 E 3500
E-4420
E-4200 E 3200 LOCATION UNDER HOLD STAIRCASE C
SS
E-4110
E-4420
E-3420
E-4410
UNDERGROUND LINES ARE
E 3410
DROP DROP DROP DROP TOG EL+123000
OUT OUT OUT OUT PRESENT AT THIS LOCATION E ZV-4510
E 'A' 'A' E ZD-4400 ZD-3400 'A' 'A' GATE 'A' 'A' 'E' TOG EL+120000
D-4700
(NOTE-6)
T-4300
'E' SS
'B' 'B' PLAN AT EL.+105425
T-4450 FS
R-4100
R-4400
'F' DOOR OPENING 'F'
TOG EL+123600
CONCRETE PAD CONCRETE PAD
CONCRETE PAD
'B'
STAIRCASE
E
'A' 'A'
PLAN AT EL.+120000, EL.122400, EL.123000, EL.123600 & EL.125100
D
R-4400
6M WIDE ROAD 'B'
GATE
TOG EL+130075
10 9 14 13 12 11 10 9
PLAN AT EL.+130075
E-4100
DH-02 DH-01
REMOVABLE GRATING
WM-01
E-4510
B
FOR E-4430
SSHOW
TOG EL+115200
472907
E-4220
POWER CABLE RESERVE
E-4511
X-4210
ZV-4210
FS
D
'D'
(NOTE-6)
R-4400
E-4310
FS
FS FS
TOG EL+125885
SSHOW
372906
SS SS SS
6 5 4 3 6 5 4 3 10 9 C
D-4510
SS
FS
R-4400
C PLAN AT EL.+125885 'E'
E-3110
F-3110 SS
D-3110
TOG EL+123000 'E'
TOG EL+105425
ZV-3510
TOG EL+105425
D-3700
TOG EL+105425
E-3710 SS
R-3400 D
D D
R-4100
FS T-3450
R-3400
R-3400
(TYP)
TOG EL+105425 'F' 'F'
R-3100
D DOOR OPENING STAIRCASE
DOOR OPENING TOG EL+130075 TOG EL+125885
R-3100
DOOR OPENING
'A' 'A' E
TOG EL+123600
(NOTE-6)
6 5 6 5
E-4300
T-4450
T-4300
R-3400
E-3410
E-3420
STAIRCASE STAIRCASE
T-4200
T-4500
E PLAN AT EL.+130075 PLAN AT EL.+125885 'B'
PLAN AT EL.+115200
PLAN AT EL.+105425 PLAN AT EL.+123000 & EL.123600
'B'
6 5 4 3 2 1 6 5 4 3 2 1 14 13 12 11 10 9
E-3100
E-3210
E-3510
REMOVABLE GRATING
B B B
X-3715
D-4210
SSHOW
D-3210
FOR E-3430
BATTERY LIMIT PLATFORM
TOG EL+115200
D-4430
372907
D-3430
E-3511
REMOVABLE GRATING
E-3220
TOGR. EL.106.725
E-3211
FOR LG OF T-3300
TOG EL+109400
TOG EL+109400
(NOTE-6)
'D'
D-4310
ZV-3210
FS
E-4350
FS
E-3350
SS SS
D-3550
D-4510
D-4511
FS
D-3510
D-3511
SS SS SS
E-3430 FS FS E-4430
FS SS SS FS
C FS SS SS SS C
C
SSHOW
SSHOW
FS FS
372905
472905
R-4100
D-3510
R-3100
FS SS FS
E-4540
E 3540
R-3400
SS CUT OUT FOR
R-4400
R-3400
DIA 1010MM
E-4520
E-3520
T-3200 T-3500 T-3450 T-4500 T-4200
(TYP)
D D D
DOOR OPENING
'F' 'F'
R-3100
I BCD FOR E-3300 (TYP) DOOR OPENING I
DOOR OPENING
DIA 840MM
STAIRCASE STAIRCASE
STAIRCASE
E E 'A' 'A' E
(NOTE-6)
E-4300
T-4300
E-4410
E-4500
E-3410
E-3500
E-4420
E-4200
E-3420
E-3200
'B'
PLAN AT EL.+109400
T-3200
T-3500
PLAN AT EL.+115200
PLAN AT EL.+109400

Project No EJ 727
Produced By HMZ
Revision -
N
Member of the Aurecon Group
0 5 10
Project Layout Plan
FIGURE 5-1
Meter
\\192.168.1.13\ere data\ERE Projects\EJ 727 2- Ethylehaxanoic Acid BASF\Drawings\1. TOR\Fig 2-3 Project Layout.dwg
06 EXISTING ENVIRONMENT
Section 6
EXISTING ENVIRONMENT
SECTION 6 : EXISTING ENVIRONMENT
6.1 INTRODUCTION
This Section describes the existing environment within and surrounding the Project
area. The information and data were collated from primary and secondary sources.
The major elements of the existing environment described include:
• Physical environment (topography and terrain, geology and soil)

• Land use and sensitive receptors
• Climate
• Hydrology and river system
• Groundwater
• Environmental quality
• Traffic condition
• Socio-economic profile
6.2 PHYSICAL ENVIRONMENT
6.2.1 Topography and Terrain
The Gebeng Industrial Estate (GIE) is located on a coastal plain to the South China
Sea to the east and a hilly area to the west. The coastal plain is low lying and includes
numerous swampy areas to the north (Paya Sg. Ular and Paya Tanah Merah) and the
northeast of GIE. The terrain in the immediate vicinity of the GIE is relatively flat
with the exception of an isolated hill that is Bukit Penggorak, to the east between the
GIE and Tg. Gelang.
The hilly ridge to the west (about 5 km from the GIE) comprises the eastern slopes
and watershed of the Bukit Balok and Bukit Sah range. The peak of Bukit Balok is
230m above mean sea level and Bukit Sah rises to 224m above mean sea level.
Based on the elevation map in Figure 6-1, the Project site ranges from 10-20 m above
mean sea level (MSL). Currently, the Project site is already prepared to platform level.

6.2.2 Geology and Soil
The Project site is underlain by predominantly unconsolidated Quaternary alluvial

sediments with mainly sandstone with subordinate shale, mudstone, siltstone,
conglomerate and volcanics. In terms of soil, the Project site sits on peat soil, whereas
Rengam-Bukit Temiang soil series can be found on the southwest of the Integrated
Chemical Site (ICS) (Figure 6-2).
6.3 LAND USE AND SENSITIVE RECEPTORS
6.3.1 Land Use Within Project Site
The Project site is located within the ICS occupied by the Project Proponent, which is
located within a designated industrial area in BPK 3.1 Gebeng, known as Gebeng
Industrial Estate (GIE). The entire ICS comprises of existing plants:
• Acrylics Complex (acrylic acid plant and acrylic esters plants);

• Oxo-syngas Complex (Oxo-alcohols, butyl acetate and synthesis gas plants);
• Aroma Complex;
• HRPIB Plant;
• Existing 2-EHAcid Plant (Plant I) (Plate 6-1);
• Common infrastructure, export, utility and support systems including drum
and truck loading, centralized wastewater treatment plant (WWTP), cooling
water system, roads, administration, and material storage;
• Toray BASF PBT Resin Sdn. Bhd. (not under the management of BPC); and
• UPC Chemicals (Malaysia) Sdn. Bhd. (not under the management of BPC).

Plate 6-1 Existing 2-EHAcid Plant
6.3.2 Existing Land Use Within 5 km of the Project Site
The proposed Project site will be located within the existing ICS in Phase III of GIE
in Pahang. GIE is one of the main industrial areas in Pahang and is located
approximately 30km northeast of the Kuantan town centre. The total land area
allocated for GIE is about 9,600 acres. GIE consists of four phases and is primarily
planned for chemical and petrochemical industries. The Pahang State Development
Corporation (PKNP) is the authority responsible for the development and
management of GIE.
The existing land use surrounding the Project site was identified through site
reconnaissance on 16 December 2021 and references from Rancangan Tempatan
Daerah Kuantan 2035 (Penggantian) obtained from Majlis Bandaraya Kuantan
(MBK). The land use surrounding the Project site is comprised mainly of industries,
vacant lots and some residential areas at the southwest direction (Figure 6-3).
A description of existing land use within the 5km radius of the Project site are
summarized in Table 6-1.

Table 6-1 Key Landmarks Within 5km Radius of the Project Site
Distance from Project
No. Description
Site
Techny Group Holdings Sdn. Bhd. site office
1 0.9km northwest
Bucida Engineering and Consultancy Sdn. Bhd.
2 1.1km northwest
Pulapel water tanks
3 1.2km northwest
PETRONAS Chemicals MTBE Sdn. Bhd.
4 0.5km east

No. Description
Site
South Pacific Chemicals Sdn. Bhd.
5 2.4km northeast
Dynaciate (Kuantan) Sdn. Bhd.
6 2.3km northeast
Polyplastics Asia Pacific Sdn. Bhd.
7 1.7km northeast
UPC Chemicals (M) Sdn. Bhd.
8 0.7km southwest

No. Description
Site
Pacific Selatan Agency Sdn. Bhd.
9 0.7km southwest
Institusi Latihan Perindustrian Kuantan
10 2.3km southeast
SK Balok Baru
11 3.1km southeast
SMK Pelabuhan & SK Pelabuhan
12 3.2km southeast

No. Description
Site
Gebeng Police Station
13 3.6km southeast
Akademi Maritim Sultan Ahmad Shah (AMSAS)
14 4.6km northeast
Taman Balok Perdana
15 2.8km south
Kompleks Perumahan TLDM, Taman Balok Perdana

No. Description
Site
Taman Balok Makmur
16 2.8km southeast
Kampung Berahi
17 3.2km southeast
Perumahan Balok Baru
18 3.5km southwest
Kg. Seberang Balok
19 4.0km southeast

No. Description
Site
Kg. Balok Baru
20 4.5km southwest
Taman Balok Pelangi
21 3.8km southwest
Kg. Balok
22 4.8km south
Kg. Selamat
23 5km southeast

6.3.3 Future Land Use Within 5 km of the Project Site
Based on Rancangan Tempatan Daerah Kuantan 2035 (Penggantian), land use within
5km radius of the Project site have been mostly gazette as industrial areas with a few
residential areas down south.
Figure 6-4 shows the future land use within and surrounding the Project site.
6.3.4 Proposed Future Developments
Aside from the local plan, the Kuantan Port City (KPC) Draft Masterplan is also
currently being prepared by ECERDC. In this Masterplan, several major
developments have been proposed within the vicinity of the Project Site, such as the
Kuantan Port City (Figure 6-5).
Majlis Bandaraya Kuantan (MBK) is at the final approval stage of the Pelan Tindakan
Khas (PTK) Daerah Kecil Gebeng preparation, and this plan is expected to be published
soon.
Once the PTK is finalized, industrial zones will be the dominant land use within 5km
from the Project site.
6.4 CLIMATE
The general climate of the Project site is similar to the rest of the Peninsular Malaysia
being equatorial with high annual rainfall and relatively uniform high humidity and
temperature. Within any year, four monsoon seasons can be recognized to prevail
namely:
(a) Northeast monsoon (November/early December until March)

(b) Inter-monsoonal or transitional season (April to May)
(c) Southwest monsoon (June to September/early October)
(d) Inter-monsoonal or transitional season (October to early November)
Despite the general uniformity in climate throughout the year, the daily weather
pattern at the Project site is subjected to the prevailing monsoon season. The climatic
data from Kuantan Meteorological Station (1985 – 2020) was obtained to represent
the climatic conditions at the Project Site.

6.4.2 Temperature
The average annual 24-hour temperature recorded is 26.8˚C. The warmest months
are May with 27.8˚C monthly average, while the coolest months are December and
January with 25.5˚C monthly average (Figure 6-6).
6.4.3 Rainfall
The average annual rainfall recorded is 2,975.3mm with an average of 186 rain days.
November had the most rain days (23 days) while February had the least number of
rain days (11 days) (Figure 6-6).
6.4.4 Relative Humidity
The average annual 24-hour mean relative humidity recorded is 84.8%. November
recorded the highest relative humidity at 88.4%, while July and August recorded the
lowest relative humidity at 83.2% (Figure 6-6).
6.4.5 Surface Wind
Based on wind rose records, the predominant wind blows from the northwest. The
annual mean speed was recorded at 1.6m/s. The calm period, when the wind speed
is less than 0.3m/s, was recorded at 17.8% of the time. The annual and seasonal wind
roses are shown in Figure 6-7.
6.5 HYDROLOGY AND DRAINAGE
6.5.1 River Catchment
The Project Site is located within the Sg. Balok catchment (Figure 6-8). The nearest
river, Sg. Balok, which is approximately 0.9km westward from the Project site, and
eventually discharging into the South China Sea.
6.5.2 Drainage System
The drainage system within the ICS can be referred in Figure 6-9. Treated wastewater
is discharged directly into PKNP’s stormwater drainage. Meanwhile, surface run-off
from within the ICS is collected via on-site drainage channels into a retention pond
at the south of the Project site (Plate 6-2) before discharging out into PKNP’s
stormwater drainage (Plate 6-3). This discharge ultimately flows into Sg. Balok.

Plate 6-2 Retention Pond Within ICS Boundary
Source: Chemsain Konsultant Sdn. Bhd.(2014)
Plate 6-3 PKNP’s Stormwater Drainage Outside ICS Boundary
6.5.3 Flood Prone Areas
Based on the Flood Prone Area map from the Department of Irrigation and Drainage,
the Project site is located within the flood prone area (Figure 6-10). The nearest flood
locations from the Project Site, according to the Annual Flood Report 2020, is at
AMSAS’s officers’ quarters (approximately 4.5km northeast from the Project Site),
where the flash flood occurs at a maximum flood depth of 0.3 m.

On 17 December 2020, it was reported that a flash flood had also occurred at Gebeng
Bypass, near the Malaysia-China Kuantan Industrial Park (MCKIP), which disrupts
the traffic heading towards Sg. Ular – Kemaman (Plate 6-4).
Plate 6-4 Flash Flood at Gebeng Bypass
Source: Sinar Harian (2020)
Nonetheless, there are already a few flood risk mitigation plans that are currently or
in the process of being implemented. The existing flood risk mitigation and action
plans are described in the following section.
6.5.3.1 Existing Flood Risk Mitigation and Action Plans
Flood Risk Strategy Outlined in RTD Kuantan 2035 (Penggantian)
In the RTD Kuantan 2035 (Penggantian), under Teras 5: Urus Tadbir Efektif, Strategy 5.1
is a proposal to form a Risk Management Unit within Majlis Bandaraya Kuantan
(MBK), which acts as a disaster monitoring task force to Majlis Keselamatan Negara
(MKN). The method for flood risk management is outlined in Chart 6-1:
Chart 6-1 Flood Risk Management Strategy
Source: Rancangan Tempatan Daerah Kuantan 2035 (Penggantian) (2016)
Besides that, under Strategy 5.3, there is also a proposal of implementation

mechanism for flood risk management. The five mechanisms proposed are:
i) Early warning system for flood disaster
• Flood Disaster Risk Index is required to assess the situation from
time to time. This system is made to collect the rate of flood
increment and rainfall distribution, which uses the satellite system.
ii) Effective database system
• This is a geospatial-like database that will be involved in
infrastructure developments. One of the examples of the system is
the National Flood Geospatial Data System (Sistem Data Geospatial
Banjir Kebangsaan).
• Information or material on floods need to reach the people
immediately so that more thorough preparation can be made to
face flood events.
iii) More comprehensive distribution of disaster funds
• The distribution of flood funds is a necessary provision when
floods occur. Jabatan Kebajikan Masyarakat (JKM) is one of the
important agencies which aims to take care of the public’s needs
during these times, such as food aid, temporary evacuation areas,
clothing and so on.
iv) Localized integration of Disaster Risk Management
• MBK, with the support of Kementerian Perumahan, Kesejahteraan
Bandar dan Kerajaan Tempatan (KPKT), Pahang State Government

and major agencies can strengthen flood risk reduction by taking
into account the aspects of land use planning systems and
development control.
v) Strategic Assistance Collection Center
• MBK, with the support of Kementerian Perumahan, Kesejahteraan
Bandar dan Kerajaan Tempatan (KPKT) together with Pahang State
Government and Non-Governmental Organizations (NGOs) are
strengthening assistance at the national level.
National Flood Forecasting and Warning Program (PRAB)
One of the programs created by the Department of Irrigation and Drainage (DID)
includes the National Flood Forecasting and Warning Program (PRAB), which will
be implemented comprehensively throughout the country via the involvement of
flood prediction models in 41 major river basins. This system is already operating in
Pahang’s river basins.
According to the National Flood Forecasting and Warning Centre (PRABN) under
the Department of Irrigation and Drainage, the PRAB program has four (4) major
components that will be implemented in an integrated manner using the latest
technology:
• Hydrological Data Detection System;
• Database and ICT Infrastructure System;
• Flood Modeling and Forecasting System; and
• Flood Warning and Dissemination System.
These main components of the program are expected to increase the capacity of the
existing system for warning and dissemination of monsoon flood and to increase
accuracy of flood forecasting. This program is anticipated to:
• Provide sufficient time for agencies and residents to act early in the event of
a flood;
• Reduce loss of public and government property;
• Increase public confidence level to the government’s delivery system;
• Allowing agencies to coordinate logistics and displacement strategies more
efficiently; and
• Improve the disaster agency’s ability to plan and execute flood evacuation in
a more organized and timely manner.
Under Malaysia’s five-year 11th and 12th Malaysia Plans, the Malaysian
Meteorological Department (MMD) is also installing new radar stations in Pahang
area, and these radar stations are expected to be ready by 2022.

Flood Disaster Risk Assessment
Malaysia is also currently implementing a flood disaster risk assessment based on

climate change forecasts, and is expected to be ready by 2024, as informed by the
Environment and Water Minister on 10 March 2022 (Plate 6-5).
Plate 6-5 KASA Implements Flood Disaster Risk Assessment
Source: Bernama.com (2022)
The risk assessment will be carried out through flood hazard and flood risks maps
under the DID, covering 36 major river basins, which are ready to be developed.
Upgrading Works at Sungai Ular
There are plans to upgrade Sungai Ular until the river estuary to ensure that the total
amount of discharge, especially additional incoming discharge from MCKIP2, can be
met. This upgrading works is under Phase 2 of the Rancangan Saliran MCKIP-Gebeng,

which is one of the projects budgeted under the Twelfth Malaysia Plan’s Flood
Mitigation Projects.
6.5.4 Beneficial Use
6.5.4.1 Water Infrastructure
There are no water intake points or any other water-related infrastructure points
downstream of the Project site.
6.5.4.2 Recreational Use and Fishing Activities
Pantai Balok, which is located 8km downstream, is a tourism destination where

recreational activities such as swimming, fishing, surfing, and sailing takes places
(Plate 6-6).
Plate 6-6 Pusat Rekreasi Pantai Balok
Source: visitPahang.my (n.d.)
Sg. Balok provide fisheries resources for the locals and the mangrove ecosystem
found along the riverbank has become recreational location (Plate 6-7). Recreational
fishing activities (anglers) are taking place along Sg. Balok.

Plate 6-7 Sungai Balok
Source: maisinggah.com (2020)
6.5.4.3 Commercial Use
Based on site reconnaissance on 21 May 2022, fishing boats were found at two
locations, one along Sg. Balok (4.8km southeast) and one at Sg. Balok estuary (5.2km
southeast) (Chart 6-2, Plates 6-8 and 6-9). Based on the records from Department of
Fisheries Pahang, there are a total of 45 boats and 90 fishermen (Appendix D).
According to one of the fishermen, they mainly carry out sea fishing at Pantai Balok.
Chart 6-2 Location of Fishing Boats
Legend
Project Site
ICS Boundary
Location of fishing
boats

Plate 6-8 Fishing Boat Stationed along Sg. Balok, near Jalan Kuantan-Kemaman
Plate 6-9 Fishing Boats at Sg. Balok Estuary, near Pasar Nelayan Balok
Other than that, fisheries survey study in Sg. Balok conducted in 2021 by Dr. Nik and
Associates Sdn. Bhd. (DNA) on Proposed Development of Permanent Disposal
Facility (PDF) for Water Leach Purification (WLP) Residue on Lot 31375 project is
also referred as secondary data. Fisheries survey study was conducted at six different
station covering freshwater, brackish, and marine environment (Chart 6-3).

Chart 6-3 Location of Sampling Point for Fisheries Survey in Sg. Balok
Legend
Project Site
ICS Boundary
Fisheries Survey
Location
Source: Dr. Nik and Associates Sdn. Bhd. (2021)
The fisheries survey study shows that fish family of Ariidae, Cyprinidae, Lutjanidae,
and Megalopidae are commonly distributed in Sg. Balok. These species are
categorized as the species that are of “Least Concern” according to the International
Union for Conservation of Nature (IUCN). Fishes of these family along with
freshwater prawn, Macrobrachium rosernbergi, which is also under the “Least Concern”
category, are generally sought after by anglers which are either local or non-local
anglers, where either shored-based or boat-based fishing are practiced. This river is
inhabited by high commercial value species and therefore attractive to inland
fisheries activities. Local communities are also gaining economic benefits via
provision of services to support the fishing activities.
Shrimp hatchery at commercial scale was present, but the location of hatchery is
located approximately 8 km from the project site (Plate 6-10 and Chart 6-4). This was
also confirmed with the Department of Fisheries (DOF) Pahang on 1 June 2022 (Ref.:
PRK.PHG.10/121-B(5), refer to Appendix D).

Plate 6-10 Shrimp Hatchery Operating in Balok, Pahang
Chart 6-4 Location of Shrimp Hatchery from Project Site
Legend
Project Site
ICS Boundary
Shrimp Hatchery
6.5.5 Existing River Conservation Programme
Balok River Adoption Programme (BRAP) is an environmental awareness outreach

initiative by the partnership of seven chemical companies (the Project Proponent, RP
Chemicals Malaysia, Eastman Chemical (Malaysia), Kaneka (Malaysia), PETRONAS
Chemicals MTBC, Polyplastics and WR Grace) in Gebeng, Kuantan. Established in
2007, these industry players had partner up since then to promote environmental
initiatives within the surrounding communities, employees and school students.

6.6 GROUNDWATER
There are twelve (12) existing groundwater monitoring well located within the
Integrated Chemical Site, where seven (7) of them were installed in 2001 and five (5)
of them were installed in 2014 (Chart 6-5).
Chart 6-5 Groundwater Monitoring Locations within the ICS
BH7
BH8
BH9
BH14
BH6
Legend
BH10 BH13
Groundwater Wells
BH5A Installed in 2001
BH1A
Groundwater Wells
BH4 Installed in 2014
BH2 Project Site
BH3A ICS Boundary
Source: Geosyntec Consultants (2014)

Five (5) out of seven (7) groundwater wells installed in 2001 were sampled on 8 and 9 January 2014 by Geosyntec Consultant for volatile organic compounds (VOCs), metals, semi-volatile organic compounds (SVOCs)
and total petroleum hydrocarbons (TPH) (Appendix E). BH9 was not sampled due to damaged surface completion and bentonite seal, meanwhile BH7 was undergoing repair at the time, so it was sampled later in
August 2014. A summary of the results can be referred in Table 6-2.
Table 6-2 Groundwater Sampling Results for Groundwater Wells BH2, BH4, BH6 BH8 and BH10
Metals (µg/L) VOCs SVOCs TPH
Well ID Sample Date
Sb Ar Be Cd Cr Cu Fe Pb Mn Ni Se Ag Sn Ti V Zn Hg (µg/L) (µg/L) (µg/L)
8 Jan 2014 <1 3 <1 <1 <1 <1 99,500 1 65 <1 <10 <1 <1 <10 <1 <5 <1 <LOR <LOR <LOR
BH2
2001 NA <10 NA NA NA NA 5,074 NA 213 NA NA NA NA NA NA NA NA NA NA NA
8 Jan 2014 <1 <1 <1 <1 <1 <1 <10 1 <1 1 <10 <1 <1 <10 <1 5 <1 <LOR <LOR <LOR
BH4
2001 NA <10 NA NA NA NA 33 NA 9 NA NA NA NA NA NA NA NA NA NA NA
8 Jan 2014 <1 <1 <1 <1 <1 <1 <10 1 <1 <1 <10 <1 <1 <10 <1 7 <1 <LOR <LOR <LOR
BH6
2001 NA <10 NA NA NA NA <1 NA 12 NA NA NA NA NA NA NA NA NA NA NA
9 Jan 2014 <1 2 <1 <1 <1 <1 10,200 <1 33 <1 <10 <1 <1 <10 <1 <5 <1 <LOR <LOR <LOR
BH8
2001 NA <10 NA NA NA NA 4,454 NA 162 NA NA NA NA NA NA NA NA NA NA NA
9 Jan 2014 <1/<1 <1/<1 <1/<1 <1/<1 <1/<1 <1/<1 7,440/7,360 <1/<1 82/81 <1/<1 <10/<10 <1/<1 <1/<1 <10/<10 <1/<1 7/6 <1/<1 <LOR <LOR <LOR
BH10
2001 NA <10 NA NA NA NA 109 NA 33 NA NA NA NA NA NA NA NA NA NA NA
Dutch Intervention Values/Indicative
20 60 15 6 30 75 - 75 - 75 160 40 50 - 70 800 0.3 - - -
Level for Serious Contamination (DIV)
Malaysian Recommended Site Screening
Levels for Contaminated Land for 15 0.045 73 18 55,000 1,500 26,000 - 880 730 180 180 22,000 - 180 11,000 0.63 - - -
Tapwater (SSLs)
Note:
1. “<” indicates not detected above Level of Reporting (LOR)
2. “/” indicates duplicate sample results
3. Bold indicates value is above SSLs
4. Chromium is compared to Tapwater SSL for chromium (III) insoluble salts
5. Nickel is compared to Tapwater SSL for nickel soluble salts
6. “NA” means value is not available in the report by Geosyntec Consultants (2014)
The analytical laboratory results showed that the VOCs, SVOCs and TPH compounds were not detected in the samples. Arsenic was detected at concentrations above its tapwater Site Screening Levels (SSL) of 0.045
µg/L in monitoring wells BH2 and BH8. Iron was detected above its tapwater SSL of 26,000 µg/L in monitoring well BH2 at a concentration of 99,500 µg/L. None of the other metal detections had exceeded their
respective tapwater SSL.

In August 2014, five (5) additional boreholes were drilled and installed. Then, the groundwater for the five (5) new wells and BH7 were collected from 2 to 4 September 2014 to be sampled. A summary of the results
can be referred in Table 6-3.
Table 6-3 Groundwater Sampling Results for Groundwater Wells BH2, BH4, BH6 BH8 and BH10
Metals (µg/L) VOCs SVOCs TPH
Well ID Sample Date
Sb Ar Be B Cd Cr Cu F Fe Pb Mn Ni Se Ag Sn Ti V Zn Hg (µg/L) (µg/L) (µg/L)
BH1A
2 Sep 2014 <1 <1 <1 <10 <1 <1 3 0.3 20,400 <1 1,100 1 <10 <1 <1 <10 <1 8 <1 <LOR <LOR <LOR
(former BH1)
BH1 2001 NA <10 NA NA NA NA NA NA 320 NA 76 NA NA NA NA NA NA NA NA NA NA NA
BH3A
2 Sep 2014 <1 <1 <1 <10 <1 <1 2 <0.1 2,090 <1 25 <1 <10 <1 <1 <10 <1 7 <1 <LOR <LOR <LOR
(former BH3)
BH3 2001 NA <10 NA NA NA NA NA NA 138,725 NA 735 NA NA NA NA NA NA NA NA NA NA NA
BH5A 3 Sep 2014 <1/<1 <1/<1 <1/<1 10/10 <1/<1 <1/<1 3/5 <0.1/<0.1 20/20 <1/<1 13/13 <1/<1 <10/<10 <1/<1 <1/<1 <10/<10 <1/<1 6/7 <1 <LOR <LOR <LOR
BH5 2001 NA <10 NA NA NA NA NA NA 19 NA 6 NA NA NA NA NA NA NA NA NA NA NA
BH7 3 Sep 2014 <1 <1 <1 12 <1 <1 2 <0.1 10 <1 24 <1 <10 <1 <1 <10 <1 <5 <1 <LOR <LOR <LOR
BH13 4 Sep 2014 <1 <1 <1 <10 <1 <1 2 <0.1 100 <1 7 <1 <10 <1 <1 <10 <1 16 <1 <LOR <LOR <LOR
BH14 5 Sep 2014 <1 <1 <1 <10 <1 <1 3 0 48,600 <1 530 <1 <10 <1 <1 <10 <1 7 <1 <LOR <LOR <LOR
Malaysian Recommended Site
Screening Levels for
15 0.045 73 7,300 18 55,000 1,500 2,200 26,000 - 880 730 180 180 22,000 - 180 11,000 0.63 - - -
Tapwater (SSLs)
Note:
1. “<” indicates not detected above Level of Reporting (LOR)
2. “/” indicates duplicate sample results
3. Bold indicates value is above SSLs
6. “NA” means value is not available in the report by Geosyntec Consultants (2014)
The analytical laboratory results showed that the VOCs, SVOCs and TPH compounds were not detected in the samples. Manganese was detected at 1,100 µg/L compared to its tapwater SSL of 880 µg/L at BH1A, and
iron was detected at 48,600 µg/L compared to its tapwater SSL of 26,000 µg/L in BH14. None of the other metal detections has exceeded their respective tapwater SSL.
Arsenic was detected with levels less than 10 µg/L for all the groundwater samples in 2001. This may have been due to the application of analytical techniques that had a detection limit of 10 µg/L for the 2001 tests.
The maximum iron detection in the 2001 event was 138,725 µg/L in former well BH3, while BH2 had a detection of 5,074 µg/L in 2001. Nonetheless, it is to be noted that the typical range of natural occuring metal
concentration for arsenic in groundwater ranges from 4 µg/L to 2,220 µg/L as mentioned in the Contaminated Land Management and Control Guidelines (CLMCG) issued by the Department of Environment (DOE)
in 2009. Meanwhile, the range of natural occurring concentration for iron in groundwater is 10 µg/L to 72,000 µg/L.
The arsenic levels detected for the groundwater samples is close to the minimum concentration of naturally occurring arsenic levels. In BH2, iron was detected above its tapwater SSL concentration and the natural
occurring iron level. However, iron levels detected at BH2 is significant lower than the 2001 detection in BH3. Iron was detected in well BH14 above its tapwater SSL concentration but significantly below its maximum
naturally occurring level.
Manganese, on the other hand, was detected at 1,100 µg/L compared to its tapwater SSL of 880 µg/L in monitoring well BH1A. However, this detection is significantly below the maximum concentration of naturally
occurring manganese and appears to most likely be a reflection of natural variation of manganese in groundwater within the ICS. Analysis of the 2014 groundwater data suggests that there is no significant increase in
concentrations of chemical parameters in the groundwater at the site well locations since the 2001 sample event.

On 6 August 2020, groundwater samples taken from two (2) boreholes, BH4 and BH5A were tested, and the analytical laboratory results showed that the parameters of heavy metals tested are all below the Malaysian
Recommended Site Screening Levels for Contaminated Land for Tapwater (SSLs) (Table 6-4). Meanwhile, the VOCs are all detected to be lower than 10 µg/L (Tables 6-5a, 6-5b, 6-5c, 6-5d and 6-5e). The certificate of
analysis can be referred in Appendix E1.
Table 6-4 Groundwater Sampling Results for Groundwater Wells BH4 and BH5A (Total Petroleum Hydrocarbon and Heavy Metals)
Total Petroleum Hydrocarcon
Metals (µg/L)
(TPH) (mg/L)
Well ID
nC6 – > nC12 – > nC28 –
Sb As Be Cd Cr Cu Fe Pb Mn Ni Se Ag Sn Ti V Zn Hg
nC12 nC28 nC35
BH4 <0.001 <0.001 <0.001 <0.001 0.001 0.003 0.093 0.001 0.004 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.035 <0.0001 <2.0 <2.0 <2.0
BH5A <0.001 <0.001 <0.001 <0.001 <0.001 0.003 0.011 <0.001 0.002 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 0.014 <0.0001 <2.0 <2.0 <2.0
Malaysian Recommended Site Screening Levels
15 0.045 73 18 55,000 1,500 26,000 - 880 730 180 180 22,000 - 180 11,000 0.63 - - -
for Contaminated Land for Tapwater (SSLs)
Source: Chemsain Konsultant Sdn. Bhd. (2020)
Note:
Table 6-5a Groundwater Sampling Results for Groundwater Wells BH4 and BH5A (Volatile Organic Compounds)
Volatile Organic Compounds (VOCs) (µg/L)
Well ID Trans-1,2- Cis-1,2-
Chloroform Trichloroethene Dibromomethane Bromodichloromethane Benzene Bromochloromethane Bromobenzene Toluene Chloroethane Chloromethane
Dichloroethene dichloroethene
BH4 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
BH5A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
Malaysian
Recommended Site
Screening Levels for 0.19 - 370 1.1 0.41 - 20 2300 - - - 1.8
Tapwater (SSLs)
Table 6-5b Groundwater Sampling Results for Groundwater Wells BH4 and BH5A (Volatile Organic Compounds)
Well ID 1,1- 1,2- 1,2- 1,1,1,2- o- m,p-
Dichlorofluoromethane Tetrachloroethene Dibromochloromethane Chlorobenzene Ethylbenzene
Dichloroethene Dichloropropane Dibromoethane Tetrachloroethane xylene xylene
BH3A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
BH5A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
Malaysian
Recommended Site
Screening Levels for - - 0.39 - 0.8 0.0065 91 0.52 1.5 1400 1400
Tapwater (SSLs)

Table 6-5c Groundwater Sampling Results for Groundwater Wells BH4 and BH5A (Volatile Organic Compounds)
Well ID Carbon 2,2- 1,3- 1,1- 2- 1,1,2,2- 1,2,3- 4- 1,2,4-
Bromoform Bromomethane
Tetrachloride Dichloropropane Dichloropropane Dichloropropene Chlorotoluene Tetrachloroethane Trichloropropane chlorotoluene Trimethylbenzene
BH3A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
BH5A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
Malaysian
Recommended Site
Screening Levels for 8.5 0.2 - 730 - 730 0.067 0.0096 8.7 2600 15
Contaminated Land
for Tapwater (SSLs)
Table 6-5d Groundwater Sampling Results for Groundwater Wells BH4 and BH5A (Volatile Organic Compounds)
Well ID 1,1- 1,2- 1,3,5- Sec- 1,2- 1,3- 1,4- n- 1,2-Dibromo-3- 1,2,4-
Tertbutylbenzene
Dichloroethane Dichloroethane Trimethylbenzene butylbenzene Dichlorobenzene Dichlorobenzene Dichlorobenzene Butylbenzene chloropropane Trichlorobenzene
BH3A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
BH5A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
Malaysian
Recommended
Site Screening
Levels for 2.4 0.15 - 12 - 370 - 0.43 - 0.00032 8.2
Contaminated
Land for Tapwater
(SSLs)
Table 6-5e Groundwater Sampling Results for Groundwater Wells BH4 and BH5A (Volatile Organic Compounds)
Well ID 1,2,3- p- Methylene n- 1,1,1- 1,1,2- Vinyl
Napthalene Hexachlorobutadiene Isopropylbenzene Styrene Trichlorofluoromethane
Trichlorobenzene Isopropyltoluene Chloride Propylbenzene Trichloroethane Trichloroethane chloride
BH3A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
BH5A <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10
Malaysian
Recommended
Site Screening
Levels for
- 0.86 - - - 4.8 - 1600 9100 0.24 13000 0.016
Contaminated
Land for
Tapwater
(SSLs)

A hydrogeological Conceptual Site Model (CSM) was developed based on the data
from the five new monitoring wells (BH1A, BH3A, BH5A, BH13, BH14). The
direction of groundwater flow in September 2014 was inferred to be toward the
southeast (Chart 6-6).
Chart 6-6 Direction of Groundwater Flow
BH7
BH8
BH9
BH14
BH6
Legend
BH10 BH13
Groundwater Wells
BH5A Installed in 2001
BH1A
Groundwater Wells
BH4 Installed in 2014
BH2 Project Site
BH3A ICS Boundary
6.7 ENVIRONMENTAL QUALITY
6.7.1 Air Quality
Ambient air quality monitoring was conducted on 27th to 29th April 2022. The
monitoring was conducted to establish the baseline ambient air quality prior to the
construction and operation of the Project.
Secondary data for long-term ambient air quality monitoring data was obtained from
DOE and Project Proponent. The continuous air quality data of monitoring stations
obtained from DOE was for the period between 2017 to 2020. Ambient air quality
data from 2019 to 2021 was supplied by the Project Proponent.

6.7.1.1 Monitoring Location and Parameters
i) Baseline Ambient Air Monitoring
The monitoring was carried out for 23 pollutants of concern, namely particulate
matter with the size less than 10 microns (PM10), particulate matter with the size less
than 2.5 microns (PM2.5), sulphur dioxide (SO2), nitrogen dioxide (NO2), carbon
monoxide (CO), ozone (O3), hydrogen sulphide (H2S), chlorine (Cl2), hydrochloric
acid (HCl), ammonia (NH3), volatile organic compound (VOC) and heavy metals (i.e.,
Cd, Tl, Hg, Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V) (refer to Appendix F for the full
report). In addition, wind measurements were also taken to determine the wind
direction and wind speed during the monitoring period.
The monitoring locations were selected based on the presence of air sensitive
receptors near to the Project site (Table 6-6 and Figure 6-11).
Table 6-6 Location of Air Quality Sampling Points

Station Description Coordinates
A1 Taman Seri Perasing N 03˚ 57’ 53.5”, E 103˚ 19’ 29.4”
A2 Perumahan Balok Baru N03˚ 57’ 07.6”, E103˚ 21’ 39.6”
A3 Taman Balok Makmur N 03˚ 57’ 34.4”, E 103˚ 22’ 44.7”
A4 Kampung Gebeng Pantai N 04˚ 00’ 56.7”, E 103˚ 24’ 18.6”
ii) Continuous Air Quality Monitoring (CAQM) by DOE
The ambient air quality of the Project site can also be represented by the continuous
air quality monitoring (CAQM) stations at Balok Baru and Kuantan (Chart 6-7) which
monitors six pollutants of concern as per Malaysia Ambient Air Quality Standard
(MAAQS) 2013 namely particulate matter less than 10 microns (PM10), particulate
matter less than 2.5 microns (PM2.5), nitrogen dioxide (NO2), sulphur dioxide (SO2),
ozone (O3) and carbon monoxide (CO).

Chart 6-7 Location of CAQM Stations Near Project Site
iii) Ambient Air Monitoring by Project Proponent
Ambient air monitoring has been carried out at three (3) monitoring stations within
the ICS on a quarterly basis. Location of monitoring stations are shown in Table 6-7
and Figure 6-12.
Table 6-7 Location of Air Monitoring Stations

Monitoring
Coordinates Description
Stations
N 03° 59’ 02.7” North western boundary of the ICS-A300
PA1
E 103° 21’ 39.0” Blockfield
N 03° 59’ 07.1”
PA2 South western of the ICS-A100 Blockfield
E 103° 21’ 49.5”
N 03° 59’ 06.3”
PA3 South eastern of the ICS-D600 Blockfield
E 103° 22’ 09.4”
6.7.1.2 Result and Discussion
i) Baseline Ambient Air Monitoring
The results obtained are tabulated in Table 6-8. Ambient air quality monitoring
results from year 2014 is also shown to compare and examine the air quality trend at
the monitoring locations.

Table 6-8 Baseline Ambient Air Quality Result
Parameter Monitoring Year
Averaging Time MAAQS b Limit
(μg/m³) 2014a 2022
A1 – Taman Sri Perasing
PM10 - 42 24 hr 100
PM2.5 - 23 24 hr 35
SO2 - <50 1 hr 250
NO2 - <0.5 8 hr -
CO - <1 1 hr 30
O3 - <1 24 hr -
H2S - <10 24 hr 7c
Cl2 - <10 24 hr 10c
HCl - N/A 24 hr 20c
NH3 - 38 24 hr 100c
VOC - <10 24 hr -
Cd - <0.03 24 hr 0.025c
Tl - <0.03 24 hr -
Hg - <0.01 24 hr 2c
Sb - <0.03 24 hr 25c
As - 0.06 24 hr 0.3c
Pb - <0.03 24 hr 0.5c
Cr - 0.22 24 hr 0.5c
Co - <0.03 24 hr 0.1c
Cu - 0.06 24 hr 50c
Mn - <0.03 24 hr 0.1c
Ni - <0.03 24 hr 0.1c
V - <0.03 24 hr 2c
A2 – Perumahan Balok Baru
PM10 - 21 24 hr 100
PM2.5 - 12 24 hr 35
SO2 - <50 1 hr 250
NO2 - <0.5 8 hr -
CO - <1 1 hr 30
O3 - <1 24 hr -
H2S - <10 24 hr 7c
Cl2 - <10 24 hr 10c
HCl - N/A 24 hr 20c
NH3 - 63 24 hr 100c
VOC - <10 24 hr -
Cd - <0.03 24 hr 0.025c
Tl - <0.03 24 hr -
Hg - <0.01 24 hr 2c
Sb - <0.03 24 hr 25c
As - 0.10 24 hr 0.3c
Pb - <0.03 24 hr 0.5c
Cr - 1.00 24 hr 0.5c
Co - <0.03 24 hr 0.1c

(μg/m³) 2014a 2022
Cu - 0.07 24 hr 50c
Mn - <0.03 24 hr 0.1c
Ni - <0.03 24 hr 0.1c
V - <0.03 24 hr 2c
A3 – Taman Balok Makmur
PM10 1.6 31 24 hr 100
PM2.5 - 21 24 hr 35
SO2 27 <50 1 hr 250
NO2 <6.0 (1 hr) <0.5 8 hr -
CO - <1 1 hr 30
O3 - <1 24 hr -
H2S - <10 24 hr 7c
Cl2 - <10 24 hr 10c
HCl - N/A 24 hr 20c
NH3 - 63 24 hr 100c
VOC - <10 24 hr -
Cd - <0.03 24 hr 0.025c
Tl - <0.03 24 hr -
Hg - 0.04 24 hr 2c
Sb - <0.03 24 hr 25c
As - 0.07 24 hr 0.3c
Pb - <0.03 24 hr 0.5c
Cr - 0.28 24 hr 0.5c
Co - <0.03 24 hr 0.1c
Cu - 0.07 24 hr 50c
Mn - <0.03 24 hr 0.1c
Ni - <0.03 24 hr 0.1c
V - <0.03 24 hr 2c
A4 – Kampung Gebeng Pantai
PM10 16.4 39 24 hr 100
PM2.5 - 24 24 hr 35
SO2 45 <50 1 hr 250
NO2 <6.0 (1 hr) <0.5 8 hr -
CO - <1 1 hr 30
O3 - <1 24 hr -
H2S - <10 24 hr 7c
Cl2 - <10 24 hr 10c
HCl - N/A 24 hr 20c
NH3 - 63 24 hr 100c
VOC - <10 24 hr -
Cd - <0.03 24 hr 0.025c
Tl - <0.03 24 hr -
Hg - 0.04 24 hr 2c
Sb - <0.03 24 hr 25c
As - <0.03 24 hr 0.3c

(μg/m³) 2014a 2022
Pb - <0.03 24 hr 0.5c
Cr - 0.21 24 hr 0.5c
Co - <0.03 24 hr 0.1c
Cu - 0.21 24 hr 50c
Mn - <0.03 24 hr 0.1c
Ni - <0.03 24 hr 0.1c
V - <0.03 24 hr 2c
Note: “-“ means data is unavailable
a. Source: DEIA for the Proposed Development of a New 30 Kt/y 2-EHAcid Plant at the ICS
in Gebeng, Kuantan, Pahang
b. Malaysian Ambient Air Quality Standards (MAAQS), 2013
c. Ontario Ambient Air Quality Criteria, 2020
From Table 6-8, all the parameters were well below the limits stipulated in the
MAAQS and Ontario Ambient Air Quality Criteria. During the most recent
monitoring on the 27th to 29th April 2022, ambient PM10 readings ranged from 21 to
42 μg/m³, with the highest reading at A1 (Taman Sri Perasing). As for PM2.5, readings
ranged from 12 to 24 μg/m³, with the highest at A4 (Kampung Gebeng Pantai). SO2,
NO2, CO and O3 levels were below detection limits (<50 μg/m³, <0.5 μg/m³, <1
mg/m³ and <1 μg/m³ respectively) at all monitoring locations.
Other gaseous compounds that are not listed under the MAAQS such as H2S, Cl2,
NH3 and VOC were also below the detection limits of <10 μg/m³ except for
parameter NH3 at A1 (38 μg/m³) and A2 (63 μg/m³) which is still below the ambient
limit of 100 μg/m³. All the heavy metals such (i.e., Cd, Tl, Hg, Sb, As, Pb, Cr, Co, Cu,
Mn, Ni and V) were below detection limits or within the limits stipulated in Ontario
Ambient Air Quality Criteria.
ii) Continuous Air Quality Monitoring (CAQM) by DOE
As shown in Table 6-9, the annual average concentrations of all monitored pollutants
in 2019 and 2020 were generally well below the stipulated limits of the Malaysia
Ambient Air Quality Standard (MAAQS). It can be seen that the annual average
concentrations recorded for all monitored air pollutants (except for SO2) in 2020 were
slightly lower compared to 2019 due to the Movement Control Order (MCO)
imposed by the Government. As such, data in 2019 will be used for comparison
purposes (if required).

Table 6-9 Summary of Air Quality at Balok Baru and Kuantan CAQM Stations in 2019 and 2020
Annual MAAQS
Parameter (µg/m3) Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Average 2020
Balok Baru
2019 - PM10 (24 Hour) 27.21 29.31 45.84 48.16 27.36 25.57 28.19 43.97 57.49 25.03 24.01 23.44 33.80
100
2020 - PM10 (24 Hour) 24.97 30.53 22.51 15.66 15.79 19.63 17.99 20.51 20.31 23.97 21.91 24.04 21.49
2019 - PM2.5 (24 Hour) 12.60 16.54 32.90 38.93 20.10 18.70 20.77 32.63 44.99 16.60 13.08 10.04 23.16
35
2020 - PM2.5 (24 Hour) 10.8 13.06 11.4 9.06 9.5 11.46 10.39 12.64 12.75 13.46 8.74 8.82 11.01
2019 - NO2 (1 Hour) 11.48 9.60 12.04 9.97 8.84 8.28 7.34 6.77 8.66 10.91 12.61 13.36 9.99
280
2020 - NO2 (1 Hour) 9.22 9.78 8.28 5.64 5.64 7.71 8.28 7.90 8.66 11.48 11.85 12.04 8.87
2019 - SO2 (24 Hour) 3.14 3.93 3.14 2.36 2.10 2.36 2.62 2.62 2.36 2.36 2.10 2.36 2.62
80
2020 - SO2 (24 Hour) 2.62 2.36 4.19 1.57 2.10 2.36 2.36 2.88 2.62 3.14 15.98 21.49 5.31
Kuantan
2019 - O3 (1 Hour) 35.34 33.37 43.19 39.26 47.12 39.26 49.08 53.01 53.01 35.34 35.34 39.26 41.88
180
2020 - O3 (1 Hour) 37.30 43.19 37.30 33.37 39.26 33.37 33.37 43.19 37.30 43.19 29.45 37.30 37.30
2019 - CO* (8 Hour) 0.58 0.51 0.54 0.60 0.59 0.66 0.58 0.78 0.79 0.63 0.50 0.35 0.59
10
2020 - CO* (8 Hour) 0.45 0.49 0.45 0.46 0.42 0.49 0.49 0.55 0.53 0.48 0.42 0.55 0.48
Note: * Unit for CO is mg/m3
Source: Compendium of Environment Statistics (2020 and 2021)

iii) Ambient Air Monitoring by Project Proponent
From Table 6-10, it can be observed that all parameters monitored were recorded to
be well within the stipulated limits. Major contributors of air quality were from
vehicle movement from main road nearby and within the plant at A1, A2 and A3.
Table 6-10 Ambient Air Monitoring Results for the Year 2021
TSP PM10 PM2.5 SO2 NO2 O3 CO
Parameter
(µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (µg/m3) (mg/m3)
Q1 2021
PA1 27.1 12.9 11.9 <20 <6.0 <100 <5.73
PA2 30.5 15.2 9.3 <20 <6.0 <100 <5.73
PA3 28.1 20.3 16.2 <20 <6.0 <100 <5.73
Q2 2021
PA1 26.5 14.3 <5.0 <20 <6.0 <100 <11.46
PA2 16.2 7.9 7.1 <20 <6.0 <100 <11.46
PA3 9.5 8.5 <5.0 <20 <6.0 <100 <11.46
Q3 2021
PA1 25.7 14.9 8.1 <20 <6.0 <100 <11.46
PA2 18.8 11.0 <5.0 <20 <6.0 <100 <11.46
PA3 28.3 7.8 5.6 <20 <6.0 <100 <11.46
*260 **100 **35 **250 **280 180 30
Guideline
µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 mg/m3
Limit
@ 24 hrs @ 24 hrs @ 24 hrs @ 1 hrs @ 1 hrs @ 1 hrs @ 1 hrs
Note:
< Less than
Bold Exceeded the requirement limit
* Malaysian Ambient Air Quality Standard (MAAQS) (1989)
** New Malaysian Ambient Air Quality Standard (NMAAQS), 2013 (Standard, 2020)
6.7.2 Environmental Noise Quality
Environmental noise monitoring was obtained via baseline monitoring and

secondary data sources. Ad-hoc environmental noise monitoring at three (3)
monitoring locations within the ICS, N1 to N3 was conducted from 28th to 29th April
2022.
Secondary data for existing environmental noise was obtained from the Project
Proponent. Environmental noise monitoring has been carried out in quarterly basis
at four (4) monitoring stations to measure the environmental noise level within the
ICS.

i) Ad-hoc Environmental Noise Monitoring
Noise levels recording were carried out for a period of 24 hours at 15 minutes interval
at the measurement locations. The recorded noise levels for each interval were
systematically and automatically integrated by the in-built electronic system. The
integrated noise levels are recorded in terms of LAeq, LAmax, LAmin, L10 and L90.
The monitoring locations selected is listed in Table 6-11 and indicated in Figure 6-11.
Table 6-11 Location of Baseline Environmental Noise Monitoring Points

Monitoring
Stations
N 03° 59’ 02.7” Northwestern boundary of the ICS-A300
N1
N 03° 59’ 03.8” Southeastern of the ICS-C300 Blockfield, located
N2*
E 103° 21’ 59.0” at the proposed 2-EHAcid plant II site
N 03° 59’ 06.3”
N3 Southeastern of the ICS-D600 Blockfield
E 103° 22’ 09.4”
Note: N2 is for the purpose of comparison only. Within the Integrated Chemical Site (ICS) where
Occupational Noise Exposure applies.
ii) Environmental Noise Monitoring by Project Proponent
Location of the existing monitoring stations within the ICS are shown in Table 6-12
and Figure 6-12.
Table 6-12 Location of Existing Environmental Noise Monitoring Stations

Monitoring
Stations
N 03° 59’ 02.7” Northwestern boundary of the ICS-A300
PN1
N 03° 59’ 07.1”
PN2 Southwestern of the ICS-A100 Blockfield
E 103° 21’ 49.5”
N 03° 59’ 06.3”
PN3 Southeastern of the ICS-D600 Blockfield
E 103° 22’ 09.4”
N 03° 59’ 02.3”
PN4 Southeastern of the ICS-D200 Blockfield
E 103° 22’ 10.5”

Prescribed Limits
As per the EIA Approval Conditions attached in Appendix A (Ref. No.:

AS(PN)35/119/000/071 Jilid 3(32) dated 4 March 2015), the environmental noise
level within the existing plant shall be limited to 70 dB(A) during daytime and 60
dB(A) during night-time. However, the Project Proponent has appealed to DOE
Pahang on this EIA approval conditions on 6 November 2012 (Ref: BPC/HSE-
ENV/REG/01:01 Vol2/L(08)12), and DOE Pahang State has allowed the noise limit
from the ICS to be limited to 70 dB(A) at all times (Ref.: AS C38/193/200/003 Jld
19(12) dated 15 January 2013, as attached in Appendix A1).
With the latest Noise Regulations, the prescribed noise limit for both daytime and
night-time is 75 dBA for industrial zone category as per the Second Schedule of the
Guidelines for Environmental Noise Limits and Control, Third Edition, 2019 (Reprint
2021) (Refer to Appendix F).
i) Ad-hoc Environmental Noise Monitoring
Ad-hoc environmental noise monitoring results are tabulated in Table 6-13. Noise
results for N1 and N3 are compared against the prescribed levels of 75 dBA for
daytime and night-time. As for N2 station, the noise limit is compared against the
levels prescribed in the Occupational Safety and Health (Noise Exposure)
Regulations 2019, which is 82 dBA due to its location within the boundary of the ICS.

Table 6-13 Ambient Noise Quality Results
A-weighted sound level (dBA)
Permissible
Station Location Lmin - Lmax
Time Leq(1) L10 L90 Limits for
Range
Leq
Northwestern
Day 60.5 59.3 49.4 48.9 – 67.3 75(2)
boundary of the
N1
ICS-A300
Night 53.2 51.1 45.5 42.7 – 58.8 75(2)
Blockfield
Southeastern of the
ICS-C300 Day 73.6 74.5 75.4 72.1 – 77.3 82(3)
Blockfield, located
N2
at the proposed 2-
EHAcid plant II Night 74.6 72.6 73.7 73.2 – 76.4 82(3)
site
Southeastern of the Day 62.9 63.6 62.1 61.9 – 64.8 75(2)
N3 ICS-D600
Night 63.2 63.8 62.8 62.7 – 63.9 75(2)
Blockfield
Source: Environmental Science (M) Sdn. Bhd. (2022)
Note:
1. The daytime LAeq is the equivalent A-weighted sound level for the daytime period of 7.00 am to 10.00 pm
(0700 to 2200 hours) and the night-time LAeq is the equivalent A-weighted sound level for the night-time
period of 10.00 pm to 7.00 am (2200 to 0700 hours).
2. The permissible limits are as stipulated in Second Schedule from the Guidelines for Environmental Noise
Limits and Control – Third Edition by DOE (2019, reprint 2021).
3. The permissible limits are as stipulated in the Occupational Safety and Health (Noise Exposure) Regulations
2019.
According to the monitoring result in Table 6-13, the noise levels recorded at all
monitoring stations during daytime and night-time are all within the permissible
limits. The noise levels detected from all monitoring locations are mostly from the
operation of plants within the ICS and some vehicle movement within the premise.
ii) Periodic Environmental Noise Monitoring by Project Proponent
Noise monitoring results from the secondary data obtained from the Project
Proponent based on monitoring activity conducted quarterly in the year 2019, 2020
and 2021 are tabulated in Table 6-14a (station PN1, PN3 and PN4) and Table 6-14b
(station PN2). Noise monitoring results for station PN1, PN3 and PN4 were
compared against levels prescribed in the Guidelines for Environmental Noise Limits
and Control, Third Edition, 2019 (reprint 2021), whereas, for station PN2, the results
were compared against levels prescribed in the Occupational Safety and Health
(Noise Exposure) Regulations 2019.

Table 6-14a Results of Historical Periodic Ambient Noise Monitoring for the year of 2019 to 2021 (Station PN1, PN3, PN4)
A-weighted sound level (dBA) Limit as per Second Schedule of the
Sampling Sampling appealed EIA Guidelines for Environmental
Time Lmin - Lmax
Date Station Leq(1) L10 L90 Approval Condition Noise Limits and Control, Third
Range
(Leq) (1) Edition, 2019 (Reprint 2021)
Daytime 59.0 62.3 51.0 44.7 – 90.0
PN1
Night-time 54.4 56.3 46.0 43.9 – 89.0
February Daytime 63.0 62.9 58.9 56.1 – 88.8
PN3
2019 Night-time 60.7 56.6 55.8 52.9 – 100.0
Daytime 68.4 70.5 65.3 60.7 – 87.4
PN4
Night-time - 70.6 68.7 63.2 - 79.7
Daytime 60.1 63.0 51.6 44.3 – 90.8
PN1
Night-time 54.9 57.8 51.1 43.9 – 82.5
Daytime 66.0 63.6 57.8 53.5 – 113.6
April 2019 PN3
Night-time 57.5 61.1 53.3 51.2 – 84.1
Daytime 67.4 68.9 65.4 59.7 – 89.2
PN4
Night-time 68.1 69.2 66.8 62.5 – 79.1 75 dB(A)
70 dB(A)
Daytime 59.5 62.6 50.5 45.2 – 91.1 (Industrial Zone)
PN1
Night-time 57.0 61.2 48.3 45.9 – 86.3
Daytime 59.7 60.3 58.8 56.2 – 80.9
July 2019 PN3
Night-time 62.3 62.6 60.4 58.7 – 86.8
Daytime 69.1 71.0 66.3 60.5 – 94.3
PN4
Night-time 69.5 71.0 57.7 55.4 – 81.4
Daytime 62.1 63.4 51.6 44.9 – 106.6
PN1
Night-time 57.5 61.7 50.9 49.3 – 91.0
November Daytime 59.2 59.6 58.2 56.1 – 95.0
PN3
2019 Night-time 61.0 59.3 55.8 52.9 – 100.0
Daytime 65.3 66.3 64.2 60.5 – 89.4
PN4
Night-time 65.4 66.6 64.3 61.5 – 80.4

Time Lmin - Lmax
Range
Daytime 57.1 60.3 52.4 46.3 – 85.7
PN1
Night-time 57.5 61.1 52.4 46.3 – 85.7
February Daytime 60.8 61.0 59.6 45.9 – 100.0
PN3
2020 Night-time 60.4 60.8 59.8 39.2 – 88.9
Daytime 69.2 70.9 66.7 61.5 – 82.9
PN4
Night-time 65.4 66.6 64.3 61.5 – 80.4
Daytime 57.4 60.5 47.0 40.9 – 97.8
PN1
Night-time 56.3 60.3 44.9 41.0 – 85.6
Daytime 64.3 66.2 62.0 59.4 – 86.1
June 2020 PN3
Night-time 62.5 63.8 60.5 57.0 – 87.8
Daytime 64.3 66.5 62.0 40.8 – 77.3
PN4
Night-time 64.4 65.8 62.9 43.2 – 87.5 75 dB(A)
70 dB(A)
Daytime 57.4 61.6 44.7 39.8 – 92.8 (Industrial Zone)
PN1
Night-time 56.4 60.7 41.9 38.2 – 85.0
August Daytime 61.6 62.5 60.3 57.6 – 85.1
PN3
2020 Night-time 62.4 63.7 60.6 58.0 – 79.5
Daytime 65.3 66.3 64.2 60.5 – 89.4
PN4
Night-time 65.4 66.6 64.3 61.5 – 80.4
Daytime 57.8 61.6 48.9 43.8 – 92.9
PN1
Night-time 56.9 61.3 46.0 43.4 – 85.9
November Daytime 64.0 65.7 61.6 59.5 – 82.8
PN3
2020 Night-time 64.2 65.0 63.3 61.2 – 73.6
Daytime 69.1 71.0 66.3 60.5 – 94.3
PN4
Night-time 69.5 71.0 57.7 55.4 – 81.4

Time Lmin - Lmax
Range
Daytime 57.7 61.4 46.3 40.8 – 83.0
PN1
Night-time 55.6 59.8 43.4 41.0 – 82.3
March Daytime 64.5 65.6 63.4 61.2 – 73.8
PN3
2021 Night-time 63.3 65.1 61.4 59.5 – 82.8
Daytime 69.6 71.0 66.4 55.4 – 94.3
PN4
Night-time 68.6 70.9 65.9 60.5 – 80.3
Daytime 56.9 60.8 50.8 41.0 – 87.3
PN1
Night-time 54.0 57.8 39.3 36.6 – 87.7
August Daytime 63.1 64.7 61.1 58.6 – 74.9 75 dB(A)
PN3 70 dB(A)
2021 Night-time 63.4 64.6 62.2 59.9 – 70.2 (Industrial Zone)
Daytime 61.9 65.1 56.2 53.1 – 90.4
PN4
Night-time 59.8 64.2 54.8 52.6 – 87.7
Daytime 56.1 60.0 44.5 42.3 – 91.9
PN1
Night-time 57.5 61.8 43.4 40.8 – 84.1
September Daytime 61.0 62.1 59.6 56.5 – 78.2
PN3
2021 Night-time 60.2 60.8 59.4 56.5 – 68.1
Daytime 64.3 66.2 62.0 59.1 – 86.1
PN4
Night-time 62.5 63.8 60.5 57.0 – 87.8
Source: Environmental Science (Malaysia) Sdn. Bhd. (2019 – 2021)
Note: 1 Refer to Appendix A1

Table 6-14b Results of Historical Periodic Ambient Noise Monitoring for the year of 2019 to 2021 (Station PN2)
A-weighted sound level (dBA) Occupational Safety and
Sampling Date Sampling Station Time Health (Noise Exposure)
Leq(1) L10 L90 Lmin - Lmax Range
Regulations 2019
Daytime 64.9 68.1 60.1 53.7 – 84.8
February 2019 PN2
Night-time 67.2 67.4 61.3 48.6 – 96.8
Daytime 61.4 60.6 56.7 52.6 – 85.0
April 2019 PN2
Night-time 56.9 57.5 56.4 54.2 – 66.8
Daytime 58.8 60.5 53.2 47.7 – 98.8
July 2019 PN2
Night-time 58.8 60.3 52.1 48.5 – 100.4
Daytime 61.2 60.5 56.5 46.1 – 82.8
November 2019 PN2
Night-time 54.9 57.8 48.6 43.9 – 82.5
Daytime 67.1 69.3 52.4 60.0 – 108.8
February 2020 PN2
Night-time 65.5 67.5 63.8 60.0 – 78.2
Daytime 60.7 63.0 56.5 52.2 – 92.6
June 2020 PN2 82 dBA
Night-time 63.1 66.8 60.3 43.3 – 90.7
Daytime 60.1 62.6 56.2 50.8 – 93.9
August 2020 PN2
Night-time 59.5 62.3 55.6 52.1 – 89.7
Daytime 58.6 61.2 54.8 52.5 – 86.5
November 2020 PN2
Night-time 58.5 61.6 54.2 51.2 – 86.3
Daytime 67.2 69.3 64.1 60.0 – 108.8
March 2021 PN2
Night-time 65.4 67.4 63.8 60.0 – 78.2
Daytime 59.5 61.8 57.0 50.9 – 88.4
August 2021 PN2
Night-time 59.4 63.1 55.4 52.5 – 81.6
Daytime 57.0 59.3 53.8 47.1 – 80.2
September 2021 PN2
Night-time 56.9 59.5 52.0 32.3 – 86.8
Source: Environmental Science (Malaysia) Sdn. Bhd. (2019 – 2021)
Note: 1 Refer to Appendix A

Based on Table 6-14a, the environmental noise level results for the year 2019, 2020
and 2021 show the average LAeq noise level at station PN1, PN3 and PN4 during
daytime and night-time complied to the new prescribed limit of 75 dB(A). As for the
environmental noise level results at station PN2 which is located within the ICS
boundary (Table 6-14b), the noise level results for the year 2019, 2020 and 2021 did
not exceed the permissible level of 82 dB(A) as per the Occupational Safety and
Health (Noise Exposure) Regulations 2019.
Noise sources observed during both daytime and night-time were mainly attributed
from normal plant operation, others nearby plant operation as well as vehicle
movement from the main road, Jalan Gebeng 1/11.
6.7.3 Water Quality
Water quality data on water bodies at and near project site was obtained via baseline
water quality sampling and secondary data sources. Baseline water quality sampling
at station W1 to W4 was conducted on 22 April 2022, sampling at station W5 and W6
was conducted on 28 April 2022 and W7 on 3 June 2022. The sampling was conducted
to determine the baseline water quality prior to the construction and operation of
project.
Secondary data for long-term water quality monitoring data was obtained from DOE
and Project Proponent. The water quality data of monitoring stations obtained from
DOE was for the period between 2017 to 2020. Water quality data from 2019 to 2021
was supplied by the Project Proponent. The water quality data were compared
against National Water Quality Standards for Malaysia (NWQS).
i) Baseline Water Quality
Baseline water quality sampling was conducted at seven different locations. The
sampling point were chosen based on discharge from Project Site as well as discharge
from WWTP located in vicinity of Project Site. The sampling locations (Figure 6-11)
and sampling parameters are presented in Table 6-15 and Table 6-16 respectively.
Table 6-15 Baseline Water Quality Sampling Location

3°58’56.9” N
W1 Sg. Balok, upstream of PKNP drainage discharge
103°21’25.84” E
PKNP drainage, downstream of discharge from 3°58’43.67” N
W2
retention pond 103°21’54.86” E
3°58’12.13” N
W3 Sg. Balok, downstream of PKNP drainage discharge
103°21’41.21” E

Sg. Balok, downstream of W3. Main road from bypass 3°57’32.63” N
W4
highway to Balok Perdana 103°21’48.64” E
3°58’52.4” N
W5 Stormwater drainage within ICS boundary
103°22’01.5” E
3°58’46.4” N
W6 Stormwater drainage within ICS boundary
103°21’57.0” E
3°59’2.01” N
W7 Upstream of the ICS at PKNP drainage
103°22’11.40” E
Table 6-16 Water Quality Parameter and Analysis Method

Parameter Unit Method
pH - APHA 4500-H+ B, 2005
Temperature ºC APHA 4500-H+ B, 2005
Dissolved Oxygen mg/L APHA 4500-O G,2005
Biochemical Oxygen Demand APHA 5210 B, 2005
mg/L
(BOD) APHA 4500-O G,2005
Chemical Oxygen Demand In-house Method (EST/L/W-07)
mg/L
(COD) based on APHA 5220 B, 2005
Total Suspended Solid (TSS) mg/L APHA 2540-D, 2005
Mercury (Hg) mg/L APHA 3112 B, 2005
Cadmium (Cd) mg/L APHA 3120 B, 2005
Chromium Hexavalent (Cr6+) mg/L APHA 3500-Cr B, 2005
In-house Method (EST/L/W-01)
Chromium Trivalent (Cr3+) mg/L based on APHA 3500-Cr B, 2005,
APHA 3120 B, 2005
Arsenic (As) mg/L APHA 3120 B, 2005
Cyanide (CN) mg/L APHA 4500-CN C&F, 2005
Lead (Pb) mg/L APHA 3120 B, 2005
Copper (Cu) mg/L APHA 3120 B, 2005
Manganese (Mn) mg/L APHA 3120 B, 2005
Nickel (Ni) mg/L APHA 3120 B, 2005
In-house Method (ESL/L/W-08)
Tin (Sn) mg/L
based on APHA 3120 B, 2005
Oil and Grease (O&G) mg/L APHA 5520 B, 2005
Zinc (Zn) mg/L APHA 5520 B, 2005
Boron (B) mg/L APHA 3120 B, 2005
Iron (Fe) mg/L APHA 3120B, 2005
Silver (Ag) mg/L APHA 3120 B, 2005
Aluminum (Al) mg/L APHA 3120 B, 2005
Silver (Ag) mg/L APHA 3120 B, 2005
Selenium (Se) mg/L APHA 3120 B, 2005
Barium (Ba) mg/L APHA 3120 B, 2005
Nitrite (NO2) mg/L APHA 4500-NO2 B, 2005
Sulfide (S2-) mg/L APHA 4500-S2- F, 2005
Ammoniacal Nitrogen (NH3-N) mg/L APHA 4500-NH3 B&C, 2005
Fluoride (F) mg/L APHA 4500-F D, 2005

Parameter Unit Method
Colour TCU APHA 2120 B, 2005
In-house method (EST/L/W-04)
Formaldehyde mg/L
based on HACH 8110, 2008, Ed 5
Phosphate (P) mg/L APHA 4500-P D, 2005
Conductivity µs/cm APHA 2510 B, 2005
Salinity ‰ APHA 2520 B, 2005
Escherichia coli Count/100 ml APHA 9222 G, 2005
Fecal Coliform Count/ 100 ml APHA 9222 D, 2005
Total Coliform Count/ 100 ml APHA 9222 B, 2005
ii) Water Quality Monitoring by DOE
DOE maintains long term river water monitoring quality at Sg. Balok. The water
quality data for selected stations was obtained from DOE (refer to Table 6-17).
Table 6-17 Water Quality Monitoring Stations by Department of

Environment
Legend
Project Site
ICS Boundary
Water Quality
Monitoring Stations
by DOE
River Station ID Location Coordinates

3°57'33.01"N
4CBLK002 Jalan ke Pelabuhan Kuantan (Bypass)
103°21'47.70"E
Sg. Balok
3°56'31.96"N
4CBLK001 Jambatan Kuala Sungai di Kg. Balok.
103°22'20.46"E
iii) Water Quality Monitoring by Project Proponent
Long term water quality monitoring at selected location was performed by project
proponent as part of Post EIA Compliance Monitoring for plants operating in
Integrated Chemical Site (ICS). The monitoring provides overall view of the

cumulative environmental impact from the operation of plants. The location of water
quality monitoring stations is detailed in Table 6-18 and Figure 6-12.
Table 6-18 Water Quality Monitoring Location

Location Description Coordinates
Upstream of Sg. Balok, located before the storm 3°58'32.2" N
PW1
water discharge point 103°21'26.3" E
Downstream of Sg. Balok, located after the storm 3°58’25.7” N
PW2
water discharge point 103°21’28.0” E
Upstream of WWTP outfall in the adjacent PKNP 3°59’02.3” N
PW3
drain 103°22’11.6” E
Downstream of BST1, BST2, and WWTP outfall in the 3°58’45.2” N
PW4
adjacent PKNP drain 103°21’57.3” E
3°58’52.4” N
PW5 Stagnant point at BST1 entrance point
103°22’01.5” E
3°58’46.4” N
PW6 Stagnant point at BST2 entrance point
103°21’57.0” E
i) Baseline Water Quality
The baseline water quality sampling showed that generally the water quality fall
within Class III limit (Table 6-19).
Biochemical Oxygen Demand and Chemical Oxygen Demand
The BOD level ranged from less than 2 mg/L at station W5 and W6 to 14 mg/L (Class
V) at station W7. The COD level ranged from 12 mg/L (Class II) to 92 mg/L (Class
IV). The COD level at W4 and W7 exceeded the Class III of NWQS.
Dissolved Oxygen
The DO level ranged from 4.49 mg/L at station W5 to 6.6 mg/L at station W7. The
DO values at all stations fall within Class III limit of NWQS except for W7.
Total Suspended Solids
The TSS level ranged from 2 mg/L (Class I) at station W6 to 106 mg/L at station W4.
The TSS level at all stations fall within Class III limit of NWQS.

Ammoniacal Nitrogen
NH3-N level ranged from 0.7 mg/L (Class III) at station W5 to 2.3 mg/L (Class IV) at
station W1. The NH3-N level at all sampled stations except W5 exceeded Class III of
NWQS.
pH and Temperature
The pH level ranged from 6.1 to 7.98 and the temperature level ranged from 28.9 °C
to 30 °C.
Heavy Metal
Most of the heavy metal parameters tested are below detection limit except for the
following parameters described below:
• Cu level at station W1, W2, W3, and W4 were 0.058 mg/L, 0.056 mg/L, 0.045
mg/L, and 0.057 mg/L respectively. Cu was not detected at station W5, W6
and W7.
• Mn level report at station W1, W2, W3, W4, and W7 were 0.111 mg/L, 0.091
mg/L, 0.082 mg/L, 0.073 mg/L, and 0.02 mg/L respectively. Mn level was
below detection limit at W5 and W6. Mn level at W1 exceeded Class III limit
of NWQS.
• Zn level at station W2, W4, W5, and W7 were 0.015 mg/L, 0.015 mg/L, 0.02
mg/L and 0.02 mg/L respectively. The values are within Class III limit of
NWQS. Zn level was below detected limit at other stations.
• Fe level ranged from 0.367 mg/L at W6 to 3.78 mg/L at W4. Fe level at station
W1, W3, and W4 was higher than the Class III limit of NWQS.
• Al level ranged from 0.03 mg/L at W6 to 3.24 mg/L at W4.
Other Parameters
Oil and grease level at all stations were below detection limit. The E. coli level at
station W1, W2, W3, W4, and W7 were 283 count/100 mL, 820 count/100 mL, 830
count/100 mL, 267 count/100 mL, and 102 count/100 mL respectively. E. coli was
not detected at station W5 and W6.
The faecal coliform level ranged from 158 count/100 mL at W7 to 1,060 count/ 100
mL at W2. The values are within Class III limit of NWQS. Fecal coliform was not
detected at W5 and W6. Total coliform level ranged from 2 count/100 mL at W5 to
5,200 count/100 mL at W1. The total coliform values are within Class III of NWQS.

Table 6-19 Baseline Water Quality Sampling Results
Stations
Parameter Unit Class III
W1 W2 W3 W4 W5 W6 W7
Temperature °C Normal ± 2°C 28.9 29.1 29.5 29.3 30 29.9 30.0
pH 5-9 6.3 6.2 6.1 6.6 7.98 7.49 7.6
Dissolved Oxygen (DO) mg/L 3-5 4.88 4.84 4.93 4.92 4.49 4.69 6.6
Biochemical Oxygen Demand (BOD) mg/L 6 2 3 2 6 <2 <2 14
Chemical Oxygen Demand (COD) mg/L 50 38 40 35 77 13 12 92
Total Suspended Solids mg/L 150 10 10 13 106 4 2 58
Mercury (Hg) mg/L 0.004 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001
Cadmium (Cd) mg/L 0.01 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005
Chromium Hexavalent (Cr6+) mg/L 1.4 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Chromium Trivalent (Cr3+) mg/L 2.5 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Arsenic (As) mg/L 0.4 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.01
Cyanide (CN) mg/L 0.6 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02
Lead (Pb) mg/L - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Copper (Cu) mg/L - 0.058 0.056 0.045 0.057 <0.01 <0.01 <0.01
Manganese (Mn) mg/L 0.1 0.111 0.091 0.082 0.073 <0.01 <0.01 0.02
Nickel (Ni) mg/L 0.9 <0.005 <0.005 <0.005 <0.005 <0.01 <0.01 <0.01
Tin (Sn) mg/L 0.004 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004 <0.004
Oil and Grease mg/L N <1 <1 <1 <1 <1 <1 <1
Zinc (Zn) mg/L - <0.005 0.015 <0.005 0.015 0.02 <0.01 0.02
Boron (B) mg/L - <0.005 0.014 0.007 0.306 <0.1 <0.1 0.08
Iron (Fe) mg/L 1 1.34 0.968 1.17 3.78 0.418 0.367 0.620
Phenol mg/L - <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001
Chlorine (Cl2) mg/L - <0.01 <0.01 <0.01 <0.01 <0.001 <0.001 <0.1
Aluminium (Al) mg/L - 0.4 0.45 0.56 3.24 0.13 0.03 0.24
Silver (Ag) mg/L 0.0002 <0.005 <0.005 <0.005 <0.005 <0.01 <0.01 <0.01

Stations
W1 W2 W3 W4 W5 W6 W7
Selenium (Se) mg/L 0.25 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Barium (Ba) mg/L - <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01
Nitrite (NO2) mg/L 0.4 0.08 0.06 0.07 0.11 0.1 2.8 1.6
Sulphide (S2-) mg/L - <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05
Ammoniacal Nitrogen (NH3-N) mg/L 0.9 2.3 1.9 1.8 1 0.7 1 1.3
Fluoride (F) mg/L 10 0.4 0.3 0.3 0.7 0.7 0.3 0.6
Colour TCU - 80 60 60 50 20 20 10
Formaldehyde mg/L - <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1
Phosphate (P) mg/L - <0.05 <0.05 <0.05 <0.05 0.1 <0.1 0.4
Conductivity µs/cm - 4120 3650 3570 2348 99 88 738
Salinity ‰ - 2 2 2 1 <1 <1 N/A
Escherichia coli count/100mL - 283 820 830 267 <1 <1 102
Faecal coliform count/100mL 5000 290 1060 910 447 <1 <1 158
Total coliform count/100mL 50000 5200 1400 2900 2500 2 <1 215
Source: Environmental Science (M) Sdn. Bhd. (2022)
Note:
1. Class III limit refers to parameter limits of class III of the National Water Quality Standards for Malaysia set by Department of Environment (DOE).
2. Bolded values are values exceeding Class III limit.
N = free from visible film, sheen, discolouration, and deposits.
TCU = True Colour Unit
“<” = ‘less than the minimum detectable limit’ or ‘not detected’

ii) Water Quality Monitoring by DOE
DOE’s long term water quality index of Sg. Balok was generally considered as
slightly polluted. The river water quality index was reported as clean or polluted at
certain period. The river water quality was deemed to be clean in September 2017,
May 2018, July 2019, and July 2020 (Tables 6-20 to 6-23). The river was classified as
polluted in January 2018, September 2019, and March 2020.
a) Station 4CBLK002
The station is located downstream of Project Site and upstream of station

4CBLK001. WQI classifies the river as slightly polluted at all times except in
March 2018 where is index shows river water as clean.
BOD level ranged from 3 mg/L (Class II) in May 2020 and July 2020 to 14
mg/L (Class V) in January 2018. BOD level exceeded Class III limit during
sampling interval of September 2017, January, March, July, and November
2018, May, September, and November 2019, and March 2020 (Chart 6-8).
Chart 6-8 Biochemical Oxygen Demand (BOD) Trendline for Station

4CBLK002 from 2017 to 2020
16
14
Concentration (mg/L)
12
10
8
6
4
2
0
Feb-17
May-17
Aug-17
Feb-18
May-18
Aug-18
Feb-19
May-19
Aug-19
Feb-20
Aug-20
May-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
COD level ranged from 13 mg/L (Class II) in July 2020 to 63 mg/L (Class IV)
in January 2018. The COD level generally falls within Class III limit of NWQS
except in January 2018. The COD level reported in January 2018 was 63 mg/L
which exceeds Class III limit of 50 mg/L (Chart 6-9).

Chart 6-9 Chemical Oxygen Demand (COD) Trendline for Station
4CBLK002 from 2017 to 2020
70
60
50
40
30
20
10
0
May-19
Feb-17
May-17
Feb-18
May-18
Feb-19
Feb-20
May-20
Aug-17
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
Dissolved Oxygen
DO level ranged from 3.4 mg/L in September 2020 to 8.08 mg/L in January
2018 (Chart 6-10). The DO level reported is higher than lower limit prescribed
for Class III of NWQS.
Chart 6-10 Dissolved Oxygen (DO) Trendline for Station 4CBLK002 from
2017 to 2020
9.00
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00
Feb-17
May-17
Feb-18
Feb-19
Feb-20
Aug-17
May-18
May-19
May-20
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
Total Suspended Solid
TSS level ranges from 4 mg/L (Class I) in September 2020 to 462 (Class V) in
January 2018.The TSS level fall within Class III limit except on February 2017,
January 2019, and January 2018 where the value reported were 170 mg/L, 173

mg/L, and 462 mg/L (Chart 6-11). The values on those intervals exceeded
150 mg/L which is Class III limit of NWQS.
Chart 6-11 Total Suspended Solids (TSS) Trendline for Station 4CBLK002
from 2017 to 2020
500
450
400
350
300
250
200
150
100
50
0
Feb-17
May-17
Feb-18
May-18
Feb-19
May-19
Feb-20
May-20
Aug-17
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
Ammoniacal Nitrogen
NH3-N level ranged from 0.08 mg/L (Class I) in February 2017 to 5.2 (Class
V) in January 2020 (Chart 6-12). NH3-N level frequently exceeds Class III limit
of 0.9 mg/L where values reported during 14 out of 22 intervals exceeds the
limit.
Chart 6-12 Ammoniacal Nitrogen (NH3-N) Trendline for Station

4CBLK002 from 2017 to 2020
6.00
5.00
4.00
3.00
2.00
1.00
0.00
Feb-17
May-17
Aug-17
Feb-18
May-18
Aug-18
Feb-19
May-19
Aug-19
Feb-20
May-20
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year

Temperature and pH
The pH level ranged from 6.3 in November 2017 to 8.03 in January 2020. The
river water temperature ranged from 24.1 ºC in March 2018 to 30.9°C in March
2018 and May 2020.
Heavy Metal
Heavy metal parameter reported fall within Class III limit of NWQS. Hg and
Cd levels reported are below detection limit except for:
• As level ranged from 0.001 mg/L in 2017 (February, July, November),

2018 (July), 2019 (September, November) and 2020 (January, July,
September, November) to 0.004 mg/L in January 2018.
• Cr level ranged from below detection limit in July 2017, November 2017,
March 2018, and July 2020 to 0.005 mg/L in November 2019 and January
2018.
• Zn level ranged from below detection limit in July 2018 to 0.178 mg/L in
January 2018.
Escherichia coli
E. coli level ranged from <1.0 CFU/100 mL in January 2018 to 32, 000
CFU/100 mL in July 2018.
b) Station 4CBLK001
Station is located downstream of Project Site and station 4CBLK002. The WQI
value of the river generally classified as slightly polluted.
BOD level ranged from 2 mg/L (Class II) in November 2020 to 16 mg/L (Class
V) in January 2018 and March 2020. The BOD level exceeded Class III limit
during nine sampling intervals between 2017 and 2020 (Chart 6-13).

Chart 6-13 Biochemical Oxygen Demand (BOD) Trendline for Station
4CBLK001 from 2017 to 2020
18
16
Concentration (mg/L) 14
12
10
8
6
4
2
0
Feb-19
Feb-17
May-17
Feb-18
May-18
May-19
Feb-20
May-20
Aug-17
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
COD level ranged from 13 mg/L (Class II) in September 2018 and July 2020
to 45 mg/L (Class III) in September 2020 (Chart 6-14). The COD level
recorded falls within Class III limit of NWQS.
Chart 6-14 Chemical Oxygen Demand (COD) Trendline for Station

4CBLK001 from 2017 to 2020
50
45
40
35
30
25
20
15
10
5
0
Feb-19
Feb-17
May-17
Aug-17
Feb-18
May-18
Aug-18
May-19
Aug-19
Feb-20
May-20
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year

Dissolved Oxygen
DO level ranged from 7.07 mg/L (Class I) in July 2019 to 3.11 mg/L (Class III)
in November 2017 (Chart 6-15). The DO level falls within Class III limit of
NWQS.
Chart 6-15 Dissolved Oxygen (DO) Trendline for Station 4CBLK001 from
2017 to 2020
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00
Feb-17
May-17
Feb-18
Feb-19
Aug-17
May-18
May-19
Feb-20
May-20
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
Suspended Solid
SS level ranged from 3 mg/L (Class I) in May 2018 to 159 mg/L (Class IV) in
May 2019 (Chart 6-16). The SS level generally fall within Class III limit except
for in May 2019 where the recorded value exceeded the limit.
Chart 6-16 Total Suspended Solids (TSS) Trendline for Station 4CBLK001
from 2017 to 2020
180
160
140
120
100
80
60
40
20
0
Feb-17
May-17
Feb-18
May-18
Feb-19
May-19
Feb-20
May-20
Aug-17
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year

Ammoniacal Nitrogen
NH3-N value ranged from 0.07 mg/L (Class I) in February 2017 to 7.49 mg/L
(Class V) in September 2019 (Chart 6-17). The NH3-N level reported
frequently exceeds Class III limit of NWQS.
Chart 6-17 Ammoniacal Nitrogen (NH3-N) Trendline for Station

4CBLK001 from 2017 to 2020
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00
May-20
Feb-17
May-17
Feb-18
May-18
Feb-19
May-19
Feb-20
Aug-17
Aug-18
Aug-19
Aug-20
Nov-17
Nov-18
Nov-19
Nov-20
Year
Temperature and pH
The pH level ranged from 5.73 in February 2017 to 8.36 in May 2019. The river
water temperature ranged from 25.7 ºC in February 2017 to 32.1 ºC in May
2018.
Heavy Metal
Heavy metal reported are As, Cd, Cr, HG, Pb, and Zn and the heavy metal
levels reported are within Class III limit of NWQS.
Escherichia coli
E. coli level ranged from below detection limit in January 2018 to 104,000
CFU/100mL in March 2020. The E. coli reported on September 2019 (60,000
CFU/100mL) and March 2020 (104,000 CFU/100mL) exceeds the maximum
value of fecal coliform for Class III of NWQS.

Table 6-20 DOE Water Quality Monitoring Data at Station 4CBKL002 in Sg. Balok in 2017
2017
Feb Jul Sep Nov
Dissolved Oxygen (DO) mg/L 3-5 5.59 4.30 4.42 4.97
Biochemical Oxygen Demand (BOD) mg/L 6 5 5 8 5
Chemical Oxygen Demand (COD) mg/L 50 19 20 24 15
Total Suspended Solid (TSS) mg/L 150 170 34 29 102
pH - 5-9 6.52 6.85 7.24 6.30
Ammoniacal Nitrogen (NH3-N) mg/L 0.9 0.08 1.17 2.17 0.68
Temperature °C Normal ± 2°C 26.5 27.1 29.6 27.2
Conductivity µs/cm - 82 3441 24195 1944
Salinity ppt - 0.04 1.72 13.3 0.98
Turbidity NTU - 271.3 16.9 5.3 107.9
Nitrate (NO3) mg/L - 0.22 <0.01 <0.01 1.49
Phosphorus (PO4) mg/L - <0.01 0.69 0.53 0.06
Arsenic (As) mg/L 0.4# (0.05) 0.001 0.001 0.002 0.001
Mercury (Hg) mg/L 0.004# (0.0001) <0.0002 <0.001 <0.001 <0.001
Cadmium (Cd) mg/L 0.01*# (0.001) <0.001 <0.001 <0.001 <0.001
Chromium (Cr) mg/L - 0.001 <0.001 0.001 <0.001
Lead (Pb) mg/L 0.02* (0.01)
# <0.01 <0.001 <0.001 0.002
Zinc (Zn) mg/L 0.4* 0.04 0.027 0.021 0.037
Oil and Grease mg/L N <1 <1 <1 <1
Escherichia coli CFU/100 mL - - 1200 6600 2000
Water Quality Index (WQI) (Class) 76.8 (II) 70 (III) 68(III) 72.2(III)
River Classification SP SP SP SP
Source: Department of Environment (2021)
Note: 1. Class III limit refers to parameter limits of class III of the National Water Quality Standards for Malaysia set by Department of Environment (DOE).
* = At hardness 50 mg/L CaCO3
# = Maximum (unbracketed) and 24-hour average (bracketed) concentration
N = Free from visible film sheen, discoloration, and deposits.

Table 6-21 DOE Water Quality Monitoring Data at Station 4CBKL001 in Sg. Balok in 2017
2017
Feb Jul Sep Nov
Dissolved Oxygen (DO) mg/L 3-5 5.82 5.63 5.94 3.11
Biochemical Oxygen Demand (BOD) mg/L 6 4 9 4 4
Chemical Oxygen Demand (COD) mg/L 50 18 42 16 16
Suspended Solid (SS) mg/L 150 125 21 20 41
pH 5-9 5.73 7.96 8.20 6.50
Ammoniacal Nitrogen (NH3-N) mg/L 0.9 0.07 0.22 0.19 1.61
Temperature °C Normal ± 2°C 25.74 29.06 29.67 27.80
Conductivity µs/cm - 3976 50195 47186 5362
Salinity ppt - 2.10 30.14 30.56 2.88
Turbidity NTU - 96.0 9.0 11.5 33.6
Nitrate (NO3) mg/L - <0.01 <0.01 <0.01 <0.01
Phosphorus (PO4) mg/L - <0.01 <0.01 <0.01 <0.01
Arsenic (As) mg/L 0.4# (0.05) 0.001 0.007 0.002 0.001
Mercury (Hg) mg/L 0.004# (0.0001) <0.0002 0.001 <0.001 <0.001
Cadmium (Cd) mg/L 0.01*# (0.001) <0.001 0.002 <0.001 <0.001
Chromium (Cr) mg/L - 0.001 0.001 <0.001 0.001
Lead (Pb) mg/L 0.02* (0.01)
# <0.01 <0.001 <0.001 <0.001
Zinc (Zn) mg/L 0.4* 0.04 0.01 0.01 0.03
Oil and Grease mg/L N <1 <1 <1 <1
Escherichia coli CFU/100 mL - 4000 400 1000 3000
Water Quality Index (WQI) (Class) 78.5 (II) 77.7 (II) 86.7 (II) 65.1 (III)
River Classification SP SP C SP
Note: 1. Class III limit refers to parameter limits of class III of the National Water Quality Standards for Malaysia set by Department of Environment (DOE).

Table 6-22 DOE Water Quality Monitoring Data at Station 4CBKL002 in Sg. Balok in 2018 to 2020
2018 2019 2020
Jan Mar May Jul Sep Nov Jan Mar May Jul Sep Nov Jan Mar May Jul Sep Nov
Dissolved Oxygen (DO) mg/L 3-5 8.08 7.84 4.4 5.82 4.52 4.18 4.5 4.2 4.0 4.3 4.6 4.8 5.0 4.3 3.8 3.5 3.4 5.0
Biochemical Oxygen Demand (BOD) mg/L 6 14 7 6 9 6 7 6 4 7 6.0 7 7 6 9 3 3 6 5
Chemical Oxygen Demand (COD) mg/L 50 63 26 24 30 24 25 23 24 23 24 22 24 25 26 19 13 14 20
Total Suspended Solid (TSS) mg/L 150 462 9 25 15 28 31 173 33 40 39 16 40 22 24 54 5 4 39
pH - 5-9 6.84 7.25 7.35 7.58 7.17 6.90 6.92 7.40 7.5 7.1 7.05 7.06 8.03 7.36 7.54 7.33 6.99 6.33
Ammoniacal Nitrogen (NH3-N) mg/L 0.9 0.13 0.2 1.91 2.2 2.26 2.42 0.64 2.86 1.0 1.6 0.13 2.09 5.2 0.96 1.78 0.12 1.29 0.6
Normal ±
Temperature °C 26.7 24.1 30.9 30.4 26.5 27.8 27.8 29.4 29.6 29.9 29.711 27.836 27.6 29.6 30.9 28.2 30.6 27.4
2°C
17918. 12871. 13636. 3521.62 1971.21 551.2 5765.2 26146.0 19257.7 7795.4 2185.1
Conductivity µs/cm - 55.6 48.7 6291.7 337.9 1784.8 1408 9522.2
6 4 2 9 2 3 1 4 1 4 9
Salinity ppt - 0.02 0.04 10.50 3.40 0.16 0.90 0.7 5.31 7.35 7.82 1.834 0.997 0.264 3.099 15.864 11.395 4.274 1.112
Turbidity NTU - 963.36 695.73 9.317 22.003 71.233 38.163 103.5 11.1 12.04 6.26 9.067 21.388 8.373 8.847 7.564 5.977 7.362 17.596
Nitrate (NO3) mg/L - 2.16 <0.01 <0.01 6.55 1.78 2.52 7.03 <0.01 <0.01 <0.01 4.76 4.44 < 0.01 0.49 < 0.01 < 0.01 6.31 5.12
Phosphorus (PO4) mg/L - 0.1 <0.01 0.28 <0.01 0.22 0.12 0.37 0.37 0.28 0.18 0.05 0.49 0.2 1.71 0.64 0.28 1.42 0.03
Arsenic (As) mg/L 0.4 (0.05)
# 0.004 0.002 0.002 0.001 0.002 0.002 0.003 0.002 0.00 0.00 0.001 0.001 0.001 0.002 0.002 0.001 0.001 0.001
0.004# <0.00 <0.00 <0.00 <0.00 <0.00 <0.00 <0.00 <
Mercury (Hg) mg/L <0.001 <0.001 <0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001
(0.0001) 1 1 1 1 1 1 1 0.001
0.01*# <0.00 <0.00 <0.00 <0.00 <0.00 <0.00 <0.00 <
Cadmium (Cd) mg/L <0.001 <0.001 <0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001
(0.001) 1 1 1 1 1 1 1 0.001
<0.00
Chromium (Cr) mg/L - 0.005 0.004 0.002 0.002 0.002 0.003 0.003 0.00 0.00 0.001 0.005 0.001 0.001 0.001 < 0.001 0.001 0.002
1
0.02*# <0.00 <0.00 <
Lead (Pb) mg/L 0.01 <0.001 0.002 0.002 0.002 0.015 <0.001 <0.001 < 0.001 0.002 < 0.001 < 0.001 < 0.001 < 0.001 0.003
(0.01) 1 1 0.001
<0.10
Zinc (Zn) mg/L 0.4* 0.178 0.014 0.034 0.014 0.02 0.16 0.015 0.03 0.04 0.072 0.042 0.018 0.031 0.016 0.022 0.024 0.095
0
Oil and Grease mg/L N <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 2
CFU/100
Escherichia coli - <1 3100 19000 32000 300 5600 3400 9600 4000 11200 1,200 600 4,400 2,300 100 5,200 5,000 2,000
mL
Water Quality Index (WQI) (Class) 66(III) 85(II) 71(III) 71(III) 68(III) 68(III) 68(III) 65(III) 69(III) 69(III) 79(II) 68(III) 65(III) 69(III) 69(III) 80(II) 70(III) 75(III)
River Classification SP C SP SP SP SP SP SP SP SP SP SP SP SP SP SP SP SP
Note:

Table 6-23 DOE Water Quality Monitoring Data at Station 4CBKL001 in Sg. Balok in 2018 to 2020
2018 2019 2020
Jan Mar May Jul Sep Nov Jan Mar May Jul Sep Nov Jan Mar May Jul Sep Nov
Dissolved Oxygen (DO) mg/L 3-5 4.20 4.80 6.10 4.70 3.54 4.36 4.47 4.08 5.72 7.07 3.69 5.19 4.25 4.03 4.86 5.74 3.14 3.38
Biochemical Oxygen Demand (BOD) mg/L 6 16 7 6 4 5 11 5 3 7 7 7 9 5 16 3 3 4 2
Chemical Oxygen Demand (COD) mg/L 50 38 22 26 18 13 37 27 29 26 28 30 28 30 34 21 13 45 30
Suspended Solid (SS) mg/L 150 42 14 3 19 16 45 45 28 159 21 42 21 25 35 91 7 12 7
pH 5-9 6.33 6.01 8.15 7.66 7.23 7.08 6.77 7.43 8.36 8.21 6.95 7.06 7.23 7.31 7.83 8.28 6.96 6.27
Ammoniacal Nitrogen (NH3-N) mg/L 0.9 1.41 0.40 0.60 3.61 2.81 1.98 1.74 2.43 0.16 0.36 7.49 2.81 3.34 3.34 0.46 0.16 3.00 1.85
Temperature °C Normal ± 2°C 27.50 28.32 32.13 29.81 27.52 27.89 28.62 30.88 31.06 30.75 29.15 27.92 28.12 30.12 30.99 28.97 30.16 27.07
Conductivity µs/cm - 816.1 721.1 45220.0 25073.2 9481.6 2137.3 2598 14934.7 45892.9 45269.8 9608.23 4267.97 5615.82 9074.26 49231.29 50619.39 20576.05 2836.56
Salinity ppt - 0.40 0.42 29.06 15.17 5.30 1.09 1.33 8.61 29.58 29.14 5.36 2.26 3.02 5.04 32.00 33.08 12.22 1.47
Turbidity NTU - 311.0 269.7 10.4 9.2 12.6 41.6 46.4 11.1 11.4 7.2 6.4 12.0 13.1 15.5 12.6 8.6 14.5 14.3
Nitrate (NO3) mg/L - 9.6 <0.01 <0.01 <0.01 0.2 <0.01 1.65 <0.01 <0.01 <0.01 3.34 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 2.56 2.27
Phosphorus (PO4) mg/L - 0.12 <0.01 0.08 <0.01 0.5 0.13 0.15 0.32 <0.010 0.04 0.42 0.08 0.28 0.96 0.12 < 0.01 0.38 0.04
Arsenic (As) mg/L 0.4# (0.05) 0.002 0.002 0.003 0.002 0.002 0.002 0.001 0.002 0.00 0.00 0.001 0.001 0.003 0.002 0.002 0.002 0.002 < 0.001
Mercury (Hg) mg/L 0.004# (0.0001) <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.0001 < 0.0001
Cadmium (Cd) mg/L 0.01*# (0.001) <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001 < 0.001
Chromium (Cr) mg/L - 0.004 <0.001 0.004 0.002 0.001 0.002 0.002 0.002 0.00 0.00 0.001 0.002 0.002 < 0.001 0.002 0.001 0.001 0.001
Lead (Pb) mg/L 0.02* (0.01)
# 0.003 <0.001 <0.001 <0.001 0.001 0.002 0.002 <0.001 0.00 <0.001 < 0.001 < 0.001 < 0.001 < 0.001 0.001 < 0.001 < 0.001 0.001
Zinc (Zn) mg/L 0.4* 0.024 0.014 0.012 <0.100 0.018 0.019 0.027 0.013 0.02 0.02 0.034 0.023 0.02 0.018 0.016 0.023 0.012 0.045
Oil and Grease mg/L N <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 2
Escherichia coli CFU/100 mL - <1 4700 39000 600 16000 11000 25600 10800 16000 300 60,000 4,800 6,000 104,000 1,200 100 3,000 10,000
58 72 82 70 66 61 66 61 77 81 59 67 64 56 78 89 61 67
Water Quality Index (WQI) (Class)
(III) (III) (II) (III) (III) (III) (III) (III) (II) (II) (III) (III) (III) (III) (II) (II) (III) (III)
River Classification P SP C SP SP SP SP SP SP C P SP SP P SP C SP SP
Note:

iii) Water Quality Monitoring by Project Proponent
The water quality monitoring results are compared against Class III standards of
NWQS. The results are tabulated in Table 6-24 to Table 6-29.
Existing Monitoring Station W1
The water quality at W1 is generally reported to be slightly polluted except in August

2020 and February 2021 where it is classified as clean. The DO level ranged from 1.9
mg/L (Class IV) to 6.6 mg/L (Class II). The DO level in May 2020 exceeded Class III
limit of NWQS where value reported was 1.9 mg/L.
BOD level ranged from 3.3 mg/L (Class III) to 9 mg/L (Class IV). BOD level in
November 2019, August 2020, August 2021, and September 2021 exceeded the Class
III limit of NWQS. COD level ranged from 35 mg/L (Class III) to 61 mg/L (Class IV).
COD level in August 2020 and September 2021 exceeded Class III of NWQS. Values
of TSS, NH3-N, fluoride, and boron fall within Class III limit of NWQS.
The water quality at W2 is generally reported to be slightly polluted except in July

2019 where it is reported to be clean. The DO level ranged from 2.1 mg/L (Class IV)
to 6.2 mg/L (Class II). DO values reported from February 2020 to August 2020 does
not comply to Class III limit where the values reported falls under Class IV of NWQS.
BOD level ranged from 3.6 mg/L (Class III) to 8.9 mg/L (Class IV). BOD level in
April 2019, August 2020, and November 2020 exceeded the Class III limit of NWQS.
COD level ranged from 11 mg/L (Class II) to 63 mg/L (Class IV). COD level in
August 2020 and August 2021 exceeded Class III limit of NWQS. Values of TSS, NH3-
N, fluoride, and boron fall within Class III limit of NWQS.
Water quality at W3 is generally reported as clean. Water quality was deemed as

slightly polluted in May 2020 and August 2021 and polluted in September 2021. BOD
level ranged from 2.8 mg/L (Class II) to 37 mg/L (Class V). BOD level in August
2021 and September 2021 exceeded Class III limit of NWQS. COD level ranged from
23 mg/L (Class II) to 279 mg/L (Class V). COD level in August 2021 and September
2021 exceeded Class III limit of NWQS.
TSS level ranged from below detection limit to 214 mg/L (Class IV) where TSS value
in September 2021 exceeded Class III limit of NWQS. Values of NH3-N, fluoride, and
boron falls within Class III limit of NWQS.

The water quality generally reported as slightly polluted or clean. Water quality was
reported as polluted in September 2021. BOD level ranged from 3.1 mg/L (Class III)
to 22.4 mg/L (Class V). BOD level in February 2019, April 2019, July 2019, and
November 2020 falls within Class III limit of NWQS while the level exceeded the
limit during other sampling duration. COD level ranged from 19 mg/L (Class II) to
175 mg/L (Class V). Values of TSS, NH3-N, fluoride, and boron fall within Class III
limit of NWQS.
The water quality at W5 is generally reported as clean except in July 2019 and May
2020 where the water quality was reported as slightly polluted and polluted
respectively. BOD level ranged from 2.9 mg/L (Class II) to 42.6 mg/L (Class V). BOD
level in May 2020 and August 2020 exceeded Class III limit of NWQS.
COD level ranged from 15 mg/L (Class II) to 347 mg/L (Class V). COD level in May
2020 exceeded the Class III limit of NWQS. Values of TSS, NH3-N, fluoride, and
boron fall within Class III limit of NWQS.
Water quality at W6 is generally reported as clean except in February 2019 and

August 2021 where it was reported as slightly polluted. BOD level ranged from 2.6
mg/L (Class II) to 14.8 mg/L (Class V). BOD level in February 2020 and August 2021
exceeded Class III limit of NWQS. COD level ranged from 13mg/L (Class II) to 97
mg/L (Class IV). COD level in August 2021 exceeded Class III of NWQS. Values of
TSS, NH3-N, fluoride, and boron fall within Class III limit of NWQS.

Table 6-24 Water Quality Data (Station PW1) from Post EIA Compliance Monitoring by BASF PETRONAS Chemicals Sdn. Bhd
Class 2019 2020 2021
Parameter Unit
III Feb Apr Jul Nov Feb May Aug Nov Feb Aug Sept
Temperature °C - 26.1 28.0 32.1 29.1 29.2 29.8 32.2 25.9 27.5 30.5 33.2
pH 6-9 6.9 5.9 6.7 7.7 7.1 6.9 6.3 6.7 7.1 7.3 7.4
Dissolved Oxygen (DO) mg/L 3-5 6.0 4.0 4.4 5.0 3.0 1.9 6.6 5.6 5.6 5.4 5.5
Total Suspended Solid (TSS) mg/L 150 111 42.5 7.0 < 5.0 <5.0 18.5 <5.0 45.8 7.0 10.4 10.2
Biochemical Oxygen
mg/L 6 3.3 4.7 4.6 6.4 5.9 5.1 6.6 4.8 4.1 9.0 7.2
Demand (BOD)
Chemical Oxygen Demand
mg/L 50 35 38 42 45 46 35 61 35 37 44 55
(COD)
Ammoniacal Nitrogen
mg/L 0.9 0.06 0.06 0.05 0.05 <0.05 0.08 0.07 0.05 0.05 0.05 0.06
(NH3-N)
Formaldehyde mg/L - 0.3 <0.3 0.5 <0.3 0.7 2.4 1.2 0.9 0.7 1.0 0.3
Fluoride mg/L 10 0.13 0.31 0.62 0.34 0.49 0.34 1.4 0.19 0.30 0.49 0.66
Boron mg/L (3.4) 0.05 0.04 0.12 0.09 0.17 0.32 0.59 0.03 0.24 0.26 2.51
79.26 72.29 78.94 78.69 71.11 67.71 81.94 79.27 82.72 77.14 77.24
Water Quality Index (Class)
(II) III) (II) (II) III) (III) (II) (II) (II) (II) (II)
River Classification SP SP SP SP SP SP C SP C SP SP
Source: Chemsain Konsultant Sdn. Bhd. (2019 – 2021)

Note:
2. <: Below detection limit

Class 2019 2020 2021
Parameter Unit
Temperature °C - 26.5 28.5 33.0 30.3 29.3 30.1 30.7 25.6 27.1 31.4 32.3
pH 6-9 6.7 6.4 6.4 8.0 7.1 6.8 6.4 6.8 7.1 7.1 7.5
mg/L 150 89 37.5 7.3 6.0 5.0 17.5 8.0 48.0 9.3 8.4 16.0
(TSS)
Biochemical Oxygen
mg/L 6 4 6.1 3.6 4.6 5.5 5.6 6.8 6.8 3.9 8.9 6.7
Demand (BOD)
mg/L 50 39 37 11 38 45 40 63 43 36 59 49
(COD)
Ammoniacal Nitrogen
mg/L 0.9 0.06 0.06 0.06 <0.05 <0.05 0.07 0.07 0.05 0.05 0.05 0.05
(NH3-N)
Formaldehyde mg/L - 0.3 0.4 0.3 <0.3 0.3 2.8 0.4 1.1 0.9 1.1 <0.3
Fluoride mg/L 10 0.13 0.35 0.33 0.42 0.43 0.36 1.1 0.18 0.34 0.59 0.71
Boron mg/L (3.4) 0.06 0.14 0.46 0.10 0.17 0.34 0.32 0.03 0.20 0.28 2.83
77.15 74.71 84.38 78.98 71.61 67.44 71.25 78.00 80.90 74.84 80.09
(II) (III) (II) (II) (III) (III) (III) (II) (II) (III) (III)
River Classification SP SP C SP SP SP SP SP SP SP SP
Note:

Class 2019 2020 2021
Parameter Unit
Temperature °C - 27.6 35.7 34.0 30.9 29.3 32.6 33.8 25.1 29.8 32.3 33.0
pH 6-9 7.6 8.0 7.3 8.2 7.1 8.0 7.6 7.3 7.8 8.1 7.8
Total Suspended Solid (SS) mg/L 150 15.5 26 5.3 <5.0 <5.0 <5.0 5.6 7.3 13.8 68.5 214
Biochemical Oxygen
mg/L 6 3.1 3.3 4.4 6.0 4.1 4.4 4.6 2.8 5.9 17.3 37.0
Demand (BOD)
mg/L 50 23 26 37 43 30 41 43 23 46 108 279
(COD)
Ammoniacal Nitrogen
mg/L 0.9 0.05 0.05 <0.05 0.05 <0.05 0.07 0.07 0.05 0.05 0.07 0.14
(NH3-N)
Formaldehyde mg/L - 1.7 6.6 8.7 6.8 4.4 20.1 5.1 3.7 12.1 6.0 33
Fluoride mg/L 10 0.16 0.32 0.32 0.28 0.19 0.03 0.4 0.07 0.17 0.16 0.17
Boron mg/L (3.4) 0.02 0.03 0.04 0.04 0.04 0.03 0.05 <0.01 0.04 0.05 0.06
82.33 89.36 87.68 82.73 87.27 80.87 86.03 88.76 83.54 64.89 42.08
(II) (II) (II) (II) (II) (II) (II) (II) (II) (III) (IV)
River Classification C C C C C SP C C C SP P
Note:

Class 2019 2020 2021
Parameter Unit
Temperature °C - 27.4 35.8 32.9 31.7 30.3 33.9 34.9 26.1 30.1 33.3 33.6
pH 6-9 7.1 7.8 7.2 8.8 7.5 7.9 7.7 7.6 7.8 7.6 7.5
Total Suspended Solid (SS) mg/L 150 26.5 22 9.7 7.5 <5.0 <5.0 11.6 8.0 11.0 35.0 103
Biochemical Oxygen
mg/L 6 4.3 3.4 4.2 6.1 6.3 17.5 8.8 3.1 8.4 15.5 22.4
Demand (BOD)
mg/L 50 29 22 37 59 50 88 76 19 54 101 175
(COD)
Ammoniacal Nitrogen
mg/L 0.9 0.05 0.05 <0.05 0.06 0.06 0.07 0.08 0.05 0.05 0.06 0.13
(NH3-N)
Formaldehyde mg/L - 1.5 5.7 3.8 2.7 1.5 15.1 2.3 2.0 5.2 3.5 28
Fluoride mg/L 10 0.5 0.28 0.54 1.16 1.68 0.03 1.95 0.17 1.20 1.76 1.05
Boron mg/L (3.4) 0.28 0.03 0.19 0.71 0.89 0.03 1.47 0.06 1.88 1.63 1.09
82.34 84.77 87.5 80.38 84.44 58.34 78.69 89.83 81.58 68.54 55.73
(II) (II) (II) (II) (II) (III) (II) (II) (II) (II) (III)
River Classification C C C SP C SP SP C C SP P
Note:

Class 2019 2020 2021
Parameter Unit
Temperature °C - 26.8 34.2 32.1 30.6 32.2 32.1 35.1 26.1 30.6 33.4 31.5
pH 6-9 7.1 6.6 8.5 8.5 7.4 8.0 7.8 7.1 7.7 7.0 6.6
Dissolved Oxygen (DO) mg/L 3-5 6.2 4.8 8.7 6.3 7.5 <1.0 10.6 7.3 8.2 8.0 7.8
Total Suspended Solid (SS) mg/L 150 55 33 16.6 6.0 8.5 8.5 13.6 11 18.5 11.5 8.5
Biochemical Oxygen
mg/L 6 2.9 4.2 7.9 4.9 4.2 42.6 6.4 3.8 4.7 3.5 3.0
Demand (BOD)
mg/L 50 15 18 47 43 31 347 39 24 19 25 28
(COD)
Ammoniacal Nitrogen
mg/L 0.9 <0.05 <0.05 <0.05 0.05 <0.05 0.07 0.05 0.05 <0.05 <0.05 <0.05
(NH3-N)
Formaldehyde mg/L - <0.3 <0.3 0.3 5.4 <0.3 0.4 <0.3 <0.3 <0.3 <0.3 <0.3
Fluoride mg/L 10 0.09 0.16 0.15 0.29 0.34 0.01 0.2 0.07 0.14 0.15 0.12
Boron mg/L (3.4) 0.02 0.06 0.05 0.06 0.10 0.01 <0.01 <0.01 0.10 0.03 0.02
85.86 86.78 80.96 82.88 88.41 39.74 84.86 89.23 88.69 89.97 89.92
(II) (II) (II) (II) (II) (IV) (II) (II) (II) (II) (II)
River Classification C C SP C C P C C C C C

Note:

Class 2019 2020 2021
Parameter Unit
Temperature °C - 27.0 35.7 32.0 29.8 28.6 32.7 34.6 26.0 31 33.9 31.1
pH 6-9 6.9 7.8 8.4 8.6 8.0 8.7 7.9 7.1 7.9 7.4 6.9
Dissolved Oxygen (DO) mg/L 3-5 6 6.7 7.7 6.9 8.4 8.0 9.3 7.0 7.7 5.9 7.9
mg/L 150 60 <5.0 18.3 6.7 7.5 <5.0 11.5 23.3 10.5 17.0 14.5
(TSS)
Biochemical Oxygen
mg/L 6 2.9 5 3.5 2.6 6.3 4.3 5.3 2.6 5.3 14.8 2.9
Demand (BOD)
mg/L 50 15 13 27 18 50 41 33 28 21 97 25
(COD)
Ammoniacal Nitrogen
mg/L 0.9 <0.05 <0.05 <0.05 <0.05 <0.05 0.06 0.05 0.1 <0.05 0.06 <0.05
(NH3-N)
Formaldehyde mg/L - <0.3 <0.3 <0.3 <0.3 <0.3 19.9 <0.3 <0.3 <0.3 0.9 0.9
Fluoride mg/L 10 0.06 1.06 0.14 0.22 3.03 0.02 0.19 0.06 2.37 2.56 0.11
Boron mg/L (3.4) 0.01 1.89 0.05 0.03 1.87 0.02 <0.01 <0.01 1.61 3.42 0.02
85.05 86.61 87.21 89.29 83.68 84.62 86.73 87.92 88.94 69.55 90.19
(III) (II) (II) (II) (II) (II) (II) (II) (II) (III) (II)
River Classification SP C C C C C C C C SP C

Note:

6.8 WASTE MANAGEMENT
6.8.1 Solid Waste
6.8.1.1 Existing Solid Waste Management
Solid waste management in Kuantan is regulated by the Solid Waste and Public
Cleansing Management Corporation (SWCorp), which has the authority to
administer and enforce the solid waste management and public cleansing
regulations. The nearest disposal facility is Tapak Pelupusan Jabor Jerangau (~4.3km
from Project site), which is under the jurisdiction of Majlis Bandaraya Kuantan
(Chart 6-18).
Chart 6-18 Location of Nearest Disposal Facility (Tapak Pelupusan Jabor

Jerangau) from Project Site
Legend
Project Site
ICS Boundary
Tapak Pelupusan
Jabor Jerangau
Transportation Route

The Project Proponent has also recently kick-started a separation at source initiative,
where recyclable items will be separated and sorted into the recycle collection bin for
collection by Alam Flora Sdn. Bhd. Currently, other solid wastes from the ICS are
being managed by Husky Enviro Services Sdn. Bhd. under the jurisdiction of Majlis
Bandaraya Kuantan to be disposed at Tapak Pelupusan Jabor Jerangau (Appendix
G).
6.8.1.2 Existing Solid Waste Generation
Solid wastes from the existing 2-EHAcid plant (Plant I) consists of general domestic
wastes, which are generated from a number of 18 staff. Assuming that the total waste
generation rate is 0.41 kg/capita/day for industry, based on the Survey on Solid
Waste Composition, Characteristics & Existing Practice of Solid Waste Recycling in
Malaysia published by the JPSPN (2013), the total amount of domestic wastes
generated from the staff is estimated to be 7.38 kg/day.
6.8.2 Scheduled Waste
6.8.2.1 Existing Scheduled Waste Management
Scheduled waste within the ICS and those generated by the Project Proponent’s
contractors were identified and managed based on an existing Scheduled Waste
Management Plan (SWMP) according to the Malaysian regulatory requirement.
For contractor’s scheduled waste that are generated within the ICS, a personnel
managing the contractor from the Project Proponent is responsible to raise a
scheduled waste notification form on behalf of the contractor. Then, the superior of
the responsible personnel will have to verify and approve the notification form. The
contractor should ensure the following requirements are met before the scheduled
wastes are taken by BPC’s Environmental Department (ENV) to the scheduled waste
storage area within the ICS:
• Each waste must have its own Waste Card Information that is attached with
the scheduled waste notification form. The waste card information shall be
prepared/verified by the contractor. The waste card should contain
information on the waste characteristics, and how to handle and dispose the
waste;
• The contractor shall collect the waste into the container either by pumping,
shoveling or tipping;
• The contractor shall ensure suitable waste container is used for different type
of scheduled wastes;
• The contractor shall ensure sorting and segregation of waste, so that
incompatible wastes are segregated;

• The contractor shall label the waste container according to the waste
information sticker;
• The contractor shall be responsible to fill up all information on the waste
information sticker;
• Any unnecessary labels found on any container must be removed either by
painting or any other method acceptable;
• The contractor shall provide temporary scheduled wastes storage and shall
keep the waste at temporary shed prior movement to the Scheduled Waste
Storage Building (Plate 6-10); and
• The contractor shall keep and update the record of scheduled wastes
generated, and the record must be ready for inspection and audit. The record
must be updated for monthly analysis and be kept for a period of three years.
ENV shall keep the scheduled waste notification form as a record.
Currently, the scheduled wastes within the ICS are sent to licensed scheduled waste
facilities, such as Ranama Resource Sdn. Bhd. and Kualiti Alam Sdn. Bhd.
Plate 6-11 Existing Scheduled Waste Storage Area Within ICS (A 342)
The SWMP is applicable to all scheduled wastes except clinical, pathological,

explosive, and radioactive waste. There are three main policies in which the
implementation of SWMP is based on:
i) Cradle to Grave: The waste generator is responsible and liable on all

scheduled wastes that are generated from their operation. The
responsibility and liability end when the SW is finally being disposed or
recovered at an approved off-site facility.

ii) Centralized Control: All scheduled wastes that are meant for disposal or
recovery must go through a central control, i.e., ENV. In implementing
this policy, ENV is responsible to identify and advice the waste generator
on the regulatory requirement, disposal/recovery arrangement and
enforcement of this SWMP.
iii) Pollution Prevention: Waste generator must handle SW via pollution
prevention hierarchy, i.e., prevent, reduce, reuse, recover, and disposal as
the last option.
6.8.2.2 Existing Scheduled Waste Generation
The maximum daily quantity of scheduled wastes generated from the existing 2-
EHAcid plant (Plant I) is summarized in Table 6-30.
Table 6-30 Estimated Quantity of Scheduled Wastes Generated from

Existing 2-EHAcid Plant (Plant I)
Maximum
Current
SW Quantity
No. Description Source Management
Code Generated
Method
(MT/yr)
Production
Process Send to
1 SW202 Waste catalysts (Selective 2.3 Kualiti Alam
hydrogenation Sdn. Bhd.
process)
Sludges containing
one or several metals
including chromium, Wastewater
Send to
copper, nickel, zinc, Treatment
2 SW204 0.16(1) Kualiti Alam
lead, cadmium, Plant
Sdn. Bhd.
aluminum, tin, (Belt press)
vanadium and
beryllium
Send to
3 SW305 Spent lubricating oil Maintenance 0.038(2) Kualiti Alam
Sdn. Bhd.
Send to
4 SW306 Spent hydraulic oil Maintenance 0.0031(2) Kualiti Alam
Sdn. Bhd.
Disposed containers, Send to
bags or equipment Kualiti Alam
contaminated with Sdn. Bhd. or
5 SW409 Maintenance 0.418
chemicals, pesticides, Ranama
mineral oil or Resource
scheduled wastes Sdn. Bhd.
A mixture of Send to
6 SW422 scheduled and non- Maintenance 1.9 Kualiti Alam

Maximum
Current
SW Quantity
Code Generated
Method
(MT/yr)
Chemicals that are Send to
Shared
7 SW429 discarded or off- 0.9 Kualiti Alam
laboratory
specification Sdn. Bhd.
Total 5.7191
Note:
1. Estimation based on total amount of sludge generated for the entire premise.
2. Estimation based on total amount of the said scheduled waste generated for the entire premise in a
year (Production area of 2-EHAcid Plant I is approximately 0.2% of the developed area within ICS).
From Table 6-30, it is observed that the main scheduled waste generated from the
existing 2-EHAcid plant is waste catalyst.
6.9 EXISTING TRAFFIC CONDITION

The Project site is accessible from the East Coast Expressway Lebuhraya Pantai
Timur (LPT), through Jabor exit, via the Gebeng Bypass or Jalan Pintasan Kuantan,
and then Jalan Gebeng 1/11.
The Gebeng Bypass, which eases traffic flow from the Gebeng Industrial Estate (GIE)
to Kuantan Port, links Kuala Lumpur and Kuantan directly via the East Coast
Highway. The route generally has low traffic and avoids directly passing through
the area of Kuantan Port and residential areas or schools.
The existing traffic volume data at the nearby roads and junctions were referred from
the EIA of Proposed Development of a Permanent Disposal Facility (PDF) for Water
Leach Purification (WLP) Residue prepared by Dr. Nik & Associates Sdn. Bhd.,
which was published on the DOE website on 12th of October 2021. The traffic data
from the EIA study was based on the forecast of other traffic studies conducted in
the previous years before the COVID-19 pandemic and lockdown. The main
document referred in this study was Road and Traffic Volume 2019 published by the
Highway Planning Division (Ministry of Works Malaysia). The junctions and
existing traffic volume referred are indicated in Chart 6-19.

Chart 6-19 Junction Locations and Existing Traffic Volume
J1
J3
J3
J2
J1 J4
J4
J2
J5 Legend
Project Site
J5 ICS Boundary
J Junction Location
The level of service for the access roads, Gebeng Bypass, Jalan Pintasan Kuantan and
Jalan Gebeng 1/11, are summarized in Table 6-31, and the meaning of level of service
is summarized in Table 6-32.
Table 6-31 Level of Service (LOS) for Access Roads

Volume
Capacity V/C Ratio (LOS)
Road Road Type (pcu/hr)
(pcu/hr/lane)
AM PM AM PM
3,600 0.19 0.07
689 259
Gebeng Dual-2 (northbound) (LOS A) (LOS A)
Bypass carriageway 3,600 0.11 0.07
396 267
(southbound) (LOS A) (LOS A)
3,600 0.19 0.06
Jalan 675 204
Dual-2 (northbound) (LOS A) (LOS A)
Pintasan
carriageway 3,600 0.08 0.08
Kuantan 284 281
(southbound) (LOS A) (LOS A)
Jalan Gebeng Single 0.03 0.09
2,200 71 189
1/11 carriageway (LOS A) (LOS A)

Table 6-32 Level of Service
Volume Capacity (V/C)
For Dual For Single
LOS Remarks
Two/Multi- Carriageway/Two
Lane/ Highway Lane Road
Free flow with low volume, densities
and high speeds. Drivers can maintain
A 0.00 to 0.28 0.00 to 0.15
their desired speeds with little or no
delay.
Stable flow. Operating speeds
B 0.29 to 0.47 0.16 to 0.27 beginning to be restricted somewhat by
traffic conditions. Slight delay.
Stable flow. Operating speeds and
maneuverability are more closely
C 0.48 to 0.66 0.28 to 0.43
controlled by higher volume.
Acceptable delay.
Approaching stable flow. Tolerable
operating speeds, which are
D 0.67 to 0.79 0.44 to 0.64
considerably affected by operating
conditions. Tolerable delay.
Unstable flow. Yet lower operating
E 0.80 to 1.00 0.65 to 1.00 speeds and perhaps stoppages of
momentary duration
Force flow. Speeds and volume can
drop to zero. Stoppages can occur for
F >1 >1 long periods. Queues of vehicle
backing up from a restriction
downstream.
From Table 6-31, it is observed that the three access roads all have LOS A, which
indicates that the existing traffic has a free flow with low volume and is considered
the best road operating condition. The drivers are expected to maintain their desired
speed with little or no delay.
6.10 SOCIO-ECONOMIC PROFILE

This section describes the demographic profile of the population within the Zone of
Influence (ZOI) area of 5 km from the Project site. Desk-based research included a
review of the Department of Statistics Malaysia Pahang’s Newsletter
(DOSM/DOSM.PAHANG/1.2020/SIRI 83) that provides the latest census
information on the population in Pahang and Kuantan District that have grown from
852,400 in 2013 to 872,900 in 2015. This represented an annual growth rate of 2.37%
from 2013 to 2015. However, the Data Asas Pahang 2014/2015 did not provide
demographic information at the mukim level.

To get information at the mukim level, one has to collect data from the 2010
Population and Housing Census of Malaysia, published by the DOSM in 2011, since
the latest official information available from the next Census Report due this year
was delayed due to the Movement Control Order (MCO) because of the COVID-19
pandemic. Hence, information on the population socioeconomics and demographics
for Mukim Sg. Karang have been projected to 2020 using a 2.37% per annum growth
rate. With that, the population of Mukim Sg. Karang is projected to be 69,312. This
provides the demographic status of Mukim Sg. Karang and Kuantan District.
6.10.1 Demographic and Socio-economic Profile of Mukim Sg. Karang
6.10.1.1 Population and Ethnic Composition
The above information is obtained from Department of Statistics Malaysia Pahang’s

Newsletter (DOSM/DOSM.PAHANG/1.2020/SIRI 83) that provides the latest
census information on the population in Pahang and Kuantan District, which has
grown from 852,400 in 2013 to 872,900 in 2015. This represented an annual growth
rate of 2.37% from 2013 to 2015. But the Data Asas 2015 did not provide demographic
information at the mukim level. To get information at the mukim level, data was
collected from the 2010 Population and Housing Census of Malaysia and projected
to 2020.
The mukim that the proposed project is located is Sungai Karang that has a projected
population of 69,312 taking up 12.36% of the district population of Kuantan (Table
6-33).
Table 6-33 Total Population of Pahang State, Kuantan District and the
mukim of Sg. Karang
Mukim Level Population 2020
Sungai Karang 69,312
Percent of District 12.36%
Table 6-34 shows the projected racial distribution of Sungai Karang as of 2020.
Malays form the majority of population with 87.27%. There were only 5.32% Chinese
population. There are smaller populations of Indian (1.24%), other Bumiputera
(1.77%) and non-Malaysians (4.03%) in this mukim.

Table 6-34 Ethnic Composition of Sg. Karang Mukim, 2020
Race Percentage Breakdown (%)
Malay 87.27
Other Bumiputera 1.77
Chinese 5.32
Indians 1.24
Others 0.37
Non-Malaysian Citizens 4.03
Total 100.00
6.10.1.2 Households and Living Quarters Distribution
Table 6-35 shows the projected number of households and living quarters in Sungai
Karang Mukim in 2020. The mukim of Sungai Karang has more living quarters than
number of households, with the ratio of living quarters to households of 1.12. This
implies that there should be available housing for households in the mukim
particularly.
Table 6-35 Projected Number of Households and Living Quarters in

Mukim Sg. Karang
Ratio of Living Quarters to
Mukim Households Living Quarters
Households
Sungai Karang 15,206 17,030 1.12
6.10.1.3 Population and Age Group
Chart 6-20 provides the breakdown of the age groups of the mukim. The age
structure of a population affects key socioeconomic issues of the district. Households
with young populations (high percentage under age 15 years) need to invest more in
school educations, while households with older populations (high percentage ages
65 and over) need to invest more in health care. The age structure can also be used to
help predict potential socioeconomic issues. For example, the rapid growth of a
young adult population suggests potential availability of labour force. But if they are
unable to find employment, it can lead to unrest.
The age distributions of the population are characterised as having 60.24% of the
populations in the working age group of 15-64 years, followed by 37.45% being
below 15 years of age. Only 2.32% belong to those with ages equal or more than 65
years old.

Chart 6-20 Proportions of Population Age Structure in Mukim Sg. Karang
2.32%
37.45% Age (Years)

<15
15 - 64
≥ 65
60.24%
6.10.1.4 Dependency Age Ratio
The age dependency ratio for the mukim has been computed and provided in Table
6-36. The age dependency ratio is calculated by dividing the group to three group,
namely the younger age group (less than 15 years old), working age group (15 to 64
years old) and older age group (above 65 years old). The younger and older group
are sum together then divided by the working age group and times by 100. The lower
the ratio the greater the potential and productive capacity.
The results showed that Sungai Karang Mukim has a ratio of 66.01% which is
considered quite high. There is a greater level of dependence among the population.
This dependence ratio tended to be higher than for the overall Malaysian age
dependency ratio of 44.74% (Index Mundi, 2015).
The high dependency ratio suggests that there was higher proportion of dependent
members of the population in the mukim relative to what occurred in the nation
overall. This can add a stress to the productive population. The creation of economic
opportunities in Sungai Karang Mukim becomes an important economic strategy for
the social well-being of society.
Table 6-36 Dependency Ratios in Mukim Sg. Karang, 2020

Regional Level Dependency Ratio
Pahang State 54.26%
Kuantan District 50.45%
Sungai Karang Mukim 66.01%

6.10.2 Zone of Influence (ZOI)
The Zone of Influence (ZOI) covering within a 5km radius of the project site involves
residential areas, institutions and public amenities.
6.10.2.1 Residential Areas
Table 6-37 shows the residential areas with distance from the Project site within the
5km radius. The residential areas are all at least 2km away from the Project Site
(Figure 6-13).
Table 6-37 Residential Areas Within 5km From the Project Site
No. Residential Area Distance from the Project Site
R1 Taman Balok Perdana 2.8km south
R2 Taman Balok Makmur 2.8km southeast
R3 Kg. Berahi 3.2km southeast
R4 Perumahan Balok Baru 3.5km southwest
R5 Kg. Seberang Balok 4.0 km southeast
R6 Kg. Balok Baru 4.5km southwest
R7 Taman Balok Pelangi 4.8km southwest
R8 Kg. Balok 4.8km south
R9 Kg. Selamat 5km southeast
6.10.2.2 Institutions and Public Amenities
Table 6-38 shows the list of institution and public amenities within 5km from the
Project site. Most of the institutions and public amenities within the 5km radius
includes schools for the residents staying at the residential areas towards the south
of the Project Site (Figure 6-13).
Table 6-38 Institutions and Public Amenities Within 5km From the Project
Site
No. Institutions and Public Amenities Distance from the Project Site
I1 Institut Latihan Perindustrian Kuantan 2.3km southeast
I2 Sekolah Kebangsaan Balok Baru 3.1km southeast
I3 Sekolah Kebangsaan Pelabuhan 3.2km southeast
I4 Sekolah Menengah Kebangsaan Pelabuhan 3.2km southeast
I5 Gebeng Police Station 3.6km southeast
I6 Akademi Maritim Sultan Ahmad Shah (AMSAS) 4.6km northeast
6.10.3 Perception Survey Outcome
A perception survey was conducted among respondents from residential areas

identified within a zone of influence (ZOI) of 5-km radius surrounding the Project

stie from 23rd to 27th Marth 2022. A structure questionnaire was prepared which
included various socio-economic includes and to gauge local communities’
perception of the proposed Project. A total of 406 respondents were interviewed to
obtain a general profile of residents living within the ZOI of the Project site.
6.10.3.1 Demographic Profile
A general profile of the respondents is provided in Table 6-39. There are slightly
more males than females. There are practically all Malays being surveyed as
indicated by the population breakdown. The age distribution is well distributed with
a large proportion from ages of 25 to 44 years old taking up 57.9%. A majority of the
respondents have full-time employment, with many working in the private sector
and the largest education category was secondary schooling. A large portion of the
respondents has 3-6 household members with a household monthly income of
RM2,001-4000/month, taking 51.5% of the respondents.
Table 6-39 General Profile of the Respondents Surveyed

No. Profile Statistic Value
1 Gender Mode Male (54.9%); Female (45.1%)
2 Age Mean 25-44 Years (57.9%)
3 Race Mode Malay (97.3%)
4 Employment Mode Full-time Private Sector (37.4%)
5 Education Mode Secondary school (60.8%)
6 Household Income Mode RM2,001-4,000/month (51.5%)
7 Household size Mode 3-6 members (75.2%)
6.10.3.2 Employment Status and Occupation
The main employments are in the private sector (37.4%) and self-employment (17.0%)
with 6.9% in the public sector. (Table 6-40). The remaining percentages comprised
those who are unemployed (5.9%), housewives (23.2%), students (4.9%) and retirees
(4.7%).
Table 6-40 Employment Status of Villagers Surveyed

Status Percentage (%)
Unemployed 5.9
Public sector employee 6.9
Private sector employee 37.4
Self-employed 17.0
Pensioner 4.7
Homemaker 23.2
Students 4.9
Total 100.0

In general, a reasonable occupation distribution belongs to the management and
professional jobs comprising of managerial level, professionals, and technical/semi-
professionals that involved 4.9%, 8.9% and 20.9% respectively (Table 6-41). There are
also high proportions working as general workers (11.1%), and clerk, sales and
service (6.4%). The remaining working households are involved in agricultural and
livestock workers (2.5%) and production various goods (7.1%), and arts and crafts
products (1.0%). Yet, a high percentage is currently not working (37.2%).
Table 6-41 Nature of Jobs Being Employed

Type Percentage (%)
Currently not working 37.2
Management & Administration 4.9
Professionals 8.9
Semi-professional & technical 20.9
Clerical, sales & service worker 6.4
Agricultural & livestock worker 2.5
Arts & Crafts 1.0
Production of goods 7.1
General labour 11.1
Total 100.0
6.10.3.3 Household Income
The monthly household incomes of the responding villagers ranged widely from
those earning less than and equal to RM1,000/month to as high as more than
RM10,000 per month (Table 6-42). The highest income category belongs to RM2,001-
RM3,000/month with 25.9% and RM3,001-RM4,000/month with 25.6%. Reasonably
high percentages have household incomes of RM1,001-RM2,000/month and
RM4,001-RM5,000 with 13.1% and 14.8% respectively.
Table 6-42 Distribution of Household Incomes Among Community

Surveyed
Income bracket Percentage (%)
≤ RM1,000 4.9
RM1,001 - RM2,000 13.1
RM2,001 - RM3,000 25.9
RM3,001 - RM4,000 25.6
RM4,001 - RM5,000 14.8
RM5,001 - RM6,000 8.9
RM6,001 - RM7,000 1.7
RM7,001 - RM8,000 1.7
RM8,001 - RM9,000 1.0
RM9,001 - RM10,000 1.7
≥ RM10,001 0.7
Total 100.0

6.11 EXISTING PUBLIC HEALTH
6.11.1 Public Health Survey
A study of the public health status of the communities residing in the vicinity of the
Project site at Gebeng Industrial Estate (GIE), Kuantan, Pahang was conducted. The
objective was to describe the existing, baseline information on the state of health of
the community prior to the construction and operation of the proposed Project.
Health data was obtained from the public health survey conducted on 23rd to 27th
March 2022 within community in the vicinity of the Project site.
6.11.1.1 Background of Respondents
A total of 406 households were surveyed comprising a total of 1,929 household

members, giving an average household size of 4.8 or 5 persons per household. Table
6-43 shows the distribution of households sampled by residential areas. A majority
of the respondents resided in Taman Balok Perdana (37.7%), Kampung Berahi (27.1%)
and Kampung Balok Baru (12.1%).
Table 6-43 Distribution of Households Sampled by Residential Areas

Residential Areas Number of Households Percentage (%)
Taman Balok Perdana 153 37.7
Taman Balok Makmur 12 2.9
Kampung Berahi 10 27.1
Perumahan Balok Baru 32 7.9
Kampung Seberabg Balok 30 7.4
Kampung Balok Baru 49 12.1
Taman Balok Pelangi 5 1.2
Kampung Balok 10 2.5
Kampung Selamat 5 1.2
Total 406 100.0
Table 6-44 shows the respondents’ highest level of education. A small proportion
(1.7%) of the respondents had no formal education. Almost two-third (60.8%) of them
had secondary school education, followed by pre-university education (21.4%) and
tertiary education (9.9%).

Table 6-44 Respondents’ Highest Level of Education
Education Levels Number of Respondents Percentage (%)
No formal education 7 1.7
Primary school 25 6.2
Secondary school 247 60.8
Pre-university (STPM and diploma) 87 21.4
Tertiary education 40 9.9
Total 406 100.0
Table 6-45 shows the respondents’ length of stay in their present houses. These seem
to be a relatively new community as a majority (41.1%) of the respondents have
stayed for less than 20 years in their present houses. Only 11.3% of the respondents
had stayed more than 40 years.
Table 6-45 Respondents’ Length of Stay in Present House

Length of Stay (Years) Number of Households Percentage (%)
≤5 39 9.6
6-10 45 11.1
11-15 38 9.3
16-20 45 11.1
21-25 45 11.1
26-30 36 8.9
31-35 37 9.1
36-40 40 9.8
41-45 28 6.9
46-50 18 4.4
51-55 15 3.7
56-60 12 3.0
≥ 61 8 2.0
Total 406 100.0
6.11.1.2 Housing
Table 6-46 shows the type of respondents’ houses. Most of the respondents lived in
terrace (55.9%) and semi-detached houses (26.8%). Table 6-47 indicates the building
materials of the houses, whereby most of the houses were built of completely brick
(95.8%). Most (63.6%) of the houses have air-conditioning. Some 35% of the houses
have household members who smoke inside the house. This practice may contribute
to poor indoor air quality in the homes.

Table 6-46 Type of Respondents’ Houses
House Type Number of Houses Percentage (%)
Kampung house 45 11.1
Detached house/modern bungalow 22 5.4
Semi-detached house 109 26.8
Terrace house 227 55.9
Flat / PPR 1 0.2
Shophouse 2 0.5
Total 406 100.0
Table 6-47 Building Materials Used for Houses

Type of house Number of Houses Percentage (%)
Completely wood 7 1.7
Completely brick 389 95.8
Wood and brick 10 2.5
Total 406 100
6.11.1.3 Environmental Sanitation Status
Table 6-48 shows the type of toilet in the houses surveyed. A significant percentage
(13.5%) of the houses did not have a toilet or had unhygienic toilets in the form of pit
or bucket latrines.
Table 6-48 Type of Toilet in the Houses Surveyed
Toilet Type Number of Houses Percentage (%)
No toilet 1 0.2
Pit latrine 53 13.1
Bucket toilet 1 0.2
Pour-flush latrine 7 1.7
Flush toilet 344 84.7
Total 406 100.0
Table 6-49 gives the sources of drinking water in the houses surveyed. A majority
(95.1%) of the houses had clean sources of drinking water in the form of gravity-feed
system, public standpipe or piped water to the houses.
Table 6-49 Source of Drinking Water in the Houses Surveyed

Source of Drinking Water Number of Houses Percentage (%)
Tube well - -
River water 1 0.2
Gravity-feed system 14 3.4
Piped water to the house 325 80.0
Piped water outside the house (standpipe) 47 11.6
Mineral water 2 0.5
Filtered water 17 4.2
Total 406 100

Table 6-50 shows the garbage disposal practices by the households surveyed. A
small percentage (2.9%) of the households surveyed still practiced unhygienic
garbage disposal practices like throwing in an open area, throwing into a drain, river
or beach and burning garbage without burying. Unhygienic garbage disposal
practices can lead to the breeding of pests like mosquitoes, flies, cockroaches and rats,
which can transmit communicable diseases in humans.
Table 6-50 Garbage Disposal Practices by the Households Surveyed

Garbage Disposal Practice Number Of Houses Percentage (%)
Thrown in an open area 2 0.5
Thrown into a drain/river/beach 1 0.2
Burn only 9 2.2
Burn and bury in a hole 9 2.2
Thrown into a hole and bury 2 0.5
Compost 6 1.5
Collection by local municipality 377 92.9
Total 406 100
Table 6-51 shows the pest problems experienced by the households surveyed. All
the households surveyed experienced all types of pest problems, but their biggest
problems were against mosquitoes (19.7%), flies (7.4%) and rodents (6.7%).
Table 6-51 Pest Problems Experienced by the Households Surveyed

Pest Problem Number Percentage (%)
Mosquitoes 301 74.1
Flies 140 34.5
Cockroaches 147 36.2
Ants 100 24.6
Rats 126 31.0
Note: Sample size, N = 406
In summary, the housing status of the communities surveyed is considered

satisfactory with respect to the types of houses, as all of the households seem to be
staying in decent and acceptable types of homes. As for the environmental sanitation
status, it was considered unsatisfactory as 13.5% houses still have unhygienic toilets
in the form of pit or bucket latrines or no toilet at all. However, it is considered as
generally satisfactory with respect to drinking water supply and garbage disposal
practices. However, pest problems need attention as some households still
experience problems with mosquitoes, flies and rodents.
6.11.2 Community Health Status
Table 6-52 gives the prevalence rates of selected diseases that have been diagnosed
by doctors within the last 1 year, among the 1,929 household members from the 406
households that were surveyed. The highest prevalence rates were for COVID-19

(2.54%) and hypertension (2.33%). While the prevalence rate for COVID-19 was
higher than the national rate, the rate for hypertension was well below the national
rate. Other prevalence rates that exceeded their national rates were tuberculosis,
dengue, leptospirosis, cholera and typhoid. This may indicate poor sanitation and
hygiene among the affected population.
Table 6-52 Household Members Diagnosed with Selected Diseases By Doctors

Within The Last Year
Disease Number Prevalence (%) National prevalence (%)
4.5 (adults)a
Asthma 22 1.14
7.1 (children)a
URTI 1 0.05
Rhinitis 4 0.21
Pneumonia 1 0.05
Chronic bronchitis 1 0.05
Tuberculosis 4 0.21 0.07 b
Lung cancer 4 0.21
Nasopharyngeal cancer 1 0.05
Other cancers 5 0.26
Hypertension 45 2.33 30.0c
Heart failure 7 0.36
Cerebrovascular accident 5 0.26
Diabetes mellitus 33 1.71 18.3c
Kidney disease 7 0.36
Liver disease 1 0.05
Skin disease 8 0.41
Dengue 7 0.36 0.28 b
Leptospirosis 11 0.57 0.0089 b
Cholera 1 0.05 0.00035 b
Typhoid 2 0.10 0.0002 b
Hepatitis 1 0.05
COVID-19 49 2.54 0.36 b
Spontaneous abortion 1 0.05
Kelahiran mati 3 0.16
Note: Sample size, N = 1,929
Sources : a Ministry of Health Malaysia, 2008
b Ministry of Health Malaysia, 2021
c Ministry of Health, 2020
As shown by Table 6-53, the main reasons household members sought medical
treatments at hospitals or clinics within the last 3 months were for fever (1.5%),
asthmatic attack (1.24%) and cold and cough (1.24%). These would be common
illnesses experienced by most communities in Malaysia.

Table 6-53 Reasons for Seeking Medical Treatments by Household Members
Within the Last 3 Months
Disease/health problem Number Prevalence (%)
Asthmatic attack 24 1.24
Fever 29 1.50
Cold/cough 24 1.24
Wheezing 1 0.05
Shortness of breath (dyspnea) 7 0.36
Fits 3 0.16
Vomiting 4 0.21
Diarrhoea 4 0.21
Chest pain 9 0.47
Heart attack 2 0.10
Eye related diseases 2 0.10
Skin disease 1 0.05
Note: Sample size, N = 1,929
6.11.3 Morbidity Statistics
Morbidity statistics on diseases related to the environment were obtained from

Klinik Kesihatan Balok and Hospital Tengku Ampuan Afzan for a period of 1 year
from January to December 2021. Table 6-54 shows the disease cases related to air
pollution seen at Klinik Kesihatan Balok in 2021. Eye and respiratory diseases as
represented by conjunctivitis, upper respiratory tract infections, asthma, tuberculosis,
pneumonia and bronchitis made up 7.5% and 41.6% of all adults and children cases,
respectively. Cardiovascular diseases as represented by hypertension, ischaemic
heart disease and cerebrovascular accident/stroke made up 0.4% of all adults cases.
Therefore, there seems to be a significant percentage of URTI cases seen at Klinik
Kesihatan Balok among children in 2021. No disease cases related to water pollution,
animal vector and reservoir was seen at Klinik Kesihatan Balok in 2021.
Table 6-55 gives the morbidity statistics on skin disease cases seen at Klinik
Kesihatan Balok in 2021. Only cases of cutaneous abscess/furuncle and carbuncle,
cellulitis, dermatitis and eczema and urticaria were reported which made up only
4.3% and 13.8% of all adults and children cases. Of these, dermatitis and eczema and
urticaria which made the most number of cases among adults and children, are
allergic forms of skin reactions that may be exacerbated by allergens and irritants
that may be present in air pollution or dust. Thus, skin cases seems to make up a
significant proportion of the children cases.
Table 6-56 to Table 6-59 give the morbidity statistics of various disease cases seen at
Hospital Tengku Ampuan Afzan in 2021. However, the hospital was not able to
provide us with the breakdown of total disease cases between adults and children
seen at the hospital, to enable us to make a comparison between the percentages of
cases.

Table 6-60 shows the prevalence rates of selected communicable diseases in the
District of Kuantan in 2021, in comparison with the prevalence of these diseases in
Malaysia in 2020. The prevalence rates for dysentery, food poisoning and COVID-19
were very much higher than that of the nation. This means that foodborne diseases
as well as COVID-19 were a problem in the district.

Table 6-54 Disease Cases Related to Air Pollution Seen at Klinik Kesihatan Balok 2021
Lung *Total
Month
Conj. URTI Inf. Asth. TB Pneu. Bron. Emphy. HPT HF IHD CVA
Year
Ca (All patients)
A C A C A C A C A C A C A C A C A C A C A C A C A C A C
J 17 9 167 175 0 0 0 4 0 0 1 6 0 8 0 0 0 0 3 0 0 0 1 0 0 0 2877 435
1.1.1.1
F 17 8 185 180 0 0 0 2 0 0 0 5 0 9 0 0 0 0 2 0 0 0 0 0 1 0 3107 442

M 21 9 178 154 0 0 0 3 0 0 0 4 0 8 0 0 0 0 3 0 0 0 1 0 0 0 2833 628
A 15 16 231 273 0 0 0 5 2 0 0 7 0 12 0 0 0 0 19 0 0 0 0 0 0 0 2743 651
M 19 11 156 197 0 0 0 4 1 0 0 3 0 9 0 0 0 0 19 0 0 0 0 0 0 0 2312 409
J 20 12 173 208 0 0 0 5 0 0 0 3 0 8 0 0 0 0 26 0 0 0 2 0 1 0 2755 480
2021
J 19 9 187 172 0 0 0 6 0 0 0 5 0 12 0 0 0 0 5 0 0 0 0 0 1 0 2628 448

A 20 10 166 163 0 0 0 4 0 0 0 3 0 12 0 0 0 0 4 0 0 0 0 0 0 0 2658 451
S 20 11 169 147 0 0 0 6 0 0 0 4 0 14 0 0 0 0 10 0 0 0 0 0 0 0 2573 475
O 14 8 145 96 0 0 0 4 1 0 0 4 0 10 0 0 0 0 5 0 0 0 0 0 1 0 2579 475
N 18 11 281 274 0 0 0 3 0 0 0 2 0 12 0 0 0 0 15 0 0 0 0 0 0 0 2484 613
D 21 10 174 167 0 0 0 5 0 0 0 8 0 16 0 0 0 0 16 0 0 0 0 0 0 0 3011 626
Total 221 108 2212 2206 0 0 0 51 4 0 1 54 0 130 0 0 0 0 127 0 0 0 4 0 4 0 32560 6133
Note:
Conj. : Conjunctivitis Emphy. : Emphysema
URTI : Upper Respiratory Tract Infections Lung Ca : Lung Cancer
Inf. : Influenza HPT : Hypertension
Asth. : Asthma HF : Heart Failure
TB : Tuberculosis IHD : Ischaemic Heart Disease
Pneu. : Pneumonia CVA : Cerebrovascular Accident/Stroke
Bron. : Chronic Bronchitis
*Total (All patients): Total number of all in-patients and out-patients who visited this facility during that month (not the sum for all the diseases).
A: Adult
C: Children

Table 6-55 Skin Disease Cases Seen at Klinik Kesihatan Balok In 2021
*Total
Cutan. Cell. Derm. Psor. Urti. Dis. Eryth. Rad.
Year Month (All patients)
A C A C A C A C A C A C A C A C A C
Jan 0 0 5 0 76 49 0 0 37 20 0 0 0 0 0 0 2877 435
Feb 0 0 3 0 104 56 0 0 28 12 0 0 0 0 0 0 3107 442
Mar 0 0 4 0 61 39 0 0 42 22 0 0 0 0 0 0 2833 628
Apr 0 0 4 0 78 53 0 0 34 24 0 0 0 0 0 0 2743 651
May 0 0 4 0 72 44 0 0 28 18 0 0 0 0 0 0 2312 409
June 0 0 5 0 70 47 0 0 33 24 0 0 0 0 0 0 2755 480
2021
July 0 0 5 0 77 52 0 0 41 28 0 0 0 0 0 0 2628 448
Aug 0 0 2 0 66 48 0 0 34 25 0 0 0 0 0 0 2658 451
Sep 1 0 5 0 49 42 0 0 30 22 0 0 0 0 0 0 2573 475
Oct 0 0 4 0 68 37 0 0 32 18 0 0 0 0 0 0 2579 475
Nov 1 0 4 0 96 55 0 0 50 28 0 0 0 0 0 0 2484 613
Dec 0 0 5 0 99 59 0 0 31 25 0 0 0 0 0 0 3011 626
Total 2 0 50 0 916 581 0 0 420 266 0 0 0 0 0 0 32560 6133
Note:
Cutan. : Cutaneous abscess/Furuncle & Carbuncle Urti. : Urticaria
Cell. : Cellulitis Dis. : Disorders of skin appendages
Derm. : Dermatitis and Eczema Eryth. : Erythemas
Psor. : Psoriasis Rad. : Radiodermatitis & other radiation-related disorders of the skin & subcutaneous tissue
A: Adult
C: Children

Table 6-56 Disease Cases Related to Air Pollution Seen at Hospital Tengku Ampuan Afzan In 2021
Lung *Total
Month
Conj. URTI Inf. Asth. TB Pneu. Bron. Emphy. HPT HF IHD CVA
Year
Ca (All
A C A C A C A C A C A C A C A C A C A C A C A C A C patients)
J 77 11 154 40 0 0 223 30 31 1 190 87 150 42 150 42 17 0 114 0 24 0 145 0 96 9 24,935
1.1.1.2
F 95 8 139 36 0 0 139 31 39 1 177 74 138 41 137 41 17 0 147 0 12 0 158 0 61 11 24,855

M 79 17 149 57 0 0 227 55 45 1 193 96 181 62 181 61 14 0 202 0 20 0 173 0 65 7 31,450
A 100 16 210 103 1 1 207 55 48 0 274 97 240 97 240 97 24 0 135 0 31 0 177 0 80 3 28,733
M 101 16 172 98 0 0 144 52 43 1 237 98 207 91 207 90 17 0 123 0 15 0 95 0 76 3 22,446
J 99 9 149 40 0 0 143 33 43 1 180 55 180 55 180 55 9 0 140 1 23 1 124 0 48 11 24,356
2021
J 104 11 162 41 0 1 141 36 36 1 163 57 162 62 162 62 4 0 90 0 12 0 77 1 68 12 23,128

A 100 7 162 39 0 0 197 33 49 1 155 59 169 57 170 57 6 0 128 1 17 0 111 0 64 2 24,436
S 89 8 165 35 0 0 159 50 30 0 158 59 173 50 173 50 5 0 125 0 21 0 101 0 83 9 25,032
O 96 9 150 50 0 3 190 59 29 0 172 55 168 47 168 47 5 0 146 0 15 0 108 0 62 6 25,260
N 94 15 155 59 0 3 198 63 4 33 175 99 176 59 176 59 6 0 168 0 15 0 131 0 80 3 26,855
D 92 15 155 77 4 2 199 82 36 0 172 131 162 70 162 68 5 0 163 0 38 0 139 0 75 8 27,185
Total 1126 142 1922 675 5 10 2167 579 433 40 2246 967 2106 733 2106 729 129 0 1681 2 243 1 1539 1 858 84 227,431
Note:
Conj. : Conjunctivitis Emphy. : Emphysema
URTI : Upper Respiratory Tract Infections Lung Ca : Lung Cancer
Inf. : Influenza HPT : Hypertension
Asth. : Asthma HF : Heart Failure
TB : Tuberculosis IHD : Ischaemic Heart Disease
Pneu. : Pneumonia CVA : Cerebrovascular Accident/Stroke
Bron. : Chronic Bronchitis
A: Adult
C: Children

Table 6-57 Disease Cases Related to Water Pollution Seen At Hospital Tengku Ampuan Afzan In 2021
Year Month Dys. Chol. Typ. Hep. A Polio. Food *Total
A C A C A C A C A C A C (All patients)
Jan 6 4 0 0 0 0 0 5 0 0 0 1 24, 935
Feb 4 1 0 0 0 0 0 4 0 0 0 0 24, 855
Mar 5 5 0 0 1 0 0 7 0 0 0 0 31, 450
Apr 8 2 0 0 0 0 14 14 0 0 2 4 28,733
May 5 3 0 0 0 0 8 5 0 0 1 3 22,446
2021 June 3 3 0 0 0 0 4 5 0 0 0 1 24,356
July 2 2 0 0 0 0 4 5 0 0 0 0 23,128
Aug 3 1 0 0 0 0 26 3 0 0 3 3 24,436
Sep 0 6 0 0 0 0 34 1 0 0 0 0 25,032
Oct 0 1 0 0 1 0 30 2 0 0 1 3 25,260
Nov 4 2 0 0 0 0 37 5 0 0 0 4 26,855
Dec 0 4 0 0 1 0 25 1 0 0 0 4 27185
Total 40 34 0 0 3 0 182 57 0 0 7 23 227,431
Note:
Dys. : Dysenteries
Chol. : Cholera
Typ. : Typhoid & Paratyphoid
Hep. A : Hepatitis A
Polio. : Acute Poliomyelitis
Food. : Food Poisoning
A: Adult
C: Children

Table 6-58 Disease Cases Related To Animal Vectors And Reservoirs Seen At Hospital Tengku Ampuan Afzan In 2021
YF DF DHF CKY Mal. Typ. Plag. Rab. *Total
Year Month
A C A C A C A C A C A C A C A C (All patients)
Jan 0 0 71 4 15 0 0 0 1 0 1 0 0 0 0 0 24, 935
Feb 0 0 59 3 15 0 0 0 2 0 0 0 0 0 0 0 24, 855
Mar 0 0 60 8 16 0 0 0 0 0 0 0 0 0 0 0 31, 450
Apr 0 0 64 5 15 0 0 0 0 0 0 0 0 0 0 0 28,733
May 0 0 53 5 10 0 0 0 0 0 0 0 0 0 0 0 22,446
June 0 0 51 3 10 0 0 0 0 0 0 0 0 0 0 0 24,356
2021
July 0 0 60 3 10 0 0 0 1 0 0 0 0 0 0 0 23,128
Aug 0 0 61 3 12 0 0 0 0 0 0 0 0 0 0 0 24,436
Sep 0 0 59 3 12 0 0 0 0 0 0 0 0 0 0 0 25,032
Oct 0 0 61 7 12 0 0 0 0 0 1 0 0 0 0 0 25,260
Nov 0 0 63 6 12 0 0 0 1 0 0 0 0 0 0 0 26,855
Dec 0 0 53 5 12 0 0 0 2 0 0 0 0 0 0 0 27185
Total 0 0 715 55 151 0 0 0 7 0 2 0 0 0 0 0 227,431
Note:
YF : Yellow Fever
DF : Dengue Fever
DHF : Dengue Haemorrhagic Fever
CKY : Chikungunya
Mal. : Malaria
Typ. : Typhus
Plag. : Plague
Rab. : Rabies
A: Adult
C: Children

Table 6-59 Skin Disease Cases Seen At Hospital Tengku Ampuan Afzan In 2021
Cutan. Cell. Derm. Psor. Urti. Dis. Eryth. Rad. *Total
Year Month
A C A C A C A C A C A C A C A C (All patients)
Jan 76 7 72 7 77 25 43 8 59 16 7 5 40 10 23 2 24, 935
Feb 50 11 52 8 75 24 39 7 48 9 7 3 33 10 0 2 24, 855
Mar 64 12 58 16 92 27 54 14 56 18 16 5 44 16 21 4 31, 450
Apr 55 9 56 16 77 25 46 7 52 23 11 5 36 19 0 8 28,733
May 60 9 42 17 47 19 32 7 37 22 17 4 28 19 28 8 22,446
June 59 7 42 10 56 14 28 5 39 10 22 4 28 6 25 6 24,356
2021
July 58 7 53 14 73 17 44 6 61 9 21 4 36 7 22 6 23,128
Aug 61 8 65 7 68 21 77 6 68 7 26 4 41 7 37 6 24,436
Sep 58 8 71 10 55 18 69 5 63 9 28 3 30 7 39 6 25,032
Oct 54 5 57 19 61 21 59 13 56 14 30 4 31 7 9 6 25,260
Nov 66 13 56 16 66 18 61 18 52 14 29 8 29 9 9 10 26,855
Dec 57 11 58 17 64 25 58 20 52 17 32 11 0 12 6 12 27185
Total 718 107 682 157 811 254 610 116 643 168 246 60 376 129 219 76 227,431
Note:
Cutan. : Cutaneous abscess/Furuncle & Carbuncle Urti. : Urticaria
Cell. : Cellulitis Dis. : Disorders of skin appendages
Derm. : Dermatitis and Eczema Eryth. : Erythemas
Psor. : Psoriasis Rad. : Radiodermatitis & other radiation-related disorders of the skin & subcutaneous tissue
A: Adult
C: Children

Table 6-60 Prevalence Rates of Selected Communicable Diseases In
District Of Kuantan In 2021
Malaysia
Disease No. of cases Prevalence rates in 2021
(2020)1
Waterborne and Foodborne Diseases
Cholera 0 0.0 0.35
Typhoid 0 0.0 0.20
Hepatitis A 0 0.0 0.14
Dysentery 17 2.90 0.48
Poliomyelitis 0 0.0 0
Food poisoning 314 53.6 28.93
Vectorborne and Zoonotic Diseases
Dengue fever 255 43.53 276.11
Dengue haemorrhagic fever 1 0.17 1.06
Chikungunya 1 0.17 7.98
Malaria 10 1.71 8.71
Filariasis 2 0.34 0.71
Typhus 0 0.00 0.03
Rabies 0 0.00 0.03
Leptospirosis 17 2.90 8.94
Melioidosis 27 4.61 -
COVID-19 40,013 6,830.49 360.25
Note: Population of District of Kuantan in 2021: 585,800

South
Terengganu China
Sea
Pahang !
Gebeng
!
Balok
Beserah
!
2
Gate
BPC
1
Gate
BPC
Ja la
nG
eb
en
g
1/
11
o
Elevation (m) Project No EJ 727
Project Site
<10 Produced by HMZ
Major Road Revision A
10 - 20
1:7,000 @ A4 size paper Minor Road
0 100 200 20 - 30
Elevation of the Project Site
Meters 30 - 40 FIGURE 6-1
Coordinate System:
GCS WGS 1984
>40
Map Units: Degree
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-1 Elevation)
Source: ERE Consulting Group (2022), SRTM (2010)
South
Terengganu China
Sea
Pahang !
Gebeng
!
Balok
Beserah
!
2 2
Gate Gate
BPC BPC
1 1
Gate Gate
BPC BPC
Geology Soil Series
o
LEGEND Rock Age Soil Series Date 20-06-2022
Project Site Project No EJ 727

Quaternary Peat Produced by HMZ
Major Road
Rengam-Bukit Temiang Revision A
1:7,000 @ A4 size paper Minor Road
0 100 200
Geological and Soil Map of the
Meters
Project Site FIGURE 6-2
Coordinate System:
GCS WGS 1984
Map Units: Degree
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-2 Geo n Soil)
Source: ERE Consulting Group (2022), Department of Agriculture Malaysia, Department of Minerals and Geoscience Malaysia
!
Cherating
Akademi Maritim
Sultan ahmad
Terengganu
5km Shah (AMSAS)
Gebeng
!
s
!
Balok Gebeng By p a s
Beserah
4km
!
Pahang South
China Sea
Alliance
Steel
Sdn Bhd
3km
Kg Gebeng
Sg
2km
Tanjung Rhu
. J
a
bo
r
1km
R
MU
ITI
N TA
PA
YA
Terengganu
RA
UH
LEB
S g . R a sa
u J ala
nG Kg Hulu Baluk alo k
eb Sg . B
en
g1 Kuantan Port
/ 11
Kg Selamat
Padang Serai Insititut Latihan
Perindustrian
Taman Putih Kuantan
Al
- M Jalan Perasing Sg. A i r
uk
taf Jab
i B or
illa -
hS Kg Berahi
ha
h
ak
Balok Perdana
gg
un
.T
a
ah
. Pak L
Sg
m
ng
La
r
Sg. P a
J abo Kg Seberang
an ab
or Balok
Ja l
Sg. Taman
Kg Balok
Desa Aspa
Bes alan
h
e ra
J
S g . Nyiur Kg Balok Baru
o
Date 10-05-2022
LEGEND Existing Land Use
Project No EJ XXX
Project Site Major Road Residential Transportation Produced by JJB
ICS Boundary Highway Commercial Infrastructure and Utilities Revision A
1:48,000 @ A3 size paper
0 1 2
Distance around Project Site State Boundary Industry Agriculture
Minor Road Institutional and Public Amenities Forest Existing Land Use within 5km
km FIGURE 6-3
Coordinate System: Open Space and Recreational Water Bodies
GCS WGS 1984
Degree Vacant Land
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-3 Existing Land Use)
Source: ERE Consulting Group (2022), Draft Rancangan Tempatan Daerah Kuantan 2035 (Penggantian), Maxar
!
Cherating
Akademi Maritim
Sultan ahmad
Terengganu
5km Shah (AMSAS)
Gebeng
!
s
!
Balok Gebeng By p a s
Beserah
4km
!
Pahang South
China Sea
Alliance
Steel
Sdn Bhd
3km
Kg Gebeng
Sg
Tanjung Rhu
2km
. J
a
bo
r
1km
R
MU
ITI
N TA
PA
YA
Terengganu
RA
UH
LEB
S g . R a sa
u J ala
nG Kg Hulu Baluk alo k
eb Sg . B
en Kuantan Port
g1
/ 11
Kg Selamat
Padang Serai Insititut Latihan
Perindustrian
Taman Putih Kuantan
Al
- M Jalan Perasing Sg. A i r
uk
taf Jab
i B or
illa -
hS Kg Berahi
ha
h
ak
Balok Perdana
gg
un
.T
a
ah
. Pak L
Sg
m
ng
La
r
Sg. P a
J abo Kg Seberang
an ab
or Balok
Ja l
Sg. Taman
Desa Aspa Kg Balok
Bes alan
h
e ra
J
S g . Nyiur Kg Balok Baru
o
Date 10-05-2022
LEGEND Future Land Use
Project No EJ XXX
Project Site Major Road Residential Transportation Produced by JJB
ICS Boundary Highway Commercial Infrastructure and Utilities Revision A
0 1 2
Distance around Project Site Proposed ECRL Alignment Industry Agriculture
Minor Road State Boundary Institutional and Public Amenities Forest Future Land Use within 5km
km FIGURE 6-4
Coordinate System: Open Space and Recreational Water Bodies
GCS WGS 1984
Degree
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-4 Future Land Use)
Source: ERE Consulting Group (2022), Draft Rancangan Tempatan Daerah Kuantan 2035 (Penggantian), Maxar
!
Cherating
n
Terengganu
A
ak S
Gebeng
g. B
!
!
a
Balok
gin
Leb
South
g
Beserah
Pahang !
China Sea
uhr
aya
Legend
K
PC
Major Roads
Por
r
Sg. Ula
Highways
t Li
nk
Proposed ECRL Alignment
Kg. Darat Proposed Future Development

Sg. Ular Land Use
Residential
Jal
Commercial
an
Sg Industry
Ku
.
AMSAS
Bt
ant
Institution & Public Facilities
Sg
. Panja
.M
an-
erah
ss Open Spaces & Recreations

ng Bypa
Ku
ng
Gebe Transportation
ala Infrastructure & Utilities
Ter
Alliance
KUANTAN
eng
Steel Waterbodies/ Rivers
PORT CITY
gan
Agriculture
u
Forest
Coast
Sg. B
alu
k
PROJECT SITE
u
Gebeng
Sg. Ras a Industrial
Park
Sg. B
. Air Put
alo
Sg ih
k
Kuantan Port
ak
gg
un
ng. Kg. Baluk

Pa Lah
.T
h
ra
k
Sg
Sg.
se
Pa
Be
n
la
Ja
r
iu
Ny
.
g
o
Date 10-05-2022
Legend
Project No EJ 727
Project Site Produced by HMZ
ICS Boundary Revision A
0 1 2 River
Proposed Future
km State Boundary
Development in Kuantan FIGURE 6-5
Coordinate System:
GCS WGS 1984
Map Units: Degree
Disclaimer: This map is produced solely for its intended purpose only. All reasonable care has been taken to ensure that the information presented here is accurate, subject to the availability and quality of data sources used.
There is however no guarantee that this map is free from errors or omissions. Its use for any other purposes is therefore at the sole risk of the user.
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-5 Proposed Future Development P)
Source: ERE Consulting Group (2022), Kuantan Port City (KPC) Draft Masterplan ,
Date 13-05-2022
Project No EJ 727
Produced by HMZ
Revision A
Climate Pattern at Kuantan

Meteorological Station FIGURE 6-6
(1985-2020)
Source: ERE Consulting Group Sdn Bhd, Jabatan Meteorologi Malaysia
Date 13-05-2022
Project No EJ 727
Produced by HMZ
Revision A
Kuantan Annual and Seasonal

Windrose Profile (1985-2020) FIGURE 6-7
Source: ERE Consulting Group Sdn Bhd, Jabatan Meteorologi Malaysia
Terengganu
Sg. C
nd
e
ur
in g
t
er a
Ch
g.
s
Sg. R a alok
au
Sg . B
yi u r
al age
Sg .
N
ok
. B in
Sg dra
ajid
to NP
kM
PK
o
Sg. T
1:336,000 1:7,000
o
LEGEND River Catchment Date 10-05-2022
Project Site Project No EJ 727

Sungai Baluk Produced by HMZ
River Sungai Cherating Revision A
@ A4 size paper State Boundary
River Catchment Surrounding
Project Site FIGURE 6-8
Coordinate System:
GCS WGS 1984
Map Units: Degree
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-8 River Catchment)
Source: ERE Consulting Group (2022), National Physical Plan 3
30 250 35 250 35 250 30 71
30
A800 B800 C800

D800
150
30
A700 B700 C700 D700

150
30
A600 B600 C600

D600
150
E=651.000
E=936.000
30
N=1704.000 9.10 9.10 N=1704.000 N=1704.000 9.10

6th STREET 7.98
CULVERT TEMPORARY DRAIN 1:600
7.95
7.98 8.38
8.01 C519 HR-PIB Flare Gate barrier N=1690.000

8.47
E=920.000
C
C
C500 D500
DOOR
FAP
TABLE
NOTE-1
Glass / Wooden
Partition
C575
DOOR
Server
Generator Control
DCS
Burner Control
Turbine Control
Marshalling
Future Space
Future Space
DOOR
LDB01
C517 BF3-Storage
N=1650.00
FUTURE
DUMMY
FUTURE
FUTURE
FUTURE
DUMMY
FUTURE
N=1652.600
B500
O/G
O/G
DUMMY
O/G
I/C 2
I/C 2
E=9361.000
11kV SWITCHGEAR
DUMMY
BPT
E=691.900
E=763.800
B/C
E=651.000
AVENUE C
BPT
DUMMY
ENTRANCE GATE
I/C 1
I/C 1
O/G
C512 SR/RR
DUMMY
O/G
O/G
FUTURE
BATTERY ROOM
FUTURE
DUMMY
FUTURE
FUTURE
FUTURE
9.35
Q
C515 Production Building
A500
150
A500 749.6728
25000.0000
500.0000
N
C574
C514 FFP
Gate barrier
N=1600.00
CULVERT
5500.0000 5500.0000 8000.0000
7499.5667
N=1600.600
E
G
T
A
S
S
T
1
E
G E
A
G
T
A S
T
S D
N
D 3
R
Sluice Gate
E
A
G
S
T
T
1
S
4999.8500
E
G E
G
T
A T
A
S S
D
N
D 3
R
E
A
G
S
T
TK3503
T
S
1
4999.8500
E E
A
G T
A
G
T
S S
D 3
R
D
2
N
TK3515 TK3535
4050.1012
3100.3018
TK3530
3399.5977
2175.0965
C572
C573
5149.6997
C510
2300.0000
Tank Farm
6000.0000
TK3526 TK3546 TK3504
3000.0000
N=1550.00
E=670.000
E=775.000
10600.0000
8699.5967
8800.2287 4999.8637
7.83 C505 Truck Loading

7.94
E=651.000
E=936.000
7.74
30
7.71
CULVERT CULVERT
N=1524.000 8.94 N=1524.000 N=1524.000 8.94

5th STREET
7.60
7.59
8.34 7.98
N=1500.00
D400
C400
B400
150
A400
DOMESTIC WATER TANK

2" OUTLET
2" INLET
SUMP PIT
CHILLER/
EXISTING ROAD
HEATER 1
WAREHOUSE
CENTRAL
AREA
A410
CHILLER/
HEATER
CHILLER/
HEATER 2
Premix Surface
68.2 M X 16.2 M
WAY Drain
WALK g Main
Existin
1 2 3 4 5 6 7 8 9 10
CAR PARK
30
Existing Main Drain

WALKWAY
EXISTING ROAD
A300
LOGISTICS
AREA
B300
A300 C300
150
Maintenance
7x15m
TBPR
LOGISTICS D300
30
FALL 1 : 500
M.S STANCHION
DP TO ENGR'S DETAILS
1M x 1M CONC. SUMP
EAVE ABOVE
DESTILLATION
COLUMN
STATIC F611
LOAD : 1.5 TON
D = 273í
H = 9720 DEHYDRATOR /GUARD BED UNIT
F361
EL EL
STATIC STATIC
LOAD : 2 TON LOAD : 2 TON
í375 H = 3000 H = 3260
F371 DC
+0.50m
150í
REFIGERATION UNIT STAINLESS STEEL
DRAIN PIPE F641B
F381 CAST INTO PLINTH
F611
REBOILER UNIT STATIC
STATIC LOAD : 10 TON
CO2 LOAD : 1 TON H = 9000 NH3 COMPRESSORCO2
H = 1600 STATIC
LOAD : 5 TON
H = 2000
F335
F641A
F410A
F611
C200
EL EL
REINFORCED
CONCRETE FLOOR
TO ENGR'S DETAILS
DP
A200 D200
WAREHOUSE
150
A245
MOTOR
WAREHOUSE
AA/AE OXO/SYNGAS
TVE JLM
EXIST. TEMPORARY BUILDING EXIST. TEMPORARY BUILDING
FEMALE
UPC
30
A100
ADMIN.
150
Type526 1D2
150#-600#
150#
N4
N1
L1
V1
N3 D1 B
N2
MH
L2
B100
5 E
12 FIN T
O
I KK DUC
N O
PR E NA L
O NT ONA
K SI
NA
Project No EJ 727
N Storm Water Drainage Produced By HMZ
Revision -
PKNP Drain Member of the Aurecon Group
0 100 200 Retention Pond Drainage System Within the

Integrated Chemical Site (ICS) FIGURE 6-9
Meter
\\192.168.1.13\ere data\ERE Projects\EJ 727 2- Ethylehaxanoic Acid BASF\Drawings\2. EIA\Fig 6-9 Drainage ICS.dwg
South
Terengganu China
Sea
Pahang !
Gebeng
!
s
as Balok
yp
gB
Beserah
en
!
b
Ge
S g. R
asau
Ja
l an Ge
beng 1
/11
Kg Hulu Baluk .B a lok
Sg
o
Date 24-05-2022
LEGEND Flood Prone Area Average Occurrence
Project No EJ 727
ICS Boundary 100 Years Produced by HMZ
Project_Site Revision A
0 100 200 400 600
Water Body
Major Road
Flood Prone Area
Meters FIGURE 6-10
Coordinate System: Minor Road
GCS WGS 1984
Map Units: Degree State Boundary
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-10 Flood Prone)
Source: ERE Consulting Group (2022), DID (2001)
s s A4
pa
By
ng
be
Ge
Kg Gebeng
Jala
Tanjung Rhu
n Ge
beng
N2
1/11
PROJECT
SITE N3 Pahang
g. R as N1
W7
au
W1 N2
W5
Kg Hulu Baluk alo k
W6 Sg. B
W2 Kuantan Port
W3 Kg Selamat
Padang Serai
Terengganu Sg.
ih
A ir Pu t
Taman Insititut Latihan
A1
Perasing Perindustrian
Al - J Kuantan
Mu a la n
kta Ja W4 A3 Kg Berahi
fi B
PANTA I T
LEBU HR UR
bo ah S
Balok Perdana
a
k
ng .
ga
r- h
Tu Sg
ill
La
Pang.
g. Lah
or
ak A2
ab
S
nJ
ah
Kg Seberang
AYA
P
IM
a
Jal o
r
Ja
b Balok
Sg
.
o
Date 09-06-2022
LEGEND Baseline Sampling Location
Project No EJ 727
Project Site Water Quality Produced by HMZ
ICS Boundary Air Quality Revision A
0 0.5 1
Water Body Noise Level
Major Road
Baseline Sampling Locations
km
for Water Quality, Air Quality FIGURE 6-11
GCS WGS 1984
Map Units: Degree
and Noise Levels
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-11 Baseline)
Source: ERE Consulting Group (2022), Earthstar Geographics, Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community
Pahang
Terengganu Gebeng
!
!
Balok
South
!
Beserah China Sea
PN2 PA2
PN3 PA3
PN1 PA1
PN4
PW3
PW5
Jalan G
ebeng 1 PW6
/11
PW4
Kg Hulu Baluk
Sg
Ra
.
s au
PW1
Existing Monitoring Station

Air Quality
PW2
Water Quality
Noise Level
o
08-06-2022
LEGEND Date
Project No EJ 727
Project Site Produced by HMZ
ICS Boundary Revision A
0 125 250
Water Body
Major Road Existing Monitoring Stations
Meters FIGURE 6-12
GCS WGS 1984
Map Units: Degree
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-12 Existing Monitoring Stn)
Source: ERE Consulting Group (2022), Maxar
5km
!
Cherating
I6 Gebe ng
Pahang B pass
y
Terengganu
4km South
China Sea
Al-Muk
Gebeng
!
Jalan illah Shah

!
Alliance Steel Sdn Bhd Balok
3km
ta fi B
Beserah
Kg Gebeng !
Jabor -
FELDA
R
IMU
Neram Satu Pahang
Jala
T
2km Tanjung Rhu
TAI
n Ge
AN
Sg. Jabor
beng
AP
1km
AY
1/11
Label Name
HR
BU
R1 Taman Balok Perdana

5KM
LE
R2 Taman Balok Makmur

au k
R3 Kg. Berahi Terengganu S g . Ra s Kg Hulu Baluk Ba l
o
Sg. Kuantan Port
R4 Perumahan Balok Baru
R5 Kg. Seberang Balok
R9
R6 Kg. Balok Baru
Pu tih
Padang Serai Kg Selamat
R7 Taman Balok Pelangi Taman Air
au
Perasing Sg. I1 R2
. Ri
R8 Kg. Balok
Sg I2 R3
R9 Kg. Selamat
ma
a I3
L
Label Name R1
I4
or
ab
I5 R4
I1 n JKuantan
Institusi Latihan Perindustrian
la bo
R5
r
I2 Sekolah Kebangsaan Balok Baru

Ja
. J
a
Sg Kg Seberang Balok
Taman
I3 Sekolah Kebangsaan Pelabuhan Desa Aspa
I4 Sekolah Menengah Kebangsaan Pelabuhan R7 R6
R8
I5 Gebeng Police Station
I6 Akademi Maritim Sultan Ahmad Shah (AMSAS) S g . Nyiu r Kg Balok Baru
o
Date 08-06-2022
LEGEND Land Use within 5km
Project No EJ 727
Project Site Residentials Produced by HMZ
ICS Boundary Institutions Revision A
0 0.5 1 2
Distance around Project Site
Water Body
Residential Areas, Institutions
km
and Public Amenities Within FIGURE 6-13
Coordinate System: Major Road
GCS WGS 1984
Map Units: Degree Minor Road
5km of the Project Site
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 6-13 Land Use within 5km)
Source: ERE Consulting Group (2022), Earthstar Geographics
07 EVALUATION OF IMPACTS
Section 7
EVALUATION OF IMPACTS
SECTION 7 : EVALUATION OF IMPACTS
7.1 INTRODUCTION
This Section identifies the potential significant impacts and describes the scope and
methodology for impact assessment during pre-construction, construction, and
operational phases of the Project, including project abandonment. The impacts will
be assessed in terms of magnitude, prevalence, duration and frequency of occurrence
whichever is applicable, and their consequences. These potential impacts are
categorized under these thematic headings, that fall within the core functional areas
of the Department of Environment (DOE):
i) Ambient air quality

ii) Water quality
iii) Waste generation
iv) Noise generation
v) Greenhouse gas emission
vi) Socio-Economy
vii) Risk
viii) Health impact
The EIA study for the proposed Project is to be undertaken, taking into account of
the following guidelines published by the Department of Environment and other
agencies:
• A Handbook for Environmental Impact Assessment Guidelines (DOE, 4th

Edition, 2007)
• Environmental Impact Assessment (EIA) Guidelines in Malaysia (DOE, 19th
July 2016)
• Environmental Impact Assessment (EIA) Guidelines for Industrial Projects
(DOE, 2007)
• Environmental Impact Assessment (EIA) Guidelines for Petrochemical
Industries (DOE, 2018)
The findings from the impact evaluation and assessment are summarized in a matrix
format. The matrix relates the type and extent of impact between the various project
activities and the physical, biological, and human components of the environment.

7.2 EVALUATION METHODOLOGY
The assessment of potential impacts has been carried out through analyzing different
Project activities and predicting possible impacts to the environment and its nearby
sensitive receptors. Each impact resulting from the Project will be assessed based on
both the magnitude and sensitivity of the receptor.
7.2.1 Receptor Sensitivity
Receptor sensitivity is the susceptibility degree of the receptor to the impact. It is

assessed based on the vulnerability of the receptor, where the receptor is more
vulnerable when it is more likely to experience significant impacts from Project
activities.
Receptor value takes into consideration its quality and its importance as represented,
i.e., by its conservation status, its cultural importance and / or its economic value.
Receptor sensitivity is assessed as negligible, low, moderate, and high-ranking
criteria.
7.2.2 Impact Significance
Impact magnitude and receptor sensitivity were used to evaluate impact significance
according to the impact assessment matrix in Table 7-1.
Table 7-1 Impact Significance Matrix

Receptor Sensitivity (Vulnerability and Value)
Negligible Low Moderate High
Not
Not Not Not
Negligible significant
significant significant significant
Impact Magnitude / Low1
(Extent, Frequency, Not Low /
Low Low Moderate
Reversibility, significant Moderate2
Duration) Not Low /
Moderate Moderate High
significant Moderate2
High Low Moderate High High
Note:
Significant impact which is likely to disrupt the function and value of the resource /
High receptor and may have broader systemic consequences. These impacts are a priority
for mitigation in order to avoid or reduce the significance of the impact
Significant impact which is likely to be noticeable and result in lasting changes to
baseline conditions, which may cause hardship to or degradation of the resource /
Moderate
receptor, although the overall function and value of the resource / receptor is not
disrupted.
Detectable but not significant. These impacts are expected to have noticeable changes
Low beyond natural variation, but are not expected to cause hardship, degradation, or
impair the function and value of the resource or receptor.

Any impacts are expected to be indistinguishable from the baseline or within the
Not
natural level of variation. These impacts do not require mitigation and are not a
significant
concern of the decision-making process
1. Allowance to decide if impact significance is Not significant or Low
2. Allowance to decide if impact significance is Low or Moderate
Source: South Stream Offshore Pipeline, 2014
Findings from the impact evaluation and assessment are summarized in a matrix
format show in Table 7-2. The matrix relates the type and extent of impact between
the various project activities and the physical, biological and human components of
the environment.
Mitigation measures for the related impacts identified will then be recommended in
Section 8.

Table 7-2 Summary of Impacts
Environmental Study Boundaries / Sensitive Impact
No. Potential Impacts
Elements Receptors Magnitude
Construction Phase
Sensitive receptors within 2km • Fugitive dust generation when particulates are lifted into the air from movement of Not
1 Air Quality
from the Project Site construction vehicles and minor earthmoving activities significant
Sensitive receptors within 2km • Temporary increase in ambient noise levels due to construction works and increment Not
2 Noise
from the Project Site of vehicular movement significant
• River water pollution due to surface runoff from exposed land during construction,
such as foundation works, piling and minimal earthwork activities
• Tributaries of Sg. Balok
3 Water Quality • Accidental discharge or spillage of petroleum products and scheduled wastes causing Low
• Existing drainage system
contamination of waterways
• Sewage and sullage generation from temporary toilet facilities
Solid Wastes
• Collection of water by wastes, which will become breeding grounds for pests which
transmit diseases
• Illegal open burning will cause air pollution
Waste • Tributaries of Sg. Balok
4 • Debris may potentially clog drains, causing flash floods during rainy seasons Low
Management • Existing drainage system
Scheduled Wastes
• Accidental spillage or leakages will deteriorate water quality of nearest river
• Illegal burning may expose nearby receptors to hazardous pollutants
Negative Impacts
• Dust and air pollution from construction activities
• Traffic congestion due to construction work
Sensitive receptors within 5km • Public safety, i.e., movement of trucks and construction machinery
5 Socio-Economic Low
from the Project Site • Social unrest resulting from incoming foreign workers
• Disturbance to routine daily travels like to work and school

Positive Impacts
• Generate employment opportunities for local people
• Increase the number of highly-skilled workers
• Increase income to surrounding businesses and services including house rental
• Increasing the value of real estate
• Addition and improvement of infrastructure
• Encourage the provision of public services such as schools, clinics, recreational areas
and others
Operation Phase
• Thermal treatment of off gases containing mainly oxygen and hydrogen will be
Sensitive receptors within 5km
1 Air Quality converted to combustion gases like nitrogen oxides, which can affect the health of Low
from the Project Site
nearby population
Greenhouse • Emissions of greenhouse gases from combustion of fossil fuel (natural gas) for Not
2 -
Gas Emission generation of steam significant
Sensitive receptors within 5km Not
3 Noise • Increase in ambient noise levels from processing equipment
from the Project Site significant
• Tributaries of Sg. Balok • Wastewater generation from the existing WWTP and accidental leakage or spillages
4 Water Quality Low
• Existing drainage system from scheduled wastes will cause deterioration of nearby waterways
• Generation of domestic waste from the office
• Generation of spent catalyst from the production process.
Waste • Tributaries of Sg. Balok • Addition of wastewater sludge generation from the existing wastewater treatment
5 Low
Management • Existing drainage system system.
• Generation of scheduled waste from shared laboratory, shared office, and
maintenance of equipment and machineries.
• Risk of fire, explosion or release of dangerous substances such as 2-ethylhexanoic
Sensitive receptors within 5km
6 Risk acid, 2-ethylhexanal, 2-ethylhexanol, hydrogen, n-butanal, heptyl formate and Low
from the Project Site
undecanol

• Health impacts (mainly secondary impacts) upon the human community that
emanate from primary impacts upon the physical (air, water, and soil), biological
Health Impact Sensitive receptors within 5km
7 (animals and plants) and social environment Low
Assessment from the Project Site
• Main health impacts emanating from human exposure to air pollutants through direct
inhalation
Negative Impacts
• Air pollution from plant
• Odour pollution from plant
• Water pollution due to discharge of liquid waste into rivers
• Fire risk arising from plant operation
• Noise from plant operation
• Traffic congestion from the movement of trucks in and out of the factory
• Public safety from truck movement
Sensitive receptors within 5km • Social unrest or dissatisfaction of the population due to the presence of foreign
from the Project Site workers
• Waste / garbage illegally disposed from plant
Positive Impacts
• Increase income to surrounding businesses and services including house rental
• Increasing the value of real estate
• Addition and improvement of infrastructure
• Encourage the provision of public services such as schools, clinics, recreational areas
and others

7.3 PRE-CONSTRUCTION PHASE
7.3.1 Project Planning and Site Investigation
The main activities during the planning phase are the feasibility studies and design,
development of the layout plan, field investigation and environmental baseline
monitoring. These activities have only minimal environmental impacts at the Project
site and its surrounding areas.
7.4 CONSTRUCTION PHASE
7.4.1 Air Quality
7.4.1.1 Potential Impact
There are several types of air emissions that could potentially affect the ambient air
quality surrounding the Project Site during the construction phase, such as:
a) Fugitive dust, including PM10, generated from construction activities such as

movement of vehicles over unpaved surfaces and stockpiling;
b) Dust and gaseous emissions of PM10, PM2.5, CO, NO2 and SO2 from the
combustion of fuel from vehicles, generators and other equipment.
7.4.1.2 Assessment
The impact of fugitive dust depends on the quantity and drift potential of the dust
particles emitted into the atmosphere and the location of the nearby sensitive
receptors. In general, larger and heavier dust particles are less likely to be carried far
by the wind. At a wind speed of 4.44 m/s, particles larger than about 100μm are
likely to settle out within 6 to 9 m from the point of emission while particles that are
30μm to 100μm in diameter are likely to undergo impeded settling. These smaller
particles, depending upon the extent of atmospheric turbulence, are likely to settle
within 100m to 200m from the source.
Fugitive dust emissions generated from the Project site are expected not to travel far
enough to cause any adverse impacts or nuisance to the surrounding air sensitive
receptors due to the following reasons:

• Average representative wind speed recorded in Kuantan Meteorological
Station is only about 1.6 m/s. This wind speed is relatively much weaker to
carry dust particles to a large distance.
• Minimum quantity of fugitive dust particles emitted into the atmosphere due
to minimal earthwork activities whereby soil and foundation improvement
works are anticipated especially at areas to be loaded with plant’s component.
• Sensitive receptors are located quite a distance away from the Project site:
o Institut Latihan Perindustrian (ILP) Kuantan (2.3 km southeast of the
Project site);
o Taman Balok Perdana (2.8 km to the south of the Project site); and
o Taman Balok Makmur (2.8 km southeast of the Project site).
Therefore, the impact of fugitive dust is expected to be localized and not significant
to the nearby air sensitive receptors.
7.4.2 Noise Pollution
The construction activities of this Project will have negligible to little noise impact to
the receptors surrounding the proposed Project because it is located within the
existing ICS occupied by the Project Proponent, which is located within a designated
industrial area, known as Gebeng Industrial Estate (GIE). The residential areas
identified surrounding the proposed Project is located more than 2.8 km away
(Taman Balok Perdana, Kompleks Perumahan TLDM, Taman Balok Makmur).
Therefore, the result of noise assessment will be compared with the boundary of
existing ICS.
The activities involved at Project site which may contribute to increase of noise
include site levelling works and piling and foundation works.
7.4.2.2 Assessment
The sound pressure levels were predicted using procedures from the ISO 9613-2:
Acoustic – Attenuation of sound during propagation outdoors – Part 2: General
Method of Calculation. CadnaA, a software package developed by Datakustik
GmbH which implements the procedures, was used to predict the noise levels.
Expected noise sources and their respective sound power levels were extracted from
Annex C of BS 5228-1:2009+A1:2014 Code of Practice for Noise and Vibration Control
on Construction and Open Sites (Part 1: Noise).

The predicted noise level from the proposed Project will be compared against the
boundary noise level of the ICS as the residential areas which is located more than
2.8 km away. Table 7-3 shows the location of existing noise monitoring station which
will be compared against the predicted noise level from the proposed Project.
Table 7-3 Location of Existing Noise Monitoring Station

Nearest Distance
Project Activities Location Description
(from Project Site) (km)
Northwestern
boundary of 0.59 km north from the
Industrial
the ICS-A300 site (Northwest)
Construction work include Blockfield
piling and foundation works Southeastern
of the ICS- 0.35 km from the site
Industrial
D600 (Southeast)
Blockfield
Worst case scenario is considered where the assessment is carried out based on noise
generated from heavy machineries without any mitigation measures i.e., temporary
hoarding as noise barriers.
Assessment Results
Assumptions used in this assessment are as follows:
• The noise attenuation assumed flat surface within the study area.
• Quantity of different types of machineries and equipment are assumed based
on understanding from the construction method statement provided and
related literature;
• Duration of machinery usage is assumed to operate consistently during
daytime; and
• The construction activity that generates highest level of noise is modelled to
predict worst case scenario.

Table 7-4 Sound Power Levels of Heavy Machinery and Equipment on Project Site
Sound
Total Sound Power
Machinery/ Power Estimated Total Sound Power Level
Site Activity Sub Activity Level of Sub Activity
Equipment Level Quantity (2) of Equipment (dBA)
(dBA)
(dBA)(1)
Motor Grader (168 kW) 111.0 1 111.0
Site Levelling 113.5
Tracked loader (97 kW) 110.0 1 110.0
Construction Jack-in Piling 98.0 2 101.0
of Project Piling and Foundation Crane 99.0 2 102.0
113.6
Works Tracked loader (97 kW) 110.0 2 113.0
Diesel Generator Set 93.0 1 93.0
Notes:
1. Source: BS 5228-1:2009+A1:2014 Code of Practice for Noise and Vibration Control on Construction and Open Sites – Part 1: Noise, 2008
2. Assumed based on nature of activity and type of works expected to be executed on-site.
From Table 7-4, the machinery/equipment which will be used during piling and foundation works are modelled using CadnaA software to
predict noise.

The predicted noise level at the nearest noise sensitive receptors is shown in Table
7-5 below:
Table 7-5 Predicted Noise Levels and Anticipated Community Response

Development Phase Construction
Northwestern boundary of Southeastern of the ICS-
Distance the ICS-A300 Blockfield (0.59 D600 Blockfield (0.35
km) km)
Noisy Site Activity Piling and Foundation Works
Existing Noise Level (L10), 59.3 63.6
Daytime (dBA) 1 (N1 station) (N3 station)
Predicted Noise Level,
Daytime from CadnaA 45.3 51.4
(dBA)2
Cumulative Noise Level
59.5 63.9
(dBA)
Maximum Permissible
Sound Level, Daytime3 75.0 75.0
(dBA)
Compliance to Max.
Within limit Within limit
Permissible Sound Level
Estimated Incremental
Noise Level, Daytime 0 0
(dBA)
Anticipated Community
Negligible Negligible
Response4
Environmental Impact4 - -
Note:
1. Refer to Section 6.7.2.2. Source: Environmental Science (M) Sdn Bhd., 2021
2. Refer to Chart 7-1, Noise Modelling Contour of the Project Boundary During Construction Stage
3. Guidelines for Environmental Noise Limits and Control Third Edition, 2019 (Reprint 2021) - Schedule
6: Maximum Permissible Sound Level (L10) of Construction, Maintenance and Demolition Work by
Receiving Land Use
4. Guidelines for Environmental Noise Limits and Control Third Edition, 2019 (Reprint 2021) - Annex
C Table C-1: Human Perception of Sound and Likely Environmental Impact
From Table 7-5 and Chart 7-1, the northwestern and southeastern boundary of ICS
which takes into account the existing noise from the operation of ICS and predicted
noise level during construction at the proposed Project are also below the maximum
permissible sound level of 75.0 dBA. No incremental noise from the construction of
Project towards the existing noise level at northwestern and southeastern boundary
of ICS. The anticipated community response is negligible. Therefore, no significant
impact is expected from the proposed Project during construction of the Project.

Chart 7-1 Noise Modelling Contour of the Project Boundary During
Construction Stage
Legend:
Project Site
ICS Boundary
45.3 Road
Receiver
51.4 (N3)
45.3 (N1)
7.4.3 Water Quality
Sewage and Sullage from Toilet Facilities
One of the potential water pollution issues that may arise during the construction
phase is sewage generated from toilets established on-site as well as sullage from the
proposed canteen. Direct discharge of untreated sewage and sullage into the
surrounding waters will lead to increased levels of nutrients and organic matter in
receiving waterways. This will lead to decreased levels of Dissolved Oxygen (DO),
and increase in Biochemical Oxygen Demand (BOD), Chemical Oxygen Demand
(COD) and Ammoniacal Nitrogen (NH3-N) leading to river water quality
degradation. The discharge of untreated sewage and sullage will potentially cause
Pantai Balok (located approximately 6 km downstream) to be unsuitable for
recreational activities, especially involving body contact.
Discharge or Spillage of Petroleum Products and Scheduled Waste
Spillage and/or leakage of fuel, oils, lubricants, or scheduled wastes either through
improper storage or improper maintenance of machinery/equipment can cause oil
& grease and chemical contamination of receiving waterways.

Soil Contamination
When not properly handled and/or disposed, oil and hazardous waste could leach
into the ground, causing soil and ground water contamination. Other impacts
include surface water contamination in the event of heavy rainfall, whereby
contaminated soil is carried and deposited in surrounding waterways.
Some of the potential sources of soil contamination include:

• Discharge or spillage of scheduled waste or hazardous substance such as
petroleum products;
• Improper storage of petroleum products, chemicals, and chemical; and
• Leachate originating from the waste dumped on site.
Retention Pond Discharge
Soil erosion and sedimentation will be the main cause of water pollution during the
construction stage. Construction activities such as foundation works, piling and
exposed surfaces may increase surface runoff into nearby waterways causing an
increase of total suspended solid (TSS) levels.
However, land clearing and earthwork activities for this project will be minimal as
the platform for the Project has been established previously. Runoff from the
construction site will be channeled into a silt trap prior to discharge into the
stormwater drainage system which will eventually discharge into the retention pond
located within the ICS complex. The retention pond will then discharge into the
Perbadanan Kemajuan Negeri Pahang (PKNP) drainage which flows into Sg. Balok.
TSS is identified as the main pollutant contributing source during construction stage.
7.4.3.2 Assessment
Impact Assessment
The impact of TSS discharge from the retention pond to the water quality of Sungai
Balok was assessed using the Mixing Model. The discharge flow during construction
stage is illustrated in Chart 7-2. The schematics of the mixing model is shown in
Chart 7-3.

Chart 7-2 Diagram on Discharge Flow from Project Site During
Construction Stage
Chart 7-3 Schematic Diagram of Mixing Model
The expected concentration (Cf) of pollutants in the receiving waterway after

receiving discharge from the retention pond was calculated as:
𝑄0 𝐶0 + 𝑄1 𝐶1 = 𝑄𝑓 𝐶𝑓
𝑄0 𝐶0 + 𝑄1 𝐶1
𝐶𝑓 =
𝑄𝑓
Where,
C0 = Concentration upstream Q0 = Flow rate upstream (m3/s)

(mg/L)
C1 = Concentration of discharge Q1 = Flow rate of discharge from

from Project Site (mg/L) Project Site (m3/s)
Cf = Concentration after mixing Qf = Flow rate after mixing (m3/s)

(mg/L)
The mixing model assessment was conducted for the following scenarios:
• Scenario 1 (with mitigation measures)

Retention pond
The maximum sediment contribution from the Project is 50 mg/L with
implementation of mitigation measures.
• Scenario 2 (worst case with no mitigation measures)

Retention pond
The sediment contribution from the Project is 500 mg/L with no mitigation
measures at peak discharge of 2-year return period.
For both scenarios, the following assumptions and criteria were applied:
• TSS discharge from the construction site is from final discharge point (i.e. after
passing though all sediment control measures) and into the retention pond
within ICS complex.
• Discharge from the retention pond and the receiving waterways (PKNP drainage,
and Sg. Balok) are assumed to be completely mixed at confluence points.
• Event mean concentration (EMC) values are used as baseline TSS level for
Scenario 2.
• Other point/diffuse sources along and leading into the receiving water bodies
are not considered.
• TSS concentration of 500 mg/L was assumed as the retention pond’s worst-case
scenario.
The inputs for the mixing model for the impact assessment from retention pond
during construction phase is described in Table 7-6 below.

Table 7-6 Mixing Model Input for TSS Assessment
Upstream
Upstream Sediment Sediment
Receiving Flow
Location Scenario Concentration, Discharge, Concentration,
Waterway Rate, Q0
C0 (mg/L) Q1 (m3/s) C1 (mg/L)
(m3/s)
Retention 1 0.008 16 0.021 50
W6
Pond 2 0.936 309 0.001 500
PKNP 1 3.267 3 0.046 22
W2
Drainage 2 10.226 158 13.326 191
1 3.606 5 1.500 23
W3 Sg. Balok
2 56.554 137 35.127 157
1 5.106 10 1.500 106
W4 Sg. Balok
2 91.680 145 35.339 184
Assessment Results
The mixing model results in Table 7-7 show the changes in TSS levels for both
Scenario 1 and 2. The discharge from the sediment basin will enter the retention pond
prior to discharge into the PKNP drainage. The retention pond is part of the
Integrated Chemical Site (ICS) and will receive surface runoff and stormwater
discharge from the entire complex.
In Scenario 1, TSS levels in the retention pond (W6) is expected to increase from 16
mg/L to 41 mg/L. However, after settlement, the discharge from the retention pond
to the PKNP drainage (W2) is predicted to have minimal impact and baseline levels
can be maintained.
From the retention pond discharge, the TSS level at PKNP drainage (W2) and Sg.
Balok (W3) is predicted to remain in Class I. TSS level at Sg Balok (W4) is predicted
to change from 106 mg/L (Class III) to 32 mg/L (Class IIA/B)
In Scenario 2, the baseline TSS level at Retention Pond (W6) is predicted to slightly
increase from 309 mg/L to 310 mg/L. The TSS level at PKNP Drainage (W2) and Sg.
Balok (W4) is predicted to remain in Class IV. TSS level in Sg. Balok (W3) is expected
to change to Class III from Class IV. The probability of Scenario 2 to occur is minimal
as Project Proponent will implement proper mitigation measures.
Table 7-7 Predicted TSS Level at PKNP Drainage and Sg. Balok Under
Scenario 1 and Scenario 2
Affected Concentration (mg/L) Changes in Water
Location
Waterway Baseline Predicted Change Quality
Scenario 1: Maximum sediment contribution from Project is 50 mg/L with
implementation of mitigation measures.
TSS levels increase in
Retention
W6 16 41 + 25 retention pond at point
Pond
of mixing

Affected Concentration (mg/L) Changes in Water
Location
Waterway Baseline Predicted Change Quality
TSS level does not
PKNP
W2 22 4 - 18 exceed baseline
Drainage
conditions
W3 23 10 - 12 TSS level does not
Sg. Balok exceed baseline
W4 106 32 - 74 conditions
Scenario 2: Sediment contribution from Project is 500 mg/L without implementation of
mitigation measures at peak discharge of 2-year return period.
Retention TSS level in retention
W6 309 310 +1
Pond pond increases.
PKNP
W2 191 176 - 14 for TSS remains within
Drainage
Class IV
TSS level does not
W3 157 145 - 12 exceed baseline
conditions.
Sg. Balok
W4 184 156 - 28 for TSS remains in Class
IV
Note: Baseline sediment concentration was estimated using Event Mean Concentration (EMC)
for Scenario 2.
The impact from construction activities, sewage and sullage, and hazardous waste is
expected to be minimal, and the impacts can be managed with implementation of
mitigation measures (refer Section 8.3.3).
7.4.4 Waste Management
7.4.4.1 Solid Waste
Potential Impacts
Based on the site activities during construction stage, the majority types of solid
wastes that are expected to be generated are construction wastes. Meanwhile, some
domestic wastes will also be generated from site. Apart from that, some excess spoil
from foundation and infrastructure works are expected but will be very minimal
since the site has already been cleared.
Mismanagement of solid wastes can potentially cause problems as listed in Table 7-

8.

Table 7-8 Potential Impacts from Solid Waste Mismanagement
Potential Wastes
Potential Impacts
Generated
General
• May collect water which will become breeding grounds for
construction
pests which will transmit diseases;
wastes (scrap
• Illegal open burning will cause air pollution;
metals, packaging
• Debris may potentially clog drains, causing flash floods
wastes, concrete
during rainy seasons;
waste,
• Rusty scrap metals will cause inflammation to the body
construction
resulting to wounds or even cause tetanus to the victims.
materials wastes)
• May become breeding grounds for dengue mosquitoes if
waste collects stagnant water;
• Improper waste management may attract insects or rodent
vectors which can spread disease to the workers due to poor
sanitation environment;
• Decomposition of biodegradable domestic wastes, i.e., food
Domestic wastes wastes, will contribute to methane emissions and cause
seepage of organic materials into the soil and eventually to
the nearby waterways, causing an increase in BOD;
• Illegal open burning will cause air pollution;
• Causes unsightly view to nearby receptors; and
• Foul smell from site to the nearby receptors, causing
nuisance.
Assessment
The estimated amount of construction wastes generation is done based on area of the
Project site, and the domestic wastes are estimated based on the expected number of
staff during construction stage (Table 7-9).
Table 7-9 Estimated Quantities of Solid Wastes During Construction

Stage
Estimated
Potential Solid Wastes Waste Generation
Factor Quantity
Generated Rate
(kg/day)
General construction waste 880 m2 18 kg/m2(1) 27.8(4)
Domestic wastes 250 pax(2) 0.41 kg/capita/day(3) 102.5
Total 130.3
Note:
1. Source: Haritharan Maniam, 2018
2. Estimated maximum number of staff during construction stage.
3. Source: JPSPN, 2012
4. Based on total construction period of 19 months, i.e., 570 days.
The total solid wastes generation is estimated to be 130.3 kg/day, where it will
mostly be comprised of domestic wastes generated by staff (78.7%). This number,

however, is expected to only reflect the quantity of domestic wastes generated during
the peak construction period, when the manpower is at maximum.
7.4.4.2 Scheduled Wastes
Potential Impacts
Scheduled wastes generated during construction period is mainly from machinery

maintenance works. Improper scheduled wastes management will cause impacts to
the soil and groundwater if there is any seepage or leakage. This will in turn
deteriorate the water quality of the nearest river, Sg. Balok, which will eventually
flow into South China Sea.
Besides that, illegal burning of scheduled wastes may expose nearby receptors to
hazardous pollutants, and these will affect their health. Health issues may either be
acute or chronic depending on the types of pollutants, nature of pollutants, and
duration of exposure.
Assessment
A list of scheduled wastes that will be generated during construction phase and their
respective codes can be referred in Table 7-10.
Table 7-10 Source and Type of Scheduled Wastes Generation

SW Code Type of Scheduled Wastes Source
SW 305 Spent lubricating oil Maintenance and machinery
SW 306 Spent hydraulic oil Maintenance and machinery
Contamination from
SW 307 Spent mineral oil-water emulsion
machinery maintenance
Contaminated soil, debris or matter
Spillage from machinery
SW 408 resulting from cleaning-up of a spill of
maintenance
chemical, mineral oil, or scheduled wastes
Disposed containers, bags or equipment
SW 409 contaminated with chemicals, pesticides, Maintenance and machinery
mineral oil, or scheduled wastes
Rags, plastics, papers or filters
SW 410 Maintenance and machinery
contaminated with scheduled wastes
Contamination from
SW 421 A mixture of scheduled wastes
machinery maintenance
A mixture of scheduled and non-scheduled Contamination from
SW 422
wastes machinery maintenance
The quantity of scheduled wastes generated varies based on construction

methodologies and the technologies available for each phase of construction.
However, the total quantity of scheduled wastes expected to be generated during

construction stage will be low as most of the sources will be from machinery
maintenance works.
7.4.5 Socio-Economic Analysis
The proposed project is an addition to the existing plant in operation. Opinions were
solicited from the respondents on the perceived impacts of this proposed project
from both negative and positive perspectives. These perceived impacts were
analyzed by assessing the level of intensity of concern (if negative impact) and the
level of satisfaction (if positive impact). For each type of perceived impact, an average
impact score was computed.
Negative Impacts
The construction stage is expected to take 2 years. During this duration there are
several negative impacts anticipated (Table 7-11).
Assessing the individual impacts, the communities perceived that these negative
impacts are clustered around low, moderate to high levels of concerned with scores
of 2, 3 and 4 respectively. Only small proportions of the respondents registered very
low (1) and very high (5) concerns. As a result, the mean scores of several of these
negative impacts hovered around 3 or moderate average level of concerns.
Table 7-11 Negative Impacts Perceived During Construction Stage

Concern Level
Very Very Mean
Perceived Impact Low Moderate High
Low High Score
(2) (3) (4)
(1) (5)
Noise from factory
construction work and
4.4% 36.2% 30.8% 26.6% 2.0% 2.9
movement of trucks /
heavy machinery
Vibration & cracking of
6.9% 39.2% 31.0% 22.4% 0.5% 2.7
residential buildings
Dust & air pollution from
3.7% 29.6% 27.8% 34.0% 4.9% 3.1
construction activities
Traffic congestion due to
3.2% 33.7% 26.4% 33.0% 3.7% 3.0
construction work
Public safety i.e.,
movement of trucks and 3.4% 33.0% 30.3% 31.5% 1.7% 3.0
construction machinery

Concern Level
Very Very Mean
Perceived Impact Low Moderate High
Low High Score
(2) (3) (4)
(1) (5)
Vector -borne diseases i.e.,
dengue caused by poorly
3.7% 41.4% 27.8% 23.2% 3.9% 2.8
managed construction
sites
Social unrest resulting
from the influx of foreign 1.5% 35.5% 32.8% 25.9% 4.4% 3.0
workers
Disturbance to routine
daily travels like to work 1.7% 33.0% 29.3% 34.5% 1.5% 3.0
and school
Construction waste /
1.7% 35.7% 33.3% 29.1% 0.2% 2.9
garbage dumped illegally
Notable negative impacts obtaining Mean Scores of > 3 are:

• Dust & air pollution from factory activity (3.1)
• Traffic jams (3.0)
• Public safety due to lorry movements (3.0)
• Social unrest from influx of foreign workers (3.0)
• Disturbance to routine daily travels (3.0)
But it should be noted that these perceived impacts did not reach mean scores of high
levels of concerns.
Positive Impacts
Table 7-12 provides for list of positive impacts anticipated during the construction
phase. It can be observed that all of these individual perceived impacts have Mean
Scores in excess of 3.5.
Among these positive impacts mentioned by the respondents included the

generation of employment opportunities for locals, and increasing the value of real
estate, both with mean scores of 3.9, increase in number of skilled workers created
and increase in income opportunities for surrounding businesses and services
including housing rentals, both with mean scores of 3.8, addition and improvement
of infrastructure (3.7) and provision of public facilities (3.6).
But it should be noted that unlike the cases of perceived negative impacts, the mean
scores obtained are all beyond Moderate levels (3) instead are closely approaching
high levels of anticipations (4) of receiving these benefits.

Table 7-12 Perceived Positive Impacts During Construction
Perceived Level of Benefit
Very Mean
Beneficial Impact Low Moderate High Very
Low Score
(2) (3) (4) High (5)
(1)
Generate employment
opportunities for local 0.7% 3.2% 15.5% 67.7% 12.8% 3.9
people
Increase the number of
0.7% 3.0% 18.2% 68.5% 9.6% 3.8
highly skilled workers
Increase income to
surrounding businesses &
0.2% 4.4% 16.0% 69.2% 10.1% 3.8
services including house
rental
Increasing the value of
0.7% 4.2% 19.7% 59.1% 16.3% 3.9
real estate
Addition & improvement
of infrastructure e.g., road,
0.5% 4.9% 27.1% 60.8% 6.7% 3.7
electricity, internet &
others
Encourage the provision
of public services such as
1.2% 9.4% 24.6% 58.1% 6.7% 3.6
schools, clinics,
recreational areas & others
Overall, quite a low proportion of the community felt that the proposed project
would be having negative impacts upon them with higher proportions having
positive expectations of the proposed project. The negative impacts would come
mainly from traffic issues pertaining to heavy vehicles.
During construction stage, there were generally very high frequencies perceiving
that there shall be generation of employment opportunities for locals, increase in
number of skilled workers created and increase in income opportunities for
surrounding businesses and services including housing rentals. These opportunities
to the local communities are open during the construction stage.
7.4.5.2 Assessment
The overall socio-impact assessment for the Project in both construction and
operation stages is detailed in Section 7.5.8.2.

7.5 OPERATION PHASE
7.5.1 Air Quality
Ambient air quality at air sensitive receptors (ASRs) within 5km from the Project site
can be affected by the operation of the Project. There are two streams of off gases
expected from the operations of the 2-EHAcid plant as follows:
• Oxygen off gas consists mainly oxygen (O2), carbon dioxide (CO2) and
nitrogen (N2) with small amounts of carbon monoxide (CO) which will be
thermally treated at the existing thermal oxidizer located in Aroma Plant; and
• Hydrogen off gas consists mainly of hydrogen (H2) and N2 with small
amounts of CO2, moisture, 2-ethylhexenal, heptylformate, heptane/heptene
and n-iso-butyraldehyde which will be thermally treated at the existing LP
flare which is dedicated for hydrogen off gas from 2-EHAcid Plant I and II.
Upon thermal treatment, off gases consist mainly O2 and H2 will be converted to
combustion gases like nitrogen oxides (NOx), CO2 and steam. NOx can affect the
health of population residing in the vicinity of the proposed Project. Table 7-13
shows the expected pollutants that will be released from two relevant stacks where
the hydrogen and oxygen off gases from the Project will be channeled into for
thermal destruction process.
Table 7-13 Expected Pollutant Emissions from Project Operation during

Normal and Abnormal Scenario
Stack Emission
No. Potential Pollutants Remarks
I.D. Source
Normal Operation:
• Carbon monoxide (CO)
• Nitrogen dioxide (NO2) Hydrogen off gas from 2-
LP/HP EHAcid Plant I and Plant II
1. X-8101
Flare Stack Abnormal Operation: will be thermally treated at
• Hydrogen (H2)a the existing flare.
• n/i-Butyraldehydea
• 2-ethylhexanal (C8H16O)b

Stack Emission
No. Potential Pollutants Remarks
I.D. Source
Normal Operation c:
• Particulate Matter (PM10)
• Nitrogen dioxide (NO2)
• Sulphur dioxide (SO2)
• Carbon monoxide (CO)
• Chlorine (Cl2)
• Hydrogen Sulphide (H2S)
• Hydrogen Chloride
(HCl)
Aroma Oxygen off gas from 2-
• Mercury (Hg)
Thermal EHAcid Plant I and Plant II
• Ammonia (NH3)
2. XX-9680 Oxidizer will be thermally treated at
• Non-Methane Volatile
(TOX) the existing Aroma Plant
Organic Compounds
Stack Thermal Oxidizer (TOX).
(NMVOCs)
Abnormal Operation d:
• 1-Butene (C4H8)
• MeOH (CH4O)
• Isoprene (C5H8)
• MTBE (C5H12O)
• Pentane (C5H12)
• Butane (C4H10)
Notes:
1. a major pollutant constituent in the raw hydrogen off gas from 2-EHAcid.
2. b major pollutant constituent in the raw gas from leaky heat exchanger event for T3200/T4200 (2-
ethylhexanal distillation column).
3. c these pollutants were detected or recorded during the stack monitoring exercise conducted for
Aroma Thermal Oxidizer (TOX).
d major pollutant constituent in the raw off gas from Offgas 1a, Offgas 2a, Offgas 2b, Offgas 4, Offgas
7, Offgas 9, Offgas E1220 and MBA-Offgas.
7.5.1.2 Assessment
The cumulative impacts of air pollutants emitted during the operational phase of the
Project (2-EHAcid plant + existing ICS) were determined by comparing the ground
level concentrations (GLC) at the pre-determined air sensitive receptors (ASRs) with
limits prescribed in the Standard 2020 of Malaysian Ambient Air Quality Standard
(MAAQS) as well relevant standards adopted by other countries for parameters
which are not covered in the MAAQS (i.e., Ontario Ambient Air Quality Criteria).
To obtain the GLC, air quality baseline results were added with the maximum
average incremental concentration (MAIC) of certain pollutants predicted using the
AERMOD View air dispersion model. AERMOD View produced dispersion contour
to show the extent and magnitude of the pollutant dispersion towards the
surrounding ASRs.

Three years (2019-2021) of hourly WRF-Preprocessed Meteorological Data from the
Lakes Environmental were used.
Air Dispersion Model
Quantitative air quality assessment has been carried out using AMS/EPA
Regulatory Model (AERMOD) View software to determine the extent of stack
emission impact towards the nearby air sensitive receptors (ASRs).
AERMOD model uses steady state Gaussian equation that combines source emission,
meteorological information, terrain, and dispersion coefficients to predict the
maximum average incremental concentration (MAIC) of pollutants within the study
impact zone. The latest AERMOD View Version 10.0.1 developed by Lakes
Environmental was used in this study.
Model Input
The setting up of the model for the assessment is shown in Table 7-14.
Table 7-14 Setting Conditions of AERMET and AERMOD

Component Set Up Conditions
• 3-year of WRF data for study area were used (year 2019–2021).
AERMET • Uniform cartesian grid spacing of 500m.
• Uniform polar with 12 direction radials and 5 rings.
• Computational grid of 10km x 10km.
• Terrain elevation data of Shuttle Topography Mission (SRTM 1) for
Datum WGS 84 with resolution of 30m.
• Concentration type calculation.
• Modelled species: PM10, NO2, SO2, CO, Cl2, H2S, HCl, Hg, NH3,
AERMOD NMVOC, 1-Butene, MeOH, Isoprene, MTBE, Pentane, Butane,
Hydrogen, n/i-Butyraldehyde and 2-ethylhexanal.
• Uniform cartesian grid spacing of 500m.
• Uniform polar with 12 direction radials and 5km radius.
• All the grids were centered at the center of the Project site: UTM-
coordinate of 318631.59 m (x-axis) and 440583.40 m (y-axis).
Air Sensitive Receptors (ASRs)
Four (4) air sensitive receptors (ASRs) have been identified and labelled as shown in
Chart 7-4. The ASRs considered in this study are as follows:
a) ASR 1 – Taman Seri Perasing (5.0km southwest of the Project site).

b) ASR 2 – Perumahan Balok Baru (3.5km southwest of the Project site).
c) ASR 3 – Taman Balok Perdana (2.8km south of Project site).
d) ASR 4 – Taman Kg. Gebeng Pantai (5.4km northeast of the Project site).

Chart 7-4 Locations of ASRs surrounding Project Site
Ground Level Concentration (GLC)
GLC is calculated at every location of the ASRs. GLC is a value indicating the
pollutant concentration level in the air where humans are normally exposed to (i.e.:
height of between ground level and roughly 2 metres above ground). The formula of
GLC is as follows:
MAIC
GLC BC
Maximum Average
Ground Level = + Baseline
Incremental
Concentration Concentration
Concentration

Where: MAIC = The predicted pollutant emission concentration at the
ASR based on air quality modelling result
BC = The existing ambient air quality concentration at the ASR

prior to Project’s earthwork stage
The value of BC was obtained from the ambient air quality monitoring result in
Section 6.7.1. A total of four air monitoring stations (A1 to A4) was placed at each
ASRs to represent the BC of the areas as shown in Chart 7-4.
Source Identification
Project Proponent will ensure all emissions from the proposed 2-EHAcid Plant will
be treated with appropriate system (i.e., flare system and thermal oxidizer) to meet
with the limits stipulated in Environmental Quality (Clean Air) Regulations 2014.
The emission sources are released from the HP Flare and Aroma TOX Stack whereby
it can be modelled as point sources. The locations of these sources are shown in Chart
7-5 while the specifications of the point sources and emission concentration and
emission rate are tabulated in Table 7-15 and Table 7-16 respectively.
Chart 7-5 Locations of Stacks

Aroma TOX
(XX-9680) LP/HP Flare
Stack
(X-8101)
Legend
Project Site

Table 7-15 Source Specification
UTM-Coordinates Stack
Stack
(m) Height Exit Exhaust
Stack Inner
No. Description from Velocity Temp.
ID Dia.
X-axis Y-axis Ground (m/s) (K)
(m)
(m)
X- LP Flare
1. 318893.52 440780.22 0.075 42.0 6.05 363.15
8101 Stack
X- HP Flare
2. 318893.52 440780.22 0.46 42.0 15.06 493.15
8101 Stack
Aroma
XX- Thermal
3. 318677.37 440785.72 1.21 30.0 13.5 473.15
9680 Oxidizer
(TOX) Stack
Table 7-16 Emission Concentration and Emission Rate

Emission Compliance
Type of Emission
No. Stack ID Description Concentration Limits
Pollutant Rate (g/s)
(mg/Nm3) (mg/Nm3)
Normal Operation
LP Flare CO 494.36 1.32E-02a -
1. X-8101
Stack NO2 90.86 2.43E-03a -
PM10 11.5 0.318b 50c
Hg 0.01 0.0003b 0.05c
HCl 31.5 0.872b 200c
Cl2 30.6 0.847b 32c
Aroma CO 2 0.055b -
Thermal
2. XX-9680 NO2 1.3 0.036b 700c
Oxidizer
(TOX) Stack SO2 2.9 0.080b 100c
H2S 2 0.055b 7.5c
NH3 1.2 0.033b 76c
20d
NMVOC 0.4 0.011b
150e
Abnormal Operation
Hydrogen (H2) 279,525.20 7.47 -
LP Flare
1. X-8101 n/i-
Stack 210,869.89 5.64 -
Butyraldehyde
HP Flare
2. X-8101 2-ethylhexanal 1,583,805.43 3,963.06 -
Stack
1-Butene
5072.48 136.41 -
(C4H8)
MeOH (CH4O) 569.55 15.32 -
Aroma Isoprene
351.19 9.44 -
Thermal (C5H8)
3. XX-9680
Oxidizer MTBE
572.55 15.40 -
(TOX) Stack (C5H12O)
Pentane
343.86 9.25 -
(C5H12)
Butane (C4H10) 345.72 9.30 -
Notes:
1. a Calculated based on AP-42, CH 13.5: Industrial Flares with total heat release rate (J/s) is obtained
from AERMOD View.

2. b The emission rates of the above pollutants are computed based on the pro-rated mass of gas of the
combined existing emission of the Aroma TOX and those from the 2-EHAcid Plant I and II.
3. c Item I (Chemical and Petrochemical Industry All Sizes), Third Schedule of the Environmental
Quality (Clean Air) Regulations 2014.

4. d Control of NMVOC Emissions, Second Schedule (Halogenated Hydrocarbon) of the
Environmental Quality (Clean Air) Regulations 2014.

5. e Control of NMVOC Emissions, Second Schedule (Other Than Halogenated Hydrocarbon) of the
Environmental Quality (Clean Air) Regulations 2014.

6. – means not available.
Modelling Scenario
In this assessment, the modelling was conducted for two (2) scenarios as follows:
a) Normal Operation Scenario

• Scenario 1 – Maximum 24-hour and annual average PM10 concentration.
• Scenario 2 – Maximum 1-hour and 24-hour average NO2 concentration.
• Scenario 4 – Maximum 1-hour and 24-hour average SO2 concentration.
• Scenario 5 – Maximum 1-hour and 8-hour average CO concentration.
• Scenario 6 – Maximum 24-hour average Cl2 concentration.
• Scenario 7 – Maximum 24-hour average H2S concentration.
• Scenario 8 – Maximum 24-hour average HCl concentration.
• Scenario 9 – Maximum 24-hour average Hg concentration.
• Scenario 10 – Maximum 24-hour average NH3 concentration.
• Scenario 11 – Maximum 24-hour average NMVOC concentration.
b) Abnormal Operation Scenario

• Scenario 12 – Maximum 1-hour average 1-Butene (C4H8) concentration.
• Scenario 13 – Maximum 1-hour average MeOH (CH4O) concentration.
• Scenario 14 – Maximum 1-hour average Isoprene (C5H8) concentration.
• Scenario 15 – Maximum 1-hour average MTBE (C5H12O) concentration.
• Scenario 16 – Maximum 1-hour average Pentane (C5H12) concentration.
• Scenario 17 - Maximum 1-hour average Butane (C4H10) concentration.
• Scenario 18 - Maximum 1-hour average Hydrogen (H2) concentration.
• Scenario 19 - Maximum 1-hour average n/i-Butyraldehyde concentration.
• Scenario 20 - Maximum 1-hour average 2-ethylhexanal (C8H16O)
concentration.
During normal operation scenario, oxygen off gas consists mainly oxygen (O2),
carbon dioxide (CO2) and nitrogen (N2) with small amounts of carbon monoxide (CO)
will be thermally treated at the existing thermal oxidizer (TOX) located in Aroma
Plant together with other continuous offgases from Aroma Plant before being
released at Stack XX-9680. At the same time, hydrogen off gas consists mainly of
hydrogen (H2) and N2 with small amounts of CO2, moisture, 2-ethylhexenal,

heptylformate, heptane/heptene and n-iso-butyraldehyde will be thermally treated
at the existing LP Flare Stack (X-8101).
Abnormal operation scenario is based on the following worst-case scenario for a

maximum duration of one (1) hour:
• Direct emission release from Aroma Plant continuous offgases (untreated

release) from Stack XX-9680 due to Aroma TOX system failure.
• Leaky heat exchanger event for T3200/T4200 (2-ethylhexanal distillation
column for 2-EHAcid Plant I and II) where pressure safety valve (PSV) will
channel the fluid into the HP Flare Stack X-8101 with failure of ignition
system.
However, the abnormal operation scenarios is very unlikely to happen since online
monitoring is available in DCS console and abnormalities or upset scenario will
trigger relevant interlock for Aroma TOX to get into fail-safe condition. Alarm will
also set off when the parameters go out of the normal operating condition.
In the case of PSV activation for leaky heat exchanger event for T3200/T4200, the
interlock for the respective equipment will trigger to get into fail-safe condition as
the system is operating outside of its normal operating condition. Based on this
configuration, the venting is not expected be continued in a long period of time
(estimated to be less than an hour).
A conservative approach has been taken when conducting the air quality assessment
for this Project. Maximum range values are deliberately used in the modelling input
for the abnormal operation scenarios to show how the operation of the Project, at
their most unmitigated operating conditions, would impact the surrounding
receptors.
Results obtained from the modeling exercise is tabulated in Table 7-17 and can be
summarized as follows:
i. Particulate Matter Less than 10 Microns (PM10)
The predicted GLC of PM10 (24-hour averaging time) at all the ASRs during
normal operation scenario is within the MAAQS limit of 100 µg/m3. The
predicted MAIC ranges from 0.08 to 0.2 µg/m3 with the highest at ASR 2
(Perumahan Balok Baru) and ASR 3 (Taman Balok Perdana) while the
predicted GLC ranges from 21.2 to 42.08 µg/m3 with the highest at ASR 1
(Taman Seri Perasing).
The predicted MAIC of PM10 (annual averaging time) at all the ASRs during

predicted MAIC ranges from 0.01 to 0.04 µg/m3 with the highest at ASR 2
(Perumahan Balok Baru) and ASR 3 (Taman Balok Perdana). The air quality
modelling output for PM10 can be referred in Chart 7-6.
ii. Nitrogen Dioxide (NO2)
The predicted GLC of NO2 (1-hour averaging time) at all the ASRs during
predicted MAIC and GLC range from 0.04 to 0.08 µg/m3 with the highest at
ASR 3 (Taman Balok Perdana). The air quality modelling output for NO2 can
be referred in Chart 7-7.
iii. Sulfur Dioxide (SO2)
The predicted GLC of SO2 (1-hour averaging time) at all the ASRs during
predicted MAIC and GLC range from 0.1 to 0.2 µg/m3 with the highest at
ASR 3 (Taman Balok Perdana). The air quality modelling output for SO2 can
be referred in Chart 7-8.
iv. Carbon Monoxide (CO)
The predicted GLC of CO (1-hour averaging time) at all the ASRs during
normal operation scenario is within the MAAQS limit of 30 mg/m3. The
predicted MAIC and GLC range from 0.08 to 0.20 µg/m3 with the highest
reading at ASR 3 (Taman Balok Perdana). The air quality modelling output
for CO can be referred in Chart 7-9.
v. Chlorine (Cl2)
The predicted GLC of Cl2 (24-hour averaging time) at all the ASRs during
normal operation scenario is within the Ontario Ambient Air Quality Criteria
limit of 10 µg/m3. The predicted MAIC and GLC range from 0.2 to 0.5 µg/m3
with the highest reading at ASR 3 (Taman Balok Perdana). The air quality
modelling output for Cl2 can be referred in Chart 7-9.
vi. Hydrogen Sulfide (H2S)
The predicted GLC of H2S (24-hour averaging time) at all the ASRs during
modelling output for H2S can be referred in Chart 7-10.

vii. Hydrogen Chloride (HCl)
The predicted GLC of HCl (24-hour averaging time) at all the ASRs during
modelling output for HCl can be referred in Chart 7-11.
viii. Mercury (Hg)
The predicted GLC of Hg (24-hour averaging time) at all the ASRs during
limit of 2 µg/m3. The predicted MAIC ranges from 0.00001 to 0.001 µg/m3
with the highest reading at ASR 1 (Taman Seri Perasing) while the predicted
GLC ranges from 0.00001 to 0.0402 µg/m3 with the highest at ASR 3 (Taman
Balok Perdana). The air quality modelling output for Hg can be referred in
Chart 7-11.
ix. Ammonia (NH3)
The predicted GLC of NH3 (24-hour averaging time) at all the ASRs during
limit of 100 µg/m3. The predicted MAIC ranges from 0.008 to 0.02 µg/m3 with
the highest reading at ASR 2 (Perumahan Balok Baru) and ASR 3 (Taman
Balok Perdana) while the predicted GLC ranges from 0.01 to 63.02 µg/m3
with the highest at ASR 2 (Perumahan Balok Baru). The air quality modelling
output for NH3 can be referred in Chart 7-12.
x. Non-Methane Volatile Organic Compound (NMVOC)
The predicted MAIC and GLC of NMVOC (24-hour averaging time) during
normal operation scenario range from 0.004 to 0.008 µg/m3 with the highest
for NMVOC can be referred to Chart 7-12.
xi. 1-Butene (C4H8)
The predicted MAIC and GLC of 1-Butene (1-hour averaging time) during
abnormal operation scenario range from 200 to 300 µg/m3 with the highest
for 1-Butene can be referred to Chart 7-13.

xii. MeOH (CH4O)
The predicted MAIC and GLC of MeOH (1-hour averaging time) during
for MeOH can be referred to Chart 7-13.
xiii. Isoprene (C5H8)
The predicted MAIC and GLC of Isoprene (1-hour averaging time) during
reading at ASR 2 (Perumahan Balok Baru) and ASR 3 (Taman Balok Perdana).
The air quality modelling output for Isoprene can be referred to Chart 7-14.
xiv. MTBE (C5H12O)
The predicted MAIC and GLC of MTBE (1-hour averaging time) during
for MTBE can be referred to Chart 7-14.
xv. Pentane (C5H12)
The predicted MAIC and GLC of Pentane (1-hour averaging time) during
reading at ASR2 (Perumahan Balok Baru) and ASR 3 (Taman Balok Perdana).
The air quality modelling output for Pentane can be referred to Chart 7-15.
xvi. Butane (C4H10)
The predicted MAIC and GLC of Butane (1-hour averaging time) during
reading at ASR2 (Perumahan Balok Baru) and ASR 3 (Taman Balok Perdana).
The air quality modelling output for Butane can be referred to Chart 7-15.
xvii. Hydrogen (H2)
The predicted MAIC and GLC of Hydrogen (1-hour averaging time) during
for Hydrogen can be referred to Chart 7-16.

xviii. n/i-Butyraldehyde
The predicted MAIC and GLC of n/i-Butyraldehyde (1-hour averaging time)

during abnormal operation scenario range from 20 to 30 µg/m3 with the
highest reading at ASR 3 (Taman Balok Perdana). The air quality modelling
output for n/i-Butyraldehyde can be referred to Chart 7-16.
xix. 2-ethylhexanal (C8H16O)
The predicted MAIC and GLC of 2-ethylhexanal (1-hour averaging time)

during abnormal operation scenario range from 12,000 to 18,000 µg/m3 with
the highest reading at ASR 3 (Taman Balok Perdana). The air quality
modelling output for 2-ethylhexanal can be referred to Chart 7-17.

Table 7-17 Predicted Maximum Average Incremental Concentration (MAIC) and Ground Level Concentration (GLC) at Air Sensitive Receptors (ASRs)
ASR 4 - Taman Kg.
ASR 1 - Taman Seri ASR2 - Perumahan Balok ASR 3 - Taman Balok
Air Gebeng Pantai (5.4km Ambient
Averaging Perasing (5.0km southwest Baru (3.5km southwest of Perdana (2.8km south
No Pollutant Unit Dispersion Max MAIC northeast of the Project Limits
Time of the Project site) the Project site) of Project site)
Contour site) (ug/m3)
BC MAIC GLC BC MAIC GLC BC MAIC GLC BC MAIC GLC
Normal Operation
µg/m3 24-Hr Chart 7-6 1.215 42 0.08 42.08 21 0.2 21.2 31 0.2 31.2 39 0.1 39.1 100a
1 PM10
µg/m3 Annual Chart 7-6 0.259 - 0.01 0.01 - 0.04 0.04 - 0.04 0.04 - 0.02 0.02 40a
µg/m3 1-Hr Chart 7-7 1.074 <0.5 0.04 0.04 <0.5 0.06 0.06 <0.5 0.08 0.08 <0.5 0.04 0.04 280a
2 NO2
µg/m3 24-Hr Chart 7-7 0.138 - 0.01 0.01 - 0.02 0.02 - 0.04 0.04 - 0.02 0.02 70a
µg/m3 1-Hr Chart 7-8 2.376 <50 0.1 0.1 <50 0.1 0.1 <50 0.2 0.2 <50 0.1 0.1 250a
3 SO2
µg/m3 24-Hr Chart 7-8 0.306 - 0.02 0.02 - 0.02 0.02 - 0.06 0.06 - 0.04 0.04 80a
µg/m3 1-Hr Chart 7-9 1.677 <1 0.08 0.08 <1 0.1 0.1 <1 0.2 0.2 <1 0.08 0.08 30,000a
4 CO
µg/m3 8-Hr Chart 7-9 0.461 - 0.04 0.04 - 0.06 0.06 - 0.08 0.08 - 0.06 0.06 10,000a
5 Cl2 µg/m3 24-Hr Chart 7-10 3.234 <10 0.2 0.2 <10 0.3 0.3 <10 0.5 0.5 <10 0.3 0.3 10b
6 H2S µg/m3 24-Hr Chart 7-10 0.211 <10 0.02 0.02 <10 0.02 0.02 <10 0.03 0.03 <10 0.02 0.02 7b
7 HCl µg/m3 24-Hr Chart 7-11 3.329 <20 0.2 0.2 <20 0.4 0.4 <20 0.6 0.6 <20 0.4 0.4 20b
8 Hg µg/m3 24-Hr Chart 7-11 0.001 <0.01 0.00001 0.00001 <0.01 0.00001 0.00001 0.04 0.0002 0.0402 <0.01 0.00001 0.00001 2b
9 NH3 µg/m3 24-Hr Chart 7-12 0.127 38 0.008 38.008 63 0.02 63.02 <10 0.02 0.02 <10 0.01 0.01 100b
10 NMVOC µg/m3 24-Hr Chart 7-12 0.042 <10 0.004 0.004 <10 0.004 0.004 <10 0.008 0.008 <10 0.004 0.004 -
Abnormal Operation
1 1-Butene (C4H8) µg/m3 1-hr Chart 7-13 4,067.457 - 200 200 - 200 200 - 300 300 - 200 200 -
2 MeOH (CH4O) µg/m3 1-hr Chart 7-13 456.707 - 20 20 - 20 20 - 40 40 - 20 20 -
3 Isoprene (C5H8) µg/m 3 1-hr Chart 7-14 281.611 - 10 10 - 20 20 - 20 20 - 10 10 -
4 Methyl tert-butyl ether (C5H12O) µg/m3 1-hr Chart 7-14 459.109 - 20 20 - 20 20 - 40 40 - 20 20 -
5 Pentane (C5H12) µg/m3 1-hr Chart 7-15 275.730 - 10 10 - 20 20 - 20 20 - 10 10 -
6 Butane (C4H10) µg/m 3 1-hr Chart 7-15 277.221 - 10 10 - 20 20 - 20 20 - 10 10 -
7 Hydrogen (H2) µg/m3 1-hr Chart 7-16 500.103 - 30 30 - 30 30 - 50 50 - 20 20 -
8 n/i-Butyraldehyde µg/m3 1-hr Chart 7-16 377.588 - 20 20 - 20 20 - 40 40 - 20 20 -
9 2-ethylhexanal (C8H16O) µg/m 3 1-hr Chart 7-17 116,182.426 - 12,000 12,000 - 12,000 12,000 - 18,000 18,000 - 12,000 12,000 -
Notes: a. Standard 2020 of Malaysian Ambient Air Quality Standards (MAAQS), 2013
b. Ontario Ambient Air Quality Criteria
Ground Level Concentration (GLC) = Baseline Concentration (BC) + Maximum Average Incremental Concentration (MAIC)
< means ‘less than the minimum detectable limit’ or ‘not detected’.
- means no data available

Chart 7-6 Predicted MAIC of PM10 (24 Hour and Annual Averaging Time) during Normal Operation

Chart 7-7 Predicted MAIC of NO2 (1-Hour and 24-Hour Averaging Time) during Normal Operation

Chart 7-8 Predicted MAIC of SO2 (1-Hour and 24-Hour Averaging Time) during Normal Operation

Chart 7-9 Predicted MAIC of CO (1-Hour and 8-Hour Averaging Time) during Normal Operation

Chart 7-10 Predicted MAIC of Cl2 and H2S (24-Hour Averaging Time) during Normal Operation

Chart 7-11 Predicted MAIC of HCl and Hg (24-Hour Averaging Time) during Normal Operation

Chart 7-12 Predicted MAIC of NH3 and NMVOC (24-Hour Averaging Time) during Normal Operation

Chart 7-13 Predicted MAIC of 1-Butene and MeOH (1-Hour Averaging Time) during Abnormal Operation

Chart 7-14 Predicted MAIC of Isoprene and MTBE (1-Hour Averaging Time) during Abnormal Operation

Chart 7-15 Predicted MAIC of Pentane and Butane (1-Hour Averaging Time) during Abnormal Operation

Chart 7-16 Predicted MAIC of Hydrogen and n/i-Butyraldehyde (1-Hour Averaging Time) during Abnormal Operation

Chart 7-17 Predicted MAIC of 2-ethylhexanal (1-Hour Averaging Time)
during Abnormal Operation

7.5.2 Greenhouse Gas Emission
Greenhouse gases (GHG) are compound gases that trap heat in the atmosphere.
Climate change, particularly global warming, is heavily influenced by the output of
GHGs emitted from human activities. The alarming rate of global warming and
climate disaster occurrence frequency observed throughout the world has prompt
businesses to adopt sustainable practices and strive for net zero ambitions in order
to mitigate climate change.
In Malaysia, emissions from natural gas accounts for 7.7% of total GHG emissions of
the country (MEWA, 2020). Natural gas is a common fossil fuel used in the industrial
sector as it is relatively cheap and widely available. Upon combustion, the
hydrocarbon will produce carbon dioxide, a greenhouse gas, which will be released
to the atmosphere and contribute to global warming.
The operation of the 2-EHAcid plant will contribute to the emissions of GHG
particularly from the combustion of fossil fuel (natural gas) and resultant off-gas
released to the atmosphere. GHG cause climate change by trapping heat in the
Earth’s atmosphere. The GHG emission from Project site will depend on the
efficiency of fuel burning equipment, machineries and production management.
Project Proponent has rolled out several emission reductions target to achieve their
Net Zero ambition by year 2050. The measures that were taken and planned to be
conducted is elaborated on Section 8.4.2.
7.5.2.2 Assessment
Assessment Methodology
The assessment will quantify the annual amount of GHGs (i.e., CO2, CH4 and N2O)
which will be released to the atmosphere during the Project operation phase. The
quantity of GHG produced is directly correlated to the amount of fossil fuel
combustion taking place to provide energy for the generation of steam, which are
used during the production process of the 2-EHAcid at the Project site.
The quantity of GHG emission from the Project is calculated using the Greenhouse
Gas Protocol tool for Stationary Combustion Version 4.1 developed by the World
Resources Institute (WRI). The tool was developed by WRI as part of its Greenhouse
Gas Protocol Initiative. The emission factors used in this tool are derived from the
IPCC 2006 Guidelines for National Greenhouse Gas Inventories.

In order to estimate GHG emission, the type and amount of fuel used to operate the
machineries and equipment at the 2-EHAcid plant will be recorded and inputted into
the GHG Protocol tool. The tool will calculate and show the amount of GHG which
will be emitted from Project operation.
The production process at the proposed 2-EHAcid plant will utilize steam generated
from existing boilers within the ICS. These boilers rely on natural gas for the
production of steam. Hence, the GHG assessment for this Project will focus on direct
emission (Scope 1) from the production of steam used within the existing and
proposed 2-EHAcid plant as well as the overall ICS. Chart 7-18 shows the scenarios
for the assessment.
Chart 7-18 GHG Emission Scenario
Assessment
The emission factors and assumptions used to calculate the GHG emission are
derived from various studies and known variables as follows:
i) Steam generation from boiler:

• Scenario A = 1,241,149.186 MT/year
• Scenario B = 47,760 MT/year
• Scenario C = 23,880 MT/year
o Source: BASF PETRONAS Chemicals (2022)
ii) Conversion factor:

• 1,194 BTU of natural gas: 1 lbs of steam
o Source: Decker, Fred (2018)

The total combustion value of 3.267×106 mmBtu is for the entire ICS of Scenario A
that includes combustion for other industrial processes. Scenario B is the
combination of the existing and proposed 2-EHAcid plant with combustion value of
125×103 mmBtu. Meanwhile Scenario C is the proposed 2-EHAcid plant that has the
same production as the existing plant at 62×103 mmBtu. The GHGs emissions are
calculated for each scenario using the GHG Protocol Tool for Stationary Combustion
with the results as shown in Table 7-18.
Table 7-18 shows the GHG emission from Project operation categorized into several
scenarios. As mentioned in the assessment methodology, the only input that is taken
into account to calculate GHG emissions is combustion of natural gas to provide
steam for the various components within the ICS. Scenario A shows the emission
from steam generation within the entire ICS which amounts to 193,570.98
tCO2e/year. Scenario B is emissions from both the existing and proposed 2-EHAcid
Plant which is predicted to emit 7,448.70 tCO2e/year. Lastly, Scenario C is emissions
generated from the proposed 2-EHAcid Plant which is found to be exactly half of the
emissions from Scenario B at 3,724.35 tCO2e/year.
Table 7-18 GHG Emission from Project Operation

Steam Natural Gas
GHG Emission
Scenario Description Generation Consumption
(tCO2e/year)
(MT/year) (mmBtu)
Scenario A ICS 1,241,149 3.267×106 193,570.98
Existing 2-EHAcid
Plant +
Scenario B 47,760 125×103 7,448.70
Proposed Existing
2-EHAcid Plant
Proposed Existing
Scenario C 23,880 62×103 3,724.35
2-EHAcid Plant
Summary
Overall, the proposed 2-EHAcid Plant represents only 1.9% of the total GHG
emission from the ICS. This finding shows that the development of the Project will
contribute to an only insignificant emission increment compared to the overall
emissions from the ICS operations. Chart 7-19 shows the breakdown of the GHG
emission (from steam generation) at the ICS including the existing and proposed 2-
EHAcid Plant.

Chart 7-19 GHG Emissions in the ICS
The operation of this Project will have negligible to little noise impact to the receptors
surrounding the proposed Project because it is located within the existing ICS
occupied by the Project Proponent, which is located within a designated industrial
area, known as Gebeng Industrial Estate (GIE). The residential areas identified
surrounding the proposed Project is located more than 2.8 km away (Taman Balok
Perdana, Kompleks Perumahan TLDM, Taman Balok Makmur). Therefore, the result
of noise assessment will be compared with the boundary of existing ICS.
7.5.3.2 Assessment
The sound pressure levels were predicted using procedures from the ISO 9613-2:
Acoustic – Attenuation of sound during propagation outdoors – Part 2: General
Method of Calculation. CadnaA, a software package developed by Datakustik
GmbH which implements the procedures, was used to predict the noise levels.
Several assumptions have been made for the modelling exercise as highlighted below:
• Noise modelling is carried out based on the limited information due to the
preliminary stage of Project development;
• Noise modelling calculation is carried out only for the components within the
Project boundary, and not taking into consideration of the overall ICS boundary.
However, ambient noise level measured as baseline at the ICS boundary will be
used to calculate the cumulative noise impact;
• Environmental noise propagation calculation is undertaken with the flat
platform level of Project site.
• The noise from the Project boundary is predicted to generate 85 dB(A) as to
predict worst case scenario.

Assessment Results
Chart 7-20 shows the noise contour of the overall ICS boundary based on the noise
generated from the Project boundary. Based on Table 7-19 and Table 7-20, the
predicted cumulative noise level is calculated based on the noise level from the
proposed Project and existing ambient noise level at northwestern boundary of the
ICS-A300 Blockfield and southeastern of the ICS-D600 Blockfield. The predicted
cumulative noise level for both daytime and night-time is below the maximum
permissible sound level in accordance to the noise limits specified in Second
Schedule of Guidelines for Environmental Noise Limits and Control, 2019 (Reprint
2021).
Therefore, the operation of the proposed Project is not anticipated to cause noise
disturbance to the residential areas which are located more than 2.8 km away from
the proposed Project.

During Daytime
Development Phase Operation
Distance the ICS-A300 Blockfield D600 Blockfield (0.35
(0.59 km) km)
Daytime1 (dBA) (N1 station) (N3 station)
Daytime from CadnaA 48.7 57.5
(dBA) 2
59.7 64.6
(dBA)
Maximum Permissible
Sound Level, Daytime3 75.0 75.0
(dBA)
Compliance to Max.
0 0
Noise Level, Daytime (dBA)
Response4
Note:
1. Refer to Subsection 6.7.2.2. Source: Environmental Science (M) Sdn Bhd., 2021
2. Refer to Chart 7-2, Noise Modelling Contour of the Project Boundary During Operation Stage
3. Guidelines for Environmental Noise Limits and Control Third Edition, 2019 (Reprint 2021) – Second
Schedule: Recommended Permissible Sound Level (LAeq) By Receiving Land Use For Existing Built
Up Areas

During Night-time
Development Phase Operation
Distance the ICS-A300 Blockfield D600 Blockfield (0.35
(0.59 km) km)
Night-time1 (dBA) (N1 station) (N3 station)
Night-time from CadnaA 48.7 57.5
(dBA)
53.1 64.7
(dBA)
Maximum Permissible
Sound Level, Night-time2 75.0 75.0
(dBA)
Compliance to Max.
Noise Level, Night-time 0 0
(dBA)
Response3
Note:
1. Refer to Subsection 6.7.2.2. Source: Environmental Science (M) Sdn Bhd., 2021
2. Refer to Chart 7-20, Noise Modelling Contour of the Project Boundary During Operation Stage
3. Guidelines for Environmental Noise Limits and Control Third Edition, 2019 (Reprint 2021) – Second
Schedule: Recommended Permissible Sound Level (LAeq) By Receiving Land Use For Existing Built
Up Areas

Chart 7-20 Noise Modelling Contour of the Project Boundary During
Operation Stage
Legend:
Project Site
ICS Boundary
45.3 Road
Receiver
57.5 (N3)
48.7 (N1)
7.5.4 Risk
A Quantitative Risk Assessment (QRA) is prepared for the proposed Project to

specifically address the risk arising to the potential sensitive receptors due to the
proposed Project (Appendix H). The objectives of the QRA study are:
• To identify and quantify the probability and consequences of the possible

accidents that may escalate from the proposed Project to the surrounding
offsite areas;
• To calculate the level of risk; and
• To suggest measures to reduce the level of risk if higher than the allowable
level in compliance with DOE’s risk criteria stipulated in the Environmental
Impact Assessment Guidelines for Risk Assessment (2004).
The scope for this study is as follows:
• Hazard identification – qualitative review of possible accidents that may

occur (based on previous accident experience or professional judgement
where necessary) for the proposed Project;
• Determination of failure scenarios;
• Determination of probability of occurrence for each failure scenario;

• Determination of consequences hazard distances of each identified hazard
scenario;
• Combination of failure frequencies and all consequences in order to
determine the individual risk levels posed by the operation of the proposed
facility; and
• Comparison of the risk results against DOE risk criteria.
The risk assessment of the proposed project has been conducted in accordance with
the elements summarized in Chart 7-21 and detailed in the following sections.
Chart 7-21 QRA Methodology

Hazard Identification: Identification of initiating release events and major hazards that
require further evaluation
Frequency Analysis: Determination of the frequency of initiating events and the

frequency of hazardous event outcomes
Consequence Analysis: Determination of the consequences of hazardous events
Event Tree Analysis: Representation of how the initiating event may develop and the
resulting likelihood of the hazardous outcome
Risk Summation: Calculation and evaluation of individual risk level and as well as
comparison against the risk criteria established for the study
Risk Mitigation: Recommendation of risk mitigation measures, as required
7.5.4.1 Hazard Identification
The first step in the QRA involves identifying physical situations (failure modes or
initiating events) that may lead to a major accident with the potential for personnel
injury or fatality, such as fire, explosion or the release of a dangerous substance. A
representative set of discrete initiating events was short listed after a full review of
the process and hazardous substances present onsite. The consequences of these
scenarios were further evaluated, and their risk was quantified in the study

General
The identification of possible major accident hazard in the proposed project is based
on the physical and chemical properties (i.e., flash point, boiling point, heat of
combustion) of substances stored in this project site. Other than that, the design
parameter of the vessels which store the hazardous substance has also been
considered as one of the factors in deciding the possible scenario of major accident
hazard.
Occupational Health Hazards
The impact of other hazards, such as occupational hazards which are limited to
personnel working within the proposed project site and external hazards (earthquake,
airplane crash etc.) have not been reported as these hazards are not within the scope
of this QRA.
Hazardous Substances
The substances that have been assessed in this QRA study are summarized in Table
7-21. The materials are chosen based on high mass percentage in each unit
(equipment) and its physical and chemical properties (explosive, flammability, and
toxicity).
It should be noted that maximum quantities/ inventories and worst-case operating/

processing conditions are used in the QRA to ensure conservatism.
Table 7-21 Characterization of Hazardous Material

Hazardous Material Characterization
2-Ethylhexanoic Acid Flammable
2-Ethylhexanal Flammable
2-Ethylhexanol Flammable and explosive
Hydrogen Flammable and explosive
n-Butanal Flammable and explosive
Heptyl Formate Flammable and explosive
Undecanol Flammable
7.5.4.2 Qualitative Risk Assessment
Qualitative risk assessment is a first choice in risk assessment, especially for the less
complex facility or operation. Such assessment by itself would be inappropriate for
complex facility with numerous on-site hazards that could lead to off-site risks.
Qualitative risk analysis uses word form or descriptive scales to describe the
magnitude of potential consequences and the likelihood that those consequences will

occur. These scales can be adapted or adjusted to suit the circumstances, and different
descriptions may be used for different risks. Qualitative risk analysis methods are
used to set priority for various other purposes, including further analysis.
Consequences versus Likelihood
Risk matrix is a tool that assists quantitative risk assessment and facilitates the
categorization of possible threat to safety (Table 7-22). The matrix axes consistent
with the definition of risk are consequences and probability (or likelihood). A scale
of consequence from 'minor' to 'major' is used to indicate increasing severity. The
consequences are those of credible scenarios (taking the prevailing circumstances
into consideration) that can develop from the realisation of a hazard. The potential
consequences, rather than the actual ones, are used. The probability on the horizontal
axis is estimated on the basis of historical evidence or experience that the identified
consequences have occurred within the industry. It is the probability of the estimated
potential consequences occurring.
Risk Matrix estimates the risk levels based on the product of the level of consequence
of an event (incident or accident) and the likelihood of its occurrence. Levels of both
consequence and likelihood must be predefined before the Risk Matrix Table may be
used. Tables 7-23 and Table 7-24 provide the general definitions for various levels
of consequence and likelihood, respectively, which may be used in qualitative risk
analysis.
Table 7-22 A Risk Matrix Table
Table 7-23 Level of Likelihood

Likelihood Level Definition of Likelihood
Almost certain 4 Is almost certain to occur in most circumstances
Likely 3 Is likely to occur in most circumstances
Unlikely 2 May occur at some time
Rare 1 May occur in exceptional circumstances

Table 7-24 Level of Consequences
Consequence Level Definition of Consequences
Major offsite hazardous event with detrimental long-term effects
Catastrophic 5
to the environment, death, huge financial loss
Major offsite hazardous event with impact recoverable beyond
Major 4 project period, major injuries (permanent disablement or/and
genetic defects), major financial loss
Hazardous event contained without side assistance,
Moderate 3 environmental impact recoverable within project period, injury
requiring hospitalization, large financial loss
On site hazardous event contained without outside assistance,
Minor 2 transient or short-term environmental impact, minor injuries,
some financial loss
Insignificant 1 Brief impact on environment, first aid cases, low financial loss
Risk Classification
Qualitatively, the risk of the identified hazards at the 2-EHAcid plant may be
classified based on its consequences and severity rating. The score for the likelihood
and consequences for the potential incident outcomes at a particular unit of the
proposed Project are obtained from Tables 7-23 and Table 7-24, respectively. The
threshold index of risk to require a quantitative risk assessment is set at 8 (EIA
Guideline for Risk Assessment, 2004) and above.
Based on Table 7-25 almost all possible incident outcomes identified at the proposed
facility requires an in-depth analysis in the form of quantitative risk assessment.
It is to be noted that drumming activities of the product shall also be carried out as
part of the proposed operation of the plant. Incidents related to this activity are very
low in terms of its consequences (inventory in a drum is small hence resulting
consequences will be localized) and risk hence further quantitative assessment has
been conducted for drumming activities.
The list of scenarios in Table 7-25 has been developed based on the Process Flow
Diagram and Heat Material Balance information. Each dominant component of the
vessel was identified and listed in Table 7-25. Outcome of any released substances
from the vessels were determined based on their chemical properties.

Table 7-25 List of Scenarios
Process Unit and Possible Hazardous Likelihood Consequence Risk Quantitative Risk
No. Material Handled
Abbreviation Outcome Score Score Score Assessment (Y/N)
Liquid Gas Separator D Hydrogen and 2- Jet Fire, Pool Fire, Flash
1 4 3 12 Y
4110 Ethylhexanal Fire and Explosion
Hexanal Column Phase
2 n-Butanal Pool Fire 4 3 12 Y
Separator D 4210
Hexanal Buffer Drum D
3 2-Ethylhexanal Pool Fire 4 3 12 Y
4230
Hexanol Column Overhead
4 2-Ethylhexanol Pool Fire 4 3 12 Y
Drum D 4310
Oxidation Product Drum D Oxygen and 2- N (but still within
5 Pool Fire 2 3 6
4430 Ethylhexanoic Acid modelling capability)
2-EHAcid Column
6 Heptyl Formate Pool Fire 4 3 12 Y
Overhead Drum (1) D 4510
2-EHAcid Column
Overhead Drum (2) D 4511
O2 Off Gas Separator D
8 Oxygen - 4 1 4 N
4614
Organic Residue Drum D Hydrogen and Jet Fire, Pool Fire, Flash
9 4 3 12 Y
4670 Heptyl Formate Fire and Explosion
Deep Drainage Drum (1) D
10 n-Butanal Pool Fire 4 3 12 Y
4680
Deep Drainage Drum (2) D
4685
Hydrogenation Reactor R Hydrogen and 2- Jet Fire, Pool Fire, Flash
12 4 3 12 Y
4100 Ethylhexanal Fire and Explosion

Process Unit and Possible Hazardous Likelihood Consequence Risk Quantitative Risk
No. Material Handled
Abbreviation Outcome Score Score Score Assessment (Y/N)
Oxygen and 2- N (but still within
13 Oxidation Reactor R 4400 Pool Fire 2 3 6
Ethylhexanoic Acid modelling capability)
2-Ethylhexanal Column T n-Butanal and Jet Fire, Pool Fire, Flash
14 4 3 12 Y
4200 Undecanol Fire and Explosion
2-Ethylhexanol Column T 2-Ethylhexanol and Jet Fire, Pool Fire, Flash
15 4 3 12 Y
4300 Undecanol Fire and Explosion
2-EHAcid Stripping Nitrogen and 2- N (but still within
16 Pool Fire 2 3 6
Column T 4450 Ethylhexanoic Acid modelling capability)
2-EHAcid Dividing Wall Heptyl Formate and Jet Fire, Pool Fire, Flash
17 4 3 12 Y
Column T 4500 2-Ethylhexanoic Acid Fire and Explosion
Residue Storage Tank TK
2920
2-EHAcid Product Tank TK N (but still within
19 2-Ethylhexanoic Acid Pool Fire 2 3 6
4610 modelling capability)
2-Ethylhexanoic Acid N (but still within
20 2-Ethylhexanoic Acid Jet Fire and Pool Fire 2 3 6
transfer line to TTLR modelling capability)
2-Ethylhexanoic Acid line N (but still within
21 2-Ethylhexanoic Acid Jet Fire and Pool Fire 2 3 6
to storage modelling capability)
Jet Fire, Flash Fire and
22 Hydrogen Off Gas Pipeline Hydrogen 4 3 12 Y
Explosion
Residue transfer line to
23 Heptyl Formate Jet Fire and Pool Fire 4 3 12 Y
storage
Hydrogen Line from Oxo- Jet Fire, Flash Fire and
24 Hydrogen 4 3 12 Y
syngas Explosion

Representative Release Scenarios
Leaks can range in size from a pinhole leak to a catastrophic failure. In general
smaller leaks have higher accident likelihood but lower consequence distances. On
the other hand larger releases have lower accident likelihood but longer consequence
distance. The representative scenarios considered in this study are:
Pressure Vessels (Reactor, Column, Drum):

• Small leak (5 mm);
• Medium leak (25 mm);
• Large leak (65 mm); and
• Catastrophic (150 mm).
Atmospheric Tank:
• Catastrophic (150 mm).
Pipeline:
• Catastrophic (rupture).
In line with PETRONAS guidelines, all release modelling is based on the following
hole sizes (Table 7-26):
Table 7-26 Hole Sizes for Release Modelling

Release Size Hole Size Range (mm) Representative Hole Size (mm)
Small 0 – 10 5
Medium 10 – 40 25
Large 40 – 100 65
Full Bore Rupture 100 – FBR 150
The events identified for further analysis in this study has been divided into
isolatable sections (which represent sections of the process that have various hold up
inventory, pressure and temperature) as tabulated in Table 7-27.

Table 7-27 Listing of Release and Outcome Events for Consequence
Analysis
Isolatable Sub-section Release Potential
No. Description
ID Size Outcome(s)
Release of Hydrogen due to
leak/ catastrophic failure of 5 mm
Liquid Gas Separator (Upper
Part) D-4110 and associated 25 mm Jet Fire,
fittings/ pipings. An Flash Fire
1 IS01_H2_LGSUP_V
immediate outcome of the and
released Hydrogen will result 65 mm Explosion
in Jet Fire while delayed
outcome will result in Flash 150 mm
Fire and Explosion.
Release of 2-Ethylhexanal due

5 mm
to leak/ catastrophic failure of
Liquid Gas Separator (Bottom
Part) D-4110 and associated 25 mm
fittings/ pipings. An Jet Fire and
2 IS02_2EH_LGSBP_L immediate outcome of the Pool Fire
released 2- Ethylhexanal will 65 mm
result in Jet Fire while delayed
outcome will result in Pool
150 mm
Fire
Release of n-Butanal due to

5 mm
leak/ catastrophic failure of
Hexanal Column Phase
Separator D-4210 and 25 mm
3 IS03_nBU_HCPS_L associated fittings/ pipings. Pool Fire
An immediate and delayed 65 mm
outcome of the released n-
Butanal will result in Pool 150 mm
Fire.
Release of 2-Ethylhexanal due 5 mm
Hexanal Buffer Drum D-4230
25 mm
and associated fittings/
4 IS04_2EH_HBD_L Pool Fire
pipings. An immediate and
65 mm
delayed outcome of the
released 2- Ethylhexanal will
result in Pool Fire. 150 mm

No. Description
ID Size Outcome(s)
Release of 2-Ethylhexanol due
5 mm
Hexanal Column Overhead
Drum D-4310 and associated 25 mm
5 IS05_2EHOH_HCOD_L fittings/ pipings. An Pool Fire
immediate and delayed 65 mm
outcome of the released H2-
Ethylhexanol will result in
150 mm
Pool Fire.
Release of Heptyl Formate
5 mm
due to leak/ catastrophic
failure of 2-EHAcid Column
Overhead Drum (1) D-4510 25 mm
6 IS06_HF_2ECODI_L and associated fittings/ Pool Fire
pipings. An immediate and 65 mm
released Heptyl Formate will
150 mm
result in Pool Fire.
5 mm
failure of 2-EHAcid Column
Overhead Drum (2) D-4511 25 mm
7 IS07_HF_2ECODII_L and associated fittings/ Pool Fire
150 mm
Orgaic Residue Drum (Upper
Part) D-4670 and associated 25 mm Jet Fire,
8 IS08_H2_ORDUP_V immediate outcome of the and
Fire and Explosion.
Release of Heptyl Formate 5 mm

failure of Organic Residue
Drum (Bottom Part) D-4670 25 mm
9 IS09_HF_ORDBP_L and associated fittings/ Pool Fire
result in Pool Fire. 150 mm

No. Description
ID Size Outcome(s)
5 mm
Deep Drainage Drum (1) D-
25 mm
4680 and associated fittings/
10 IS10_nBU_DDDI_L Pool Fire
pipings. An immediate and
65 mm
released n- Butanal will result
150 mm
in Pool Fire.
5 mm
failure of Deep Drainage
Drum (2) D-4685 and 25 mm
11 IS11_HF_DDDII_L associated fittings/ pipings. Pool Fire
outcome of the released
Heptyl Formate will result in
150 mm
Pool Fire.
Hydrogenation Reactor
(Upper Part) R-4100 and 25 mm Jet Fire,
associated fittings/ pipings. Flash Fire
12 IS12_H2_HRUP_V An immediate outcome of the and
Fire and Explosion.
Release of 2-Ethylhexanal due
to leak/ catastrophic failure of 5 mm
Hydrogenation Reactor
(Bottom Part) R-4100 and 25 mm
associated fittings/ pipings. Jet Fire and
13 IS13_2EH_HRBP_L
An immediate outcome of the Pool Fire
released 2- Ethylhexanal will 65 mm
outcome will result in Pool 150 mm
Fire.

No. Description
ID Size Outcome(s)
Release of 2-Ethylhexanoic
Acid due to leak/ catastrophic 5 mm
failure of Oxidation Reactor R-
4400 and associated fittings/ 25 mm
pipings. An immediate Jet Fire and
14 IS14_2EHA_OR_L
outcome of the released 2- Pool Fire
Ethylhexanoic Acid will result 65 mm
Fire.
leak/ catastrophic failure of 2- 5 mm
Ethylhexanal Column (Upper
Part) T-4200 and associated 25 mm Jet Fire,
15 IS15_nBU_2EHCUP_V
released n- Butanal will result 65 mm Explosion
Fire and Explosion.
Release of Undecanol due to
5 mm
leak/ catastrophic failure of 2-
Ethylhexanal Column
(Bottom Part) T-4200 and 25 mm
16 IS16_UDOH_2EHCBP_ L associated fittings/ pipings. Pool Fire
Undecanol will result in Pool
150 mm
Fire.
Release of 2-Ethylhexanol due
to leak/ catastrophic failure of 5 mm
2-Ethylhexanol Column
(Upper Part) T-4300 and 25 mm Jet Fire,
IS17_2EHOH_2EHCUP associated fittings/ pipings. Flash Fire
17
_V An immediate outcome of the and
released 2- Ethylhexanol will 65 mm Explosion
Fire and Explosion.

No. Description
ID Size Outcome(s)
Release of Undecanol due to
5 mm
leak/ catastrophic failure of 2-
Ethylhexanol Column
(Bottom Part) T-4300 and 25 mm
18 IS18_UDOH_2EHCBP_ L associated fittings/ pipings. Pool Fire
Undecanol will result in Pool
150 mm
Fire.
5 mm
Acid due to leak/ catastrophic
failure of 2- Ethylhexanoic
Acid Stripping Column T- 25 mm
19 IS19_2EHA_2EHASC_ L 4450 and associated fittings/ Pool Fire
released 2-Ethylhexanoic Acid
150 mm
will result in Pool Fire.
due to leak/ catastrophic 5 mm
failure of 2-Ethylhexanoic
Acid Dividing Wall Column
25 mm Jet Fire,
(Upper Part) T-4500 and
Flash Fire
20 IS20_HF_2EDWCUP_V associated fittings/ pipings.
and
An immediate outcome of the
65 mm Explosion
Fire and Explosion.
Acid Dividing Wall Column 25 mm
IS21_2EHA_2EDWCBP (Bottom Part) T-4500 and
21 Pool Fire
_L associated fittings/ pipings.
outcome of the released 2-
Ethylhexanoic Acid will result 150 mm
in Pool Fire.

No. Description
ID Size Outcome(s)
5 mm
failure of Residue Storage
Tank TK-2920 and associated 25 mm
22 IS22_HF_RST_L fittings/ pipings. An Pool Fire
immediate and delayed 65 mm
Heptyl Formate will result in
150 mm
Pool Fire.
5 mm
Acid due to leak/ catastrophic
Acid Product Tank TK- 4610 25 mm
23 IS23_2EHA_2EPT_L and associated fittings/ Pool Fire
released 2-Ethylhexanoic Acid
150 mm
will result in Pool Fire.
Acid transfer line to TTLR and 25 mm
IS24_2EHA_2ETLTTLR associated fittings/ pipings. Jet Fire and
24
_L An immediate outcome of the Pool Fire
released 2-Ethylhexanoic Acid 65 mm
will result in Jet Fire while
delayed outcome will result 150 mm
in Pool Fire.
Acid line to storage and 25 mm
associated fittings/ pipings. Jet Fire and
25 IS25_2EHA_2ELS_L An immediate outcome of the Pool Fire
released 2- Ethylhexanoic 65 mm
Acid will result in Jet Fire
while delayed outcome will 150 mm
5 mm
H2 Offgas pipeline and
Jet Fire,
associated fittings/ pipings. 25 mm
Flash Fire
26 IS26_H2_H2OPIPE_V An immediate outcome of the
and
released Hydrogen will result 65 mm
Explosion
outcome will result in Flash
150 mm
Fire and Explosion.

No. Description
ID Size Outcome(s)
due to leak/ catastrophic 5 mm
failure of Residue transfer line
to storage and associated 25 mm
fittings/ pipings. An Jet Fire and
27 IS27_HF_RTLS_L
immediate outcome of the Pool Fire
released Heptyl Formate will 65 mm
Fire.
Hydrogen line from Oxo-
Syngas and associated 25 mm Jet Fire,
28 IS28_H2_HLOG_V
Fire and Explosion.
7.5.4.3 Frequency Analysis
Frequency analysis involves estimating the likelihood of each of the representative

release events highlighted in the hazard identification exercise. Frequency analysis
involves the following steps:
• Quantification of the frequency of initiating events (such as vessel rupture,

leakage, etc.) based on historical data; and
• Quantification of the frequency of various hazardous outcomes (such as fire,
explosion) through Event Tree Analysis, which is used to describe and
analyse how, an initiating event can lead to various outcomes, depending
upon the nature and type of the release.
Release Frequencies for Equipment in the Plants
Generic failure rate data for equipment item have been taken from Offshore
Hydrocarbon Release Database and Guideline for Chemical Transport Risk Analysis
(CCPS, 1995). Table 7-28 summarizes the generic equipment failure data used in this
study.

Table 7-28 Equipment Failure Rates
Equipment Size Failure Rate
Pipeline(1) Full Bore 3.50E-06 per m per year
Tank Bund Fire(2) Large Bund Fire 6.00E-05 per tank per year
Catastrophic 6.00E-06 per tank per year
65mm 5.00E-06 per tank per year
Pressure Vessel(3)
Source:
1. Extracted from QRA for Existing ICS.
2. OGP – Storage Incident Frequencies Report, March 2010
3. UK HSE, Failure Rate and Event Data for use within Risk Assessment
It should be noted that the equipment listed above are not subjected to any lifting
operations once installed at the plant. Hence the possibility of failures due to lifting
operations is deemed not credible.
This generic failure data were derived from statistical analysis of historical accident
data from the chemical industry as a whole and take no account of the current safety
engineering standards which are generally higher than the historical average.
Furthermore, no account was taken of clients’ engineering design standards nor
safety management systems. The data can be considered as conservative for the
purposes of assessment.
Ignition Probabilities
The probability of ignition depends on the availability of a flammable mixture, the

flammable mixture reaching an ignition source, and the type of ignition source
(energy, etc.). The possible ignition sources on the facility include:
• Hot work;
• Faults in electrical equipment;
• Faults in rotating equipment;
• Ignition caused by combustion engines/ hot surfaces;
• Automatic ignition in the event of a fracture/ rupture;
• Static electricity; and
• Lighting.
According to Cox, Lees and Ang (2000) also contained in Frank P. Lee’s Loss
Prevention in the Process Industries), generic ignition probabilities are given in
Table 7-29.

Table 7-29 Generic Ignition Probabilities
Probabilities of Ignition for Release Rate Categories
Scenario
0.1 to 1.0 kg/s 1.0 to 50 kg/s > 50 kg/s
Gas Leak 0.01 0.07 0.3
Oil / Condensate Leak 0.01 0.03 0.08
Depending on the time of ignition after release, the ignition can be “immediate
ignition” or “delayed ignition”. The following assumptions have been made for
distribution of overall ignition probability into immediate and delayed ignition
(Table 7-30):
Table 7-30 Immediate and Delayed Ignition Probability Distribution

Release Rate (kg/s) Immediate Ignition Delayed Ignition
0.1 to 1.0 0.1 0.9
1.0 to 50 0.5 0.5
> 50 0.6 0.4
The probability of explosion depends on factors such as location of leak source, gas
concentrations (presence of vapour clouds), location and energy of ignition sources,
area geometry, and ventilation of the area and equipment congestion. Cox, Lees and
Ang (2000) provides probabilities for explosion used in the assessment in lieu of the
detailed information required for estimation (Table 7-31).
Table 7-31 Probability of Explosion Given Gas Cloud Ignition

Release Rate (kg/s) Probability of Explosion (Given Ignition)
0.1 to 1.0 0.04
1.0 to 50 0.12
> 50 0.3
7.5.4.4 Event Tree Analysis
Event tree analysis involves taking each initiating event through a defined sequence
of events to determine the likelihood that an associated hazardous outcome will
occur. Such event trees will take into account the necessary conditions for the
hazardous outcome to occur, such as ignition.
By assigning probabilities to each branch of the event tree, the final frequency of each
outcome can then be established. The frequency of occurrence and probabilities of
the initiating events develops to that outcome. The consequences associated with
each of the hazardous outcomes can then be evaluated.
The event frequencies can be obtained by applying the ignition probabilities above
to event tree as shown in Charts 7-22 to 7-25.

Chart 7-22 Event Tree Model for Small, Medium, and Large Release of
Flammable Liquid > 2 bar
Chart 7-23 Event Tree Model for Catastrophic Release of Flammable

Liquid > 2 bar

Chart 7-24 Event Tree Model for Small, Medium, Large and Catastrophic
Release of Flammable Liquid < 2 bar
Chart 7-25 Event Tree Model for Small, Medium and Catastrophic Release
of Flammable Gas
7.5.4.5 Consequence Analysis
This stage of the QRA involves the determination of the impact of each of the
identified hazardous outcomes on the surrounding population. The following

hazard zones have been analyzed via consequence modeling. The criteria for each
hazard zone are as Table 7-32.
Table 7-32 Hazard Zones Criteria

Hazard
Hazard Effects on Human Effects on Property
Criteria
Thermal radiation limit
4 kW/m2 below which fatalities are No damage.
unlikely.
Thermal Radiation Minimum energy
(Jet Fire, Pool Fire, 12.5 required for piloted
Significant injury.
Fireball) kW/m2 ignition of wood, melting
of plastic tubing
37.5 100% fatality probability Failure of steel structures
kW/m2 for a 30 second exposure. within 30 minutes
100% fatality probability if
personnel outdoor is
Flash Fire LFL No damage.
engulfed within LFL
envelope (Reference 3).
Minor damage (windows
0.5 psi No fatalities.
broken)
Overpressure from
Moderate damage (pipe
explosion 2.0 psi 20% fatalities
deformation)
5.0 psi 50% fatalities Heavy damage.
Models Used
Software package EFFECTS from GEXCON has been used for the calculation of
consequence effects for all events.
Consequence analysis was carried out for identified outcome events, including
release rates, characterizing flames and thermal radiation ranges and estimate
dispersion distances.
Events
Fire and explosion events have been considered for further evaluation. Jet fire
scenarios (due to immediate ignition) have been modelled (deemed to give greater
consequence distance regardless of the total mass released), as a pressurized release
may be ignited and hence the consequence of a fire event in this particular scenario
is deemed more likely to take place within the confined area of the plant.
The consequence modelling is performed on a conservative basis to ensure risk is not

underestimated. For example, the maximum inventories of hazardous substances in
vessels, are used together with worst case process conditions, and releases are
modelled based on initial maximum (rather than average) release rates; no account

taken of site drainage/ emergency spill containment systems to limit the spread of
liquid releases etc., using published computer models that are inherently
conservative.
a) Pool Fire
Pool fire is a result from the ignition of flammable liquid spills. Upon spillage,
the liquid draws energy from the ground and surrounding air, to form a
flammable vapour/ air layer close to the liquid surface. The thickness of this
vapour/ air layer is dependent on the flash point of the spilt liquid.
If the spill releases insufficient fuel to fill the bund area or the spill is
unconfined, the pool will spread with gravitational forces pushing down on
it and forcing it outwards at the edges. Spreading will stop when equilibrium
is reached between the gravitational forces, frictional forces and surface
tension forces acting on the spreading liquid (the latter two forces resisting
pool spread). The pool thickness and hence surface area are therefore
dependent on the point at which this equilibrium is reached. For pools that
fill the bund or containment area, the pool surface area is fixed, with the depth
of liquid varying according to the volume of liquid spilled.
Upon ignition, it is the vapour layer above the liquid pool that burn,
generating heat that in turn causes further evaporation of liquid (i.e., the fire
becomes self-generating). Since burning only occurs at the surface of the pool,
the radiant heat effect of a pool fire is dependent on the volume of fuel spilt,
the size of the bund/containment area and the burning rate of the fuel.
Hazards arising from pool fires are primarily due to thermal radiation.
b) Jet Fire
In the event of a continuous pressurised release of either gas or liquid or two-

phase fluid, a jet of fluid will form. A jet or spray fire is a turbulent diffusion
flame resulting from the combustion of a fuel continuously released with
some significant momentum in a particular direction or directions. Jet fire can
arise from releases of gaseous, flashing liquid (two phase) and pure liquid
inventories.
The primary concern for jet fires is that of engulfment and high thermal
radiation flux. Normally jet fires should be distinguished as being either
horizontal or vertical jets. Horizontal jets have the possibility of impacting
upon other structures and being deflected. This process gives rise to a loss of
momentum and substantial entrainment which enhances the formation of a
flammable cloud and hence the potential for an
unconfined explosion.

The properties of jet fire depend on the fuel composition, release conditions,
release rate, release geometry, direction and ambient wind conditions. Low
velocity two-phase releases of condensate material can produce ‘lazy’, wind
affected buoyant, sooty and highly radiative flames similar to pool fire.
c) Flash Fire
Following a vapour, a gas cloud (which is heavier than air) will form, initially
located around the release point. If this cloud is not ignited immediately, it
will move with the wind and be diluted as a result of air entrainment.
The principal hazard arising from a cloud of dispersing flammable material

is its subsequent (delayed) ignition, resulting in a flash fire or vapour cloud
explosion. Large scale experiments on the dispersion and ignition of
flammable gas clouds show that ignition is unlikely when the average
concentration is below the Lower Flammability Limit (LFL). Therefore, the
following critical hazard distances were calculated to determine the
hazardous extent of the clouds:
• Maximum distance to the LFL and ½ LFL of the cloud;

• Maximum crosswind LFL and ½ LFL distance of the cloud; and
• Maximum upwind LFL and ½ LFL distance of the cloud.
It is considered that there is no probability for escape within the flammable

limits of a flash fire. Therefore, a fatality probability of 100% of persons
present within the flammable cloud (as defined by the distances above) is
assumed for flash fire.
d) Vapor Cloud Explosion (VCE)
Explosion occurs when a sufficient amount of flammable material in gas or

vapour phase within the explosive limit (LEL, UEL) is ignited. Ignition of
vapour cloud with flammable mass less than the threshold value may result
in a flash fire and subsequently jet fire for continuous source. The most
damaging effects of an explosion come from its blast overpressure. An
explosion is the sudden release of tremendous energy. The intensity of
explosion depends on the rate of energy release.
Tabulation of Consequence and Frequency of All Possible Accident Scenarios
This section presents the results of the consequence modelling performed for the
failure cases identified in the hazard identification. All consequence results and

frequency results can be referred in the Quantitative Risk Assessment in Appendix
H.
7.5.4.6 Risk Criteria
This section presents the risk tolerability criteria used in this study as stated in the
Risk Assessment Guidelines from DOE.
• The 1 x 10-5 fatalities/person per year individual risk contour should not
extend beyond industrial developments; and
• The 1 x 10-6 fatalities/person per year individual risk contour should not
encompass involuntary recipients of industrial risks such as residential areas,
schools, hospitals and places of continuous occupancy.
7.5.4.7 Risk Summation
Risk summation involves combining the frequency of a given event outcome with its
associated consequences to determine the individual risk levels associated with the
facility.
For the purpose of this study, risks evaluated are reported in terms of Individual Risk
(IR). Individual risk may be defined as the frequency of fatality per individual per
year due to the realization of specified hazards.
The results of risk summation are presented in terms of IR which, in the context of
the DOE Risk Guidelines, is defined as the risk of fatality to a person in the vicinity
of a hazard. This includes the nature of the fatality to the individual, the likelihood
of the fatality occurring, and the period of time over which the fatality might occur.
The individual is assumed to be unprotected and to be present during the total time
of exposure (i.e. 24 hours a day, every day of the year). The individual risk value, Ri,
at a particular distance, i, due to the occurrence of a particular event outcome, j, is
calculated by the following equation:
Ri = Σfeo,j.Pfat,i,j.Pweather,j, where:
feo,j is the frequency of event outcome j obtained from event tree analysis and
historical data;
Pfat,i,j is the probability of fatality at distance i produced by event outcome j from
consequence analysis; and
Pweather,j is the probability of the weather conditions required to produce the event
outcome at j (from meteorological data, 1 for weather independent event outcomes).

The individual risk (IR) profile for the site under study is calculated via
RISKCURVES (software). It is represented as a function of distance from the source
of potential risk upon the surrounding environment. Risk summation involves
combining the frequency of a given event outcome j with its associated consequences
to determine the IR levels associated with the site.
Based on IR contour in Chart 7-26, both the 1x10-5 risk contour and 1x10-6 risk contour
extend beyond the proposed Project site boundary, but remains within the ICS
compound and do not encompass involuntary recipients of industrial risks such as
residential areas, schools, hospitals, and places of continuous occupancy, etc. These
results are in compliance of the requirements stipulated by the DOE risk criteria.
The risk remains largely onsite hence, the operation of the proposed unit does not
pose a threat to nearby residential areas. The risk posed offsite (post operation of this
proposed project) remains the same as the risk posed by the existing facilities.

Chart 7-26 Individual Risk (IR) Contour

7.5.4.8 Salient Findings
The credible scenario consequences assessed does not reach involuntary recipients
of industrial risk surrounding the project, which is in compliance with DOE’s risk
acceptance criteria.
IR Contours:
• The 1 x 10-5 per year IR contour of the proposed project remains within the
established industrial development, i.e. Gebeng Indstrial Estate (GIE); and
• The 1 x 10-6 per year IR contour of the proposed project remains within the
established industrial development, i.e. Gebeng Indstrial Estate (GIE) only
and do not encompass involuntary recipients of industrial risks such as
residential areas, schools, hospitals, and places of continuous occupancy, etc.
The above results are in compliance of the requirements stipulated by the DOE risk
criteria.
It should be noted that the risks have been assessed on a conservative basis, both in
terms of consequences (e.g. use of the maximum inventories of hazardous substances
in vessels, worst case process conditions, releases are modelled based on initial
maximum (rather than average) release rates, no account taken of site drainage/
emergency spill containment systems to limit the spread of liquid releases etc. using
published computer models that are inherently conservative), and frequency – i.e. no
account has been taken of project site safety systems (e.g. isolation valves, detectors),
operator intervention to prevent or minimise releases and no credit has been taken
to account for the site Safety Management System.
A worst case scenario (WCS) is the scenario which entails the farthest consequence
distance amongst all the scenarios irrespective of the frequency, while a worst case
credible scenario (WCCS) is a credible scenario (with event frequencies > 1 × 10-6 per
year) with furthest consequence distance.
• The WCS for fire event is pool fire arising from the catastrophic release of
Hexanal Buffer Drum D-4230, which operates at 50˚C and 0.7 barg pressure.
This resulted in the 37.5 kW/m2 heat radiation hazard zone (that corresponds
to a radiation intensity sufficient to cause up to 100% fatalities and damage
process equipment) of up to 32.00 m. The 12.5 kW/m2 and 4 kW/m2 heat
radiation hazard zone (that typically corresponds to a radiation intensity to
cause up to 50% fatalities and damage process equipment; and 3% fatalities
and below which no injuries or damage would be expected) extends a
maximum of 55.00m and 86.00 m, respectively. Refer to Appendix H for the
WCS contour.

• The WCCS for fire event is pool fire arising from the medium release of
Residue Storage Tank TK-2920, which operates at 44˚C and 0.02 barg pressure.
This resulted in the 37.5 kW/m2 heat radiation hazard zone (that corresponds
to a radiation intensity sufficient to cause up to 100% fatalities and damage
process equipment) of up to 26.00 m. The 12.5 kW/m2 and 4 kW/m2 heat
radiation hazard zone (that typically corresponds to a radiation intensity to
cause up to 50% fatalities and damage process equipment; and 3% fatalities
and below which no injuries or damage would be expected) extends a
maximum of 43.00m and 62.00 m, respectively. Refer to Appendix H for the
WCCS contour.
• The WCS for explosion event originates from the vapour cloud explosion
(VCE) resulting from a delayed ignited release of Heptyl Formate due to
catastrophic release of 2-Ethylhexanoic Acid Dividing Wall Column which
operates at 113˚C and 250 barg pressure. This result in a 0.2068 bar explosion
overpressure hazard zone (where extensive damage and fatalities are to be
expected) extends up to 105 m but remains within the industrial area. Refer
to Appendix H for the WCS contour.
7.5.5 Water Quality
Wastewater Treatment Plant
The operation of the Project will generate wastewater that will be treated at the
wastewater treatment plant (WWTP). The average generation of wastewater from
the Project is 0.04 m3/h which makes up a small portion of current total generation
of 262 m3/h (refer Section 5.3.4). The WWTP is designed to treat process wastewater
and sewage generated within the ICS complex (refer to Section 5.3.4, Table 5-5). The
final treated effluent quality is treated to meet Standard B of the Environmental
Quality (Industrial Effluent) Regulation 2009. Accidental discharge of untreated
wastewater may cause water pollution.
The sewage generated during operational phase is expected to increase as additional

five personnel will be appointed. The sewage will be channeled to an existing
sanitary pit prior to discharge to WWTP for further treatment. The sanitary pit is
equipped with level sensor and pump, where once the waste reaches certain level, it
will be pumped out to WWTP. Hence, the sanitary pit capacity is adequate to receive
additional sewage generation from the operational stage of Project.

Accidental Discharge or Spillage of Scheduled Wastes
The plant operation is expected to generate scheduled waste (such as spent

lubricating and hydraulics oils) during maintenance and other waste material (such
as spent catalyst) from plant operation. Improper handling during storage, transport,
and disposal of these material may cause accidental discharge or spillage, thus
contaminating the and waterways. However, the impacts are expected to be minimal
with the implementation of mitigation measures and good housekeeping practices
(refer Section 8.4.6).
7.5.5.2 Assessment
Impact Assessment
To assess the impacts of effluent discharge from the WWTP on receiving waterways,
a mixing model (refer to Section 7.4.3.2) was applied for the following scenarios:
• Scenario 1 (Normal)
WWTP discharge meets Standard B limit of the Environmental Quality
(Industrial Effluent) Regulation 2009 during 7Q10 low flow conditions.
• Scenario 2 (Worst Case)

Raw effluent discharged from WWTP during 7Q10 low flow conditions.
For this estimation, the following assumptions and criteria were made:
• Effluent discharge from WWTP and receiving waterbody is assumed to be

completely mixed at the discharge/confluence points;
• Pollutants of concern are biochemical oxygen demand (BOD), chemical
oxygen demand (COD), and total suspended solids (TSS);
• Based on the WWTP mass balance, ammoniacal nitrogen (NH3-N) will be
discharged at 3.7 mg/L for both scenarios;
• BOD is treated as conservative pollutant; no chemical formations, however,
it is assumed that the biodegradability of BOD, k = 0.23 day;
• NH3-N is treated as conservative pollutant; no chemical formations, however,
it is assumed that the biodegradability of NH3-N, k = 0.13 day;
• Other point/diffuse sources along and leading into the receiving water
bodies were not considered.
The flow of effluent from WWTP to Sg. Balok is illustrated in Chart 7-27.

Chart 7-27 Diagram on Discharge Flow from Project Site during
Operational Stage

Table 7-33 Mixing Model Input for Water Quality Assessment during Operational Stage
Receiving Upstream Flowrate Upstream concentration Discharge Flowrate Discharge Concentration
Location Parameter
Waterway (m3/s) (mg/L) (m3/s) (mg/L)
Scenario 1 - WWTP discharge meets Standard B limit of the EQ(Industrial Effluent) Regulation 2009 during 7Q10 low flow conditions
BOD 23 9
COD 129 65
W2 PKNP Drainage 0.153 0.094
TSS 65 22
NH3-N 1.8 0.1
BOD 12 6
COD 77 42
W3 Sg. Balok 0.443 2.713
TSS 38 23
NH3-N 0.7 0.1
BOD 7 6
COD 47 77
W4 Sg. Balok 3.155 2.713
TSS 25 106
NH3-N 0.1 1.0
Scenario 2 Untreated effluent discharged from WWTP during 7Q10 low flow conditions
BOD 424 9
COD 1,221 65
W2 PKNP Drainage 0.153 0.094
TSS 76 22
NH3-N 1.8 1.1
BOD 151 6
COD 455 42
W3 Sg. Balok 0.443 2.713
TSS 42 23
NH3-N 0.7 0.1
BOD 26 6
COD 100 77
W4 Sg. Balok 3.155 2.713
TSS 26 106
NH3-N 0.1 1.0

Assessment Results
The mixing model results in Table 7-34 and Table 7-35 shows the changes in BOD,
COD, TSS, and NH3-N for both Scenario 1 and 2. The discharge from the WWTP will
enter the PKNP drainage.
In Scenario 1, mixing model shows BOD level in PKNP drainage (W2) is predicted
to increase from 9 mg/L (Class IV) to 18 mg/L (Class V) during 7Q10 low flow event.
BOD level in Sg. Balok (W3) is predicted to increase from 6 mg/L (Class III) to 7
mg/L (Class IV) during 7Q10 low flow event. The increase in 1 mg/L, despite
resulting in change of class of water quality is expected not to disturb the beneficial
uses downstream. The BOD level at W4 is predicted to remain at 6 mg/L during
7Q10 low flow event.
COD level is expected to increase from 65 mg/L (Class IV) to 104 mg/L (Class V) in
PKNP drainage (W2) during 7Q10 low flow event. At Sg. Balok (W3), COD level is
predicted to increase from 42 mg/L to 47 mg/L while remaining within Class III
limit of NWQS during 7Q10 low flow event. At Sg. Balok (W4), COD level is
predicted to change from 77 mg/L to 61 mg/L where the COD level remains in Class
IV limit of NWQS.
Mixing model shows TSS level in PKNP drainage (W2) is predicted to increase from
22 mg/L (Class I) to 49 mg/L (Class IIA/B) during 7Q10 low flow event. After
sedimentation, the impact WWTP discharge towards Sg. Balok is expected to be
minimized. At Sg. Balok (W3), TSS level is predicted to increase from 23 mg/L to 25
mg/L while still remaining within Class I limit of NWQS. TSS level at W4 is
predicted to change from 106 mg/L to 62 mg/L during 7Q10 low flow event where
the predicted concentration does not exceed baseline conditions.
NH3-N level in PKNP drainage (W2) is predicted to increase from 0.1 mg/L (Class I)
to 1.1 mg/L (Class IV) during 7Q10 low flow event. As it flows downstream, the
impact of WWTP discharge on NH3-N level in Sg. Balok is predicted to be minimal.
At Sg. Balok (W3), NH3-N level is predicted to remain unchanged at 0.1 mg/L (Class
I). At Sg. Balok (W4), NH3-N level is predicted to not exceed baseline water quality.
Sg. Balok is classified as Class III River in 2020 by DOE. The Project Site is located in
industrial area where the waterway receives discharge from multiple industrial
complexes. Furthermore, occurrence of 7Q10 low flow incidents is low hence the flow
rate under normal conditions will be higher than flow rate used for the assessment.
In Scenario 2, the BOD level at all locations is predicted to deteriorate to Class V

when receiving raw effluent during 7Q10 low flow event. COD level at W2 and W3
is predicted to deteriorate to Class V during 7Q10 low flow event. At W4, COD level
is predicted to increase from 77 mg/L to 89 mg/L while remaining withing Class IV
limit of NWQS.

TSS level at PKNP drainage (W2) is predicted to increase from 22 mg/L (Class I) to
56 mg/L (Class III) during 7Q10 low flow event. At W3, TSS level is predicted to
increase from 23 mg/L (Class I) to 26 mg/L (Class IIA/B) during 7Q10 low flow
event. TSS level at W4 is predicted to change to 63 mg/L from 106 mg/L where the
concentration falls within Class III limit of NWQS.
NH-3-N level in Scenario 2 is predicted to be same as reported in Scenario 1 as the

raw effluent contains 3.7 mg/L of NH3-N. The NH3-N level in raw effluent is lower
than prescribed limit of 20.0 mg/L.
The likelihood of Scenario 2 event to occur is minimal as Project Proponent will

ensure all best management practices related to WWTP are performed properly
(refer to Section 8.4.6).

Parameter Affected Waterway Location Changes in Water Quality
Baseline Predicted Change
BOD level changes from
PKNP Drainage W2 9 18 +9
Class IV to Class V
BOD level changes from
BOD W3 6 7 +1
Class III to Class IV
Sg. Balok
BOD level does not exceed
W4 6 6 0
baseline conditions
COD level changes from
PKNP Drainage W2 65 104 + 40
Class IV to Class V
COD W3 42 47 +5 COD level does not exceed
Sg. Balok
W4 77 61 - 16 baseline conditions
TSS level changes from

Class I to Class IIA/B
TSS W3 23 25 +2 TSS level does not exceed
Sg. Balok
W4 106 62 - 44 baseline conditions
NH3-N level changes from

PKNP Drainage W2 0.1 1.1 + 1.0
Class IIA/B to Class IV
NH3-N W3 0.1 0.1 0 NH3-N level does not
Sg. Balok
W4 1.0 0.5 - 0.5 exceed baseline conditions

Parameter Affected Waterway Location Changes in Water Quality
Baseline Predicted Change

BOD level change to Class
BOD W3 6 26 + 20
Sg. Balok V
W4 6 17 + 11
COD level changes from
Class IV to Class V
COD level change from
COD W3 42 100 + 58
Class III to Class V
Sg. Balok
COD level does not exceed
W4 77 89 + 12
baseline conditions
TSS level change from
Class I to Class III
TSS level changes from
TSS W3 23 26 +3
Class I too Class IIA/B
Sg. Balok
TSS level does not exceed
W4 106 63 - 43
baseline conditions
NH3-N level change from
PKNP Drainage W2 0.1 1.1 + 1.0
Class I to Class IV
NH3-N W3 0.1 0.1 0 NH3-N level does not
Sg. Balok
W4 1.0 0.5 - 0.5 exceed baseline conditions

7.5.6.1 Solid Wastes
Potential Impact
Solid wastes generated during operation phase of the Project will consist of mainly
domestic wastes, like food waste and office waste. Mismanagement of the solid
wastes will cause the following impacts:
• Decomposition of biodegradable domestic wastes will contribute to methane

emissions and cause seepage of organic materials into the soil and eventually
to the nearby waterways, causing an increase in BOD;
• Pest infestation of organic wastes;
• Illegal open burning will cause air pollution and health impacts;
• Unpleasant odour will occur due to mismanaged domestic wastes;
• Poor handling of inorganic wastes can lead to drainage blockage, leading to
flash floods; and
• Unsightly view of the area.
Assessment
There will be an addition of 5 new operation staff for the Project, in addition to the
existing 18 pax from the existing 2-EHAcid Plant (Plant I). Hence, the estimated solid
waste generation during the operation stage is as detailed in Table 7-36.
Table 7-36 Estimated Quantities of Solid Wastes During Operation Stage

Estimated
Potential Solid Wastes Waste Generation
Factor Quantity
Generated Rate
(kg/day)
Domestic wastes
18 pax 0.41 kg/capita/day 7.38
(Existing staff)
Domestic wastes
5 pax 0.41 kg/capita/day 2.05
(New staff)
Total 9.43
Source: JPSPN, 2012
With that, the impact from solid waste generated during operation stage from the
Project is anticipated to be low since the increase in quantity of solid waste generated
is only 2.05 kg/day. Nonetheless, best management practices for solid wastes will be
recommended and further elaborated in Section 8.4.7.1.

7.5.6.2 Scheduled Wastes
Potential Impact
During the operation stage, spent catalysts will be generated from the production
process. Other than that, there will also be maintenance of machinery and equipment
during the operation stage. There may also be a slight increase in the sludge
production from the wastewater treatment system since a 0.04m3/h of wastewater
from the Project will be treated in the wastewater treatment system.
The potential impacts from mismanagement of the scheduled wastes generated is as

may include:
• Soil and groundwater contamination due to potential leaching and seepage;

• Degrade surface water quality if leaked into the waterways;
• Cause potential harm to the existing aquatic life in Sg. Balok; and
• Cause potential adverse health impacts towards human receptors nearby the
Project site.
Assessment
The estimated maximum quantity of the potential scheduled wastes with their
respective codes and sources are as listed in Table 7-37.
Table 7-37 Estimated Maximum Quantity of Potential Scheduled Wastes

Generated During Operation Phase
Maximum
Current
SW Quantity
Code Generated
Method
(MT/yr)
Existing 2-EHAcid Plant (Plant I) (Table 6-6)
Production
Process Send to
1 SW202 Waste catalysts (Selective 2.3 Kualiti Alam
process)
Sludges containing
Send to
2 SW204 0.16 Kualiti Alam
Sdn. Bhd.
vanadium and
beryllium
Send to
3 SW305 Spent lubricating oil Maintenance 0.038 Kualiti Alam
Sdn. Bhd.

Maximum
Current
SW Quantity
Code Generated
Method
(MT/yr)
Send to
4 SW306 Spent hydraulic oil Maintenance 0.0031 Kualiti Alam
Sdn. Bhd.
5 SW409 Maintenance 0.418
6 SW422 scheduled and non- Maintenance 1.9 Kualiti Alam
Shared
7 SW429 discarded or off- 0.9 Kualiti Alam
laboratory
Total (Plant I) 5.7191
Project Site (2- EHAcid Plant II)
Waste from electrical Send to
Maintenance
1 SW110 and electronic 0.004(1) Kualiti Alam
or upgrading
assemblies Sdn. Bhd.
Production
Process Send to
2 SW202 Waste catalysts (Selective 2.3(2) Kualiti Alam
process)
Sludges containing
Send to
3 SW204 0.16(2) Kualiti Alam
Sdn. Bhd.
vanadium and
beryllium
Send to
4 SW305 Spent lubricating oil Maintenance 0.038(2) Kualiti Alam
Sdn. Bhd.
Send to
5 SW306 Spent hydraulic oil Maintenance 0.0031(2) Kualiti Alam
Sdn. Bhd.
6 SW409 Maintenance 0.418(2)
7 SW422 scheduled and non- Maintenance 1.9(2) Kualiti Alam

Maximum
Current
SW Quantity
Code Generated
Method
(MT/yr)
Shared
8 SW429 discarded or off- 0.9(2) Kualiti Alam
laboratory
Total (Plant II) 5.7231
Total (Plant I and Plant II) 11.4422
Note:
1. No e-waste generated by existing 2-EHAcid Plant I currently. Maximum quantity which may
potentially be generated from the Project is estimated based on the total amount of e-waste produced
within the entire premise in a year (Production area of 2-EHAcid Plant II is approximately 0.2% of the
developed area within ICS).
2. Based on the estimation of scheduled waste generation from Plant I.
3. Based on the mass balance for maximum 2-EHAcid production capacity of 36,000 MT/a (Table 5-3)
Based on the estimated quantity of the above scheduled wastes, majority of the
scheduled waste is made up of SW202, which is the waste catalyst that will be
disposed once in every four years. The properties of waste catalyst are assumed to
be the same as new catalyst. Hence, the toxicity and ecological information for the
catalyst (aluminium oxide) is referred and summarized in Table 7-38.
Table 7-38 Toxicity and Ecological Information

Toxicity and Ecological
Description
Information
Virtually nontoxic by inhalation
Acute toxicity Virtually nontoxic after a single ingestion
Virtually nontoxic after a single skin contact
Irritation Not irritating to eyes and skin
Respiratory/skin
No sensitizing effect
sensitization
Germ cell mutagenicity Mutagenicity tests revealed no genotoxic potential
The whole of the information assessable provides no indication
Carcinogenicity
of a carcinogenic effect
The results of animal studies gave no indication of a fertility
Reproductive toxicity
impairing effect
No indications of a developmental toxic/teratogenic effect
Developmental toxicity
were seen in animal studies
Specific target organ
Based on the available information, there is no specific target
toxicity (single
organ toxicity to be expected after a single exposure
exposure)
Aspiration hazard No aspiration hazard expected
There is a high probability that the product is not acutely
harmful to aquatic organisms. Based on long-term (chronic)
Ecotoxicity
toxicity study data, the product is very likely not harmful to
aquatic organisms.
Mobility Adsorption to solid soil phase is not expected

Toxicity and Ecological
Description
Information
Persistence and
Not applicable for inorganic substances
degradability
Bioaccumulation
Accumulation in organisms is not to be expected
potential
Source: BASF PETRONAS Chemicals Sdn. Bhd. (2022) – Refer to Appendix I for SDS of the catalyst
Based on the toxicity and ecological information, the waste catalyst is not expected
to cause any health impairing effects to living organisms. Nevertheless, the
recommendations and best management practices for scheduled wastes generated
during the operation stage will be discussed in Section 8.4.7.2.
7.5.7 Socio-Economic Assessment
The proposed project is an addition to the existing plant in operation. Opinions were
solicited from the respondents on the perceived impacts of this proposed project
from both negative and positive perspectives. These perceived impacts were
analysed by assessing the level of intensity of concern (if negative impact) and the
level of satisfaction (if positive impact). For each type of perceived impact, an average
impact score was computed.
Negative Impacts
Table 7-39 provides for the individual perceived negative impacts of the proposed
project during the operation phase. Almost all these perceived negative impacts have
clustered at the Moderate levels of concern ranging from mean scores ranging from
3.1 to 3.4. These notable negative impacts perceived are on:
• Air pollution from factory smoke (3.4)
• Odour pollution from factory (3.3)
• Public safety concern due to movement of lorries (3.2)
• Traffic jam from movement of lorries in-out of factory (3.2)
• Social unrest due to the presence of foreign workers (3.2)
But it should be noted that these perceived impacts did not reach mean scores of high
levels of concerns.

Table 7-39 Average Negative Impact Scores During Project Operation
Level of Concern
Mean
Concerns Very Low Moderate High Very
Score
Low (1) (2) (3) (4) High (5)
Air pollution from factory
1.2% 19.2% 27.1% 43.3% 9.1% 3.4
smoke
Odour pollution from
1.2% 22.7% 28.1% 40.4% 7.6% 3.3
factory
Water pollution due to
the discharge of liquid 0.7% 29.3% 32.0% 32.8% 5.2% 3.1
waste into rivers
Fire risk arises from plant
1.2% 30.5% 32.3% 32.0% 3.9% 3.1
operations
Noise from plant
1.7% 26.4% 31.8% 36.2% 3.9% 3.1
operation
Traffic congestion from
the movement of trucks in 0.2% 25.4% 30.5% 38.7% 5.2% 3.2
and out of the factory
Public safety from truck
0.5% 25.1% 28.1% 42.1% 4.2% 3.2
movement
Social unrest or
dissatisfaction of the
population due to the 0.2% 27.1% 30.5% 39.2% 3.0% 3.2
presence of foreign
workers
Factory waste / garbage
from illegally disposed of 0.2% 27.6% 33.0% 36.5% 2.7% 3.1
factories
Positive Impacts
Table 7-40 provides the list of perceived positive impacts of the proposed project
during operation phase. The overall average scores obtained for each of the
individual impacts were all clustered close to Mean Scores of 4 or High category
which imply that the community have high anticipations for the various perceived
impacts to occur. The impacts having scores of 3.6 to 3.9 are:
• Greater incomes from business and services offered (3.9)
• Increase in real estate value (3.9)
• Improvements in infrastructures (3.7)
• Improvements in public facilities (3.6)
It is important to reiterate that unlike the cases of perceived negative impacts, the
mean scores obtained for these positive impacts are all beyond Moderate levels (3)
instead are closely approaching high levels of anticipations (4) of receiving these
benefits.

Table 7-40 Perceived Positive Impacts During the Proposed Project
Operational Phase
Perceived Level of Benefit
Mean
Positive Impacts Very Low Moderate High Very Score
Low (1) (2) (3) (4) High (5)
Increase income to
surrounding businesses &
0.0% 2.7% 14.5% 68.7% 14.0% 3.9
services including house
rental
Increasing the value of real
0.7% 3.4% 20.7% 57.6% 17.5% 3.9
estate
Addition & improvement of
infrastructure e.g., road, 0.5% 5.9% 23.6% 61.6% 8.4% 3.7
electricity, internet & others
Encourage the provision of
public services such as 10.8
0.2% 24.1% 57.1% 7.6% 3.6
schools, clinics, recreational %
areas & others
Overall, quite a low proportion of the community felt that the proposed project
would be having negative impacts upon them with higher proportions having
positive expectations of the proposed project. The negative impacts would come
from dust and air pollution from the factory activities.
During the operation stage, there were generally very high frequencies perceiving
that there shall be increase in income opportunities for surrounding businesses and
services including housing rentals. Most employment opportunities would go to
existing workers at the current plant. It is anticipated that there would spill-overs to
the local communities in terms of income and business opportunities.
7.5.7.2 Assessment
The objective of the socio-economic assessment was to gather information on the

current socio-economic situations at both macro and micro levels i.e. at the mukim
of Sungai Karang and of residents within 5 km radius of the proposed Project site.
Specifically, the objectives are:

• To provide a background of current demography of the mukim where the
Project is located and of villages within 5 km of the Project.
• To identify the affected communities within the zone of influence of within
5km radius of the project site and collect baseline data to determine their
demographic and socio-economic profile.
• To assess the community’s perception towards the Project and to identify any
issues or concerns and perceived of the proposed project upon the
community.

• To propose mitigation measures to address the predicted social impacts.
Relevant suggestions from key stakeholders on resolving some of the
perceived impacts or issues will also be considered.
The socioeconomic assessment of the Project consists of the following studies:

i) Perception survey among local residents
ii) Focus Group Discussion (FGD) with local residents
iii) Engagement with Institut Latihan Perindustrian (ILP) Kuantan
iv) Engagement with Gebeng Industrial Support Group (GISG)
i) Perception survey among local residents
A perception survey was conducted among respondents from residential areas

identified within a zone of influence (ZOI) of 5-km radius surrounding the Project
stie from 23rd to 27th Marth 2022 (Plates 7-1 and 7-2).
Plate 7-1 Enumerator Interviewing Local Resident

Plate 7-2 Enumerator Interviewing Local Resident
A structure questionnaire was prepared which included various socio-economic

includes and to gauge local communities’ perception of the proposed Project. A total
of 406 respondents were interviewed to obtain a general profile of residents living
within the ZOI of the Project site.
The ZOI could be divided into three categories (Table 7-41):

• ZOI 1 (<1km radius of project site), where none of the residential areas are
located;
• ZOI 2 (1.1-3km radius of project site) involves two villages and the
respondents from this zone involved 40.6% of the total respondents surveyed;
and
• ZOI 3 (3.1-5.0km radius) involved seven villages and the samples took up the
remaining 59.4% of the total respondents.
Table 7-41 Distribution of Respondents Surveyed Among the Villages in the

ZOIs
Number of
Survey Locations ZOI % of total samples % by ZOI
samples
Taman Balok Perdana 2.0 (1.1-3km) 153 37.7%
40.6%
Taman Balok Makmur 2.0(1.1-3km) 12 2.9%
Kampung Berahi 3.0 (3.1-5km) 110 27.1%
Perumahan Balok Baru 3.0(3.1-5km) 32 7.9%
Kampung Seberang Balok 3.0 (3.1-5km) 30 7.4%
Kampung Balok Baru 3.0(3.1-5km) 49 12.1% 59.4%
Taman Balok Pelangi 3.0 (3.1-5km) 5 1.2%
Kampung Balok 3.0 (3.1-5km) 10 2.5%
Kampung Selamat 3.0(3.1-5km) 5 1.2%
Total 406 100.0% 100%

a) Community profile
A general profile of the respondents is provided in Table 7-42. There are

slightly more males than females. There are practically all Malays being
surveyed as indicated by the population breakdown. The age distribution is
well distributed with a large proportion from ages of 25 to 44 years old taking
up 57.9%. A majority of the respondents have full-time employment, with
many working in the private sector and the largest education category was
secondary schooling. A large portion of the respondents has 3-6 household
members with a household monthly income of RM2,001-4000/month, taking
51.5% of the respondents.
Table 7-42 General Profile of the Respondents Surveyed

No. Profile Statistic Value
1 Gender Mode Male (54.9%); Female (45.1%)
2 Age Mean 25-44 Years (57.9%)
3 Race Mode Malay (97.3%)
4 Employment Mode Full-time Private Sector (37.4%)
5 Education Mode Secondary school (60.8%)
6 Household Income Mode RM2,001-4,000/month (51.5%)
7 Household size Mode 3-6 members (75.2%)
More specifically, the distribution of the race of the respondents are

dominated by Malays (94.1%), followed by Bumiputra from Sabah (3.2%) and
Sarawak (1.0%) with Chinese and Indians both taking up 0.5% (Table 7-43).
The remainder other Malaysian citizen and non-citizens.
Table 7-43 Race Distribution of the Respondents

Race Percentage
Malay 94.1%
Bumiputra Sabah 3.2%
Bumiputra Sarawak 1.0%
Chinese 0.5%
Indian 0.5%
Other Malaysian citizen 0.2%
Non-Citizen 0.5%
Total 100.0%
The age distribution of the respondents is provided in Table 7-44. The ages
of the respondents are well distributed with the greater frequencies from
among the ages 25 to 44 years of age taking up 57.9%.

Table 7-44 Age Distribution of the Respondents
Age Distribution (years) Percentage
15 – 19 4.9%
20 – 24 6.2%
25 – 29 15.3%
30 – 34 13.3%
35 – 39 15.0%
40 – 44 14.3%
45 – 49 6.9%
50 – 54 10.3%
55 – 59 3.9%
60 – 64 5.4%
≥ 65 4.4%
Total 100.0%
The level of education of the sampled villagers is shown in Table 7-45. Only
1.23% of the sampled villagers have no formal education with another 6.65%
just up to primary school education. Some 60.84% have a secondary school
education, with the majority a medium secondary school education.
Meanwhile, 21.43% have seek further education of higher certificate of
education (STPM), matriculation and diploma, and 9.85% obtained university
education. The low proportions with no formal education and only primary
schooling may have a significant implication on the ability of locals to meet
the skill requirements of employment opportunities to be offered by the
proposed project which tend to have a high level of automation.
Table 7-45 Education Level of Respondents

Education Percentage
Pre-school 0.49%
Primary schooling 6.16%
Form three (SRP/PMR/PT3) 8.13%
Form Five (SPM) 52.71%
Pre-University (Matriculation/STPM/Diploma) 21.43%
University Bachelor’s Degree 7.39%
University Master’s Degree 1.23%
University PhD Degree 1.23%
No formal education 1.23%
Total 100%
The main employments are in the private sector (37.4%) and self-employment
(17.0%) with 6.9% in the public sector. (Table 7-46). The remaining
percentages comprised those who are unemployed (5.9%), housewives
(23.2%), students (4.9%) and retirees (4.7%).

Table 7-46 Employment Status of Villagers Surveyed
Status Percent
Unemployed 5.9%
Public sector employee 6.9%
Private sector employee 37.4%
Self-employed 17.0%
Pensioner 4.7%
Homemaker 23.2%
Students 4.9%
Total 100.0%
In general, a reasonable occupation distribution belongs to the management

and professional jobs comprising of managerial level, professionals, and
technical/semi-professionals that involved 4.9%, 8.9% and 20.9% respectively
(Table 7-47). There are also high proportions working as general workers
(11.1%), and clerk, sales and service (6.4%). The remaining working
households are involved in agricultural and livestock workers (2.5%) and
production various goods (7.1%), and arts and crafts products (1.0%). Yet, a
high percentage is currently not working (37.2%).
Table 7-47 Nature of Jobs Being Employed

Type Percent
Currently not working 37.2%
Management & Administration 4.9%
Professionals 8.9%
Semi-professional & technical 20.9%
Clerical, sales & service worker 6.4%
Agricultural & livestock worker 2.5%
Arts & Crafts 1.0%
Production of goods 7.1%
General labour 11.1%
Total 100.0%
The monthly household incomes of the responding villagers ranged widely

from those earning less than and equal to RM1,000/month to as high as more
than RM10,000 per month (Table 7-48). The highest income category belongs
to RM2,001-RM3,000/month with 25.9% and RM3,001-RM4,000/month with
25.6%. Reasonably high percentages have household incomes of RM1,001-
RM2,000/month and RM4,001-RM5,000 with 13.1% and 14.8% respectively.
Table 7-48 Distribution of Household Incomes Among

Community Surveyed
Income bracket Percent
≤ RM1,000 4.9%
RM1,001 - RM2,000 13.1%
RM2,001 - RM3,000 25.9%
RM3,001 - RM4,000 25.6%

Income bracket Percent
RM4,001 - RM5,000 14.8%
RM5,001 - RM6,000 8.9%
RM6,001 - RM7,000 1.7%
RM7,001 - RM8,000 1.7%
RM8,001 - RM9,000 1.0%
RM9,001 - RM10,000 1.7%
≥ RM10,001 0.7%
Total 100.0%
In general household size of the respondents range from as low as an

individual to as many as 13 members (Table 7-49). The household sizes with
higher frequencies are from 3 to 6 members together taking up 75.2% of the
respondents.
Table 7-49 Number of Household Members

Household members Percent
1 2.0%
2 8.1%
3 13.3%
4 22.9%
5 26.4%
6 12.6%
7 8.6%
8 1.2%
9 3.0%
10 1.2%
12 0.5%
13 0.2%
Total 100.0%
In terms of residential duration, the percentage frequency period living in the

existing villages have been quite widespread. Some 20.7% have only been in
resident for less than 10 years (Table 7-50). High percentages have stayed for
longer periods including 11-15 years with 9.4%, 16-20 years and 21 -25 years,
both with 11.1% have been living in their existing location. For much longer
residential durations, the percentages have been less than 10% each.
Table 7-50 Residential Duration at Existing Location

Years of Resident Percent
0–5 9.6
6 -10 11.1
11 -15 9.4
16 - 20 11.1
21 - 25 11.1
26 - 30 8.9
31 - 35 9.1

Years of Resident Percent
36 - 40 9.9
41 - 45 6.9
46 - 50 4.4
51 - 55 3.7
56 - 60 3.0
≥ 61 2.0
Total 100.0
From Table 7-51, it is clear that only 9.6% have only recently transferred to
their current residential areas. Among the residents having recently stayed in
these existing villages, high percentages, almost half are from Kuantan
Districts itself (4.4%) (Table 21). The rests are distributed thinly among
Terengganu state (2.5%) and from other districts in Pahang (0.2%). Other
proportions are from other states like Johore (0.7%), Kuala Lumpur (0.7%)
and Kelantan 0.5%), whereas other states involved very small proportion.
Table 7-51 Previous Residential Locations for Those Having Been

in Residence for Less Than 5 Years
Previous Residential Area Percentage
Kuantan District 4.4%
Other Districts in Pahang 0.2%
Terengganu 2.5%
Kelantan 0.5%
Johor 0.7%
Kuala Lumpur 0.7%
Selangor 0.2%
Sabah 0.2%
Perak 0.2%
Total 9.9%
b) Local Communities Awareness and Acceptance of the Project and Their

Perceptions of the Proposed Project
As for perception study, the communities were interviewed based on the

wisdom that whilst the proposed project would benefit the project proponent,
state and nation, but the social impacts could affect the population of the
immediate surroundings and visitors head on. The local communities would
bear these impacts, if any, due to their proximity to the proposed project site
to their homes. Besides, it is the concern of the immediate locals that must be
taken into consideration to ensure that a project is socially sound and
inclusive. Hence in the first place, it is necessary to gauge these stakeholders’
level of awareness and acceptance of the impending Project. These feedbacks
are crucial in determining the smooth implementation of the proposed project.
Hence, the questionnaire survey seeks the following information as well:

• local community’s awareness and acceptance of the project; and
• local community’s perceptions towards the Proposed Project.
Level of Project Awareness and Acceptance by the Local Communities
The level of awareness of the proposed project of the respondents are very
low. Overall, only 17.5% of the respondents are aware of the proposed project
to construct a 2-Ethylhexanoic Acid (2-EHAcid) at the existing Integrated
Chemical Site. The remainder of the respondents are not aware of the
proposed project and do not have knowledge of the proposed project.
Considering the low awareness level, the respondents were inquired as to the
popular means of conveying information on the project. The channel to
convey information on the proposed project is provided in Table 7-52. Social
media such as Facebook is the most popular channel and source of
information with 68.0%. But the traditional mass media e.g., newspaper has
still remained important with 54.7% recorded. This is followed by public
notice boards and advertisements with 30.3%. Community associations /
Residents Association / JKKK / ADUN with 19.2% being reported by the
respondents. The traditional engagement such as Public Dialogue, Briefing &
Engagement still are popular sources of information with 7.1%.
Table 7-52 Channel of Conveying Information on the Proposed Project

Channel Percent*
Mass Media e.g., Newspaper 54.7%
Social Media e.g., Facebook, WhatsApp, SMS 74.2%
Public notice board, advertisements 30.3%
Community associations 19.2%
Interested party and NGOs 2.5%
Public Exhibition 2.2%
Public Dialogue, Briefing & Engagement 7.1%
Not able to answer 18.0%
Note: * Does not add up to 100%, as some respondents have suggested multiple channels of
information delivery
The level of support of the proposed project, could be ascertained from the
frequency of responses in Table 7-53. 1.7% of the respondents did not support
the proposed project. But some 21.2%, 45.3% and 20.7% of the respondents
respectively provide moderate, high and very high support upon the
proposed project. Hence from a scale 0 (no support) to 5 (very high support),
a mean score of 3.66 was obtained which is close to a round numbered score
of 4, which is suggesting that a high level of support for the proposed project
has been provided.

Table 7-53 Level of Support of the Proposed Project
Level of Support Percent Approving
None (0) 1.7%
Very Low (1) 4.7%
Low (2) 6.4%
Moderate (3) 21.2%
High (4) 45.3%
Very High (5) 20.7%
Mean Score 3.66
Perceived Impacts of Existing Project
It is interesting to know the level of impacts that the existing project has upon
themselves or members of their households. Some 25.9% of the respondents
surveyed have the perceptions that indeed they have been affected by
existing project in operation. On the other hand, a large proportion of the rest
(74.1%) felt the existing project has not affected them at all. From amongst
those who have been affected, the manner that they are touched come about
in both positive and negative ways.
For those perceiving to be impacted positively have provided various forms

of advantages that they felt have occurred (Table 7-54). Up to 89.5% of the
respondents touched by the existing project in operation, have quoted
employment opportunities. This is equivalent to 23.2% of the total
respondents surveyed. These are followed by additional income
opportunities for local businesses and services with 49.5% of the respondents
affected by the existing project or 12.8% of the total samples surveyed. The
other reasonings are on potential rise in local real estate value and
improvements of public infrastructural services.
Table 7-54 Perceived Positive Impacts of Existing Project in Operation

Percentage Among
Percentage of
Impacts Samples Agreeing to
Total Samples
Proposed Project
Job opportunities to local populations 89.5% 23.2%
Raise incomes from surrounding
49.5% 12.8%
commerce and services
Raise local real estate value 25.7% 6.7%
Increase and improvement of
28.6% 7.4%
infrastructural facilities
Increase and improvement of public
21.9% 5.7%
services
Note: Column 2 provides the proportion from among the 105 respondents (25.9%) who have
been affected by the existing project whereas Column 3 refers to the proportion from among
all 406 respondents surveyed.

From those who are affected by the existing project in operation, they also
perceive that despite the advantages, there have been negative impacts. These
are as shown in Table 7-55. The major negative impact mentioned was from
dust and air pollution from the existing factory activities. This is perceived by
71.4% of the respondents who felt that they were affected by the existing
project. Despite the high percentage, this is equivalent to only 18.5% of the
total number of respondents surveyed. The other high concerns are on noise
from factory operations and odour pollution from factory operations that are
mentioned by 30.5% and 21.9% respectively of respondents who felt that they
affected by the existing project. In terms of the whole respondents surveyed,
the proportions were equivalent to 7.9% and 5.7% respectively of the total
respondents surveyed. The other major concerns are on vibrations and
cracking of residential buildings, road safety risk from rise in traffic, traffic
congestion and pollution of rivers from the release of wastewater.
Table 7-55 Form of Negative Impacts Perceived from the Existing

Project in Operation
Percentage Among
Percentage of
Impacts Samples Affected by
Total Samples
Existing Project
Dust and air pollution from proposed
71.4% 18.5%
factory activities
Noise from factory activity & traffic 30.5% 7.9%
Vibration & cracking of residential
13.3% 3.4%
buildings
Risk of fire from factory 6.7% 1.7%
Traffic congestion 11.4% 3.0%
Road safety risk from rise in traffic 12.4% 3.2%
Pollution of rivers from wastewater
10.5% 2.7%
release
Flash flood 1.0% 0.2%
Rise in crime 1.0% 0.2%
Vector diseases from factory areas 1.9% 0.5%
Odour pollution from factory 21.9% 5.7%
Influx of foreign workers 4.8% 1.2%
Note: Column 2 provides the proportion from among the 105 respondents (25.9%) who have
been affected by the existing project whereas Column 3 refers to the proportion from among
all 406 respondents surveyed
Based on the perception survey, the mitigation measures at the two project
development stages will be discussed in Sections 8.3.5 and 8.4.8. A number
of potential mitigation measures were suggested and posted to the
respondents during the survey to obtain their feedbacks. This is done with
the intention to ensure that these recommendations are inclusive with
consultation of the local communities.

ii) Focus Group Discussion (FGD) With Local Residents
Focus Group Discussion (FGD) is often organized as a means of public engagement

with relevant stakeholders with the following objectives:
• Gauging stakeholders’ reactions to the proposed Project
• Identifying any problems directly or indirectly related to the proposed Project
• Seek recommendations to reduce the effects that would arise when the
proposed Project is approved
A physical FGD session was conducted with the residents surrounding the Project
site on 21 May 2022. The attendance of the FGD comprised of:
• Community: 5 members of Jawatankuasa Kebajikan dan Keselamatan Kampung
(JKKK), 1 member of SMK Chengal Lempong Parent-Teacher Association, 1
member from SMK Pelabuhan and 4 nearby residents
• NGO: 1 member of the Malaysian Natural Society (MNS)
• Majlis Perbandaran Kuantan (Lestari Jaya): 1 urban planning officer
• Project Proponent: 4 personnel
• EIA Consultant: 6 personnel
The FGD first began with a presentation from ERE Consulting Group, giving a brief
background as well as environmental impacts and mitigation measures of the Project
(Plate 7-3).
Plate 7-3 Briefing about the Project to the Local Residents

Plate 7-4 Feedback Session Conducted During the FGD with Local Residents

After the project briefing session, feedbacks were solicited from the local residents whereby they raised their concerns and asked further questions
regarding the proposed Project (Plate 7-4). Table 7-56 summarizes the issues raised and addressed during the FGD.
Table 7-56 Feedbacks Received During FGD With Local Residents

No. Participants Issues raised
Mansor Mokhtar
Ketua Kampung, Kg. Balok
i. Job opportunities for local community be provided.

ii. Corporate Social Responsibility programmes have to be activated again by BASF PETRONAS
1
Chemicals especially after the inactivities during the long MCO for the past two years
iii. Sungai Balok plays an essential role to the socio-economy of local population especially to fishermen.
i. Gebeng Industrial Estate has been in the mainstream news because of the presence of Lynas Plant.
Lynas has attracted national attentions so much so that many interests have been raised by social
activists. Many of these parties are not local. According to the Ketua Kampung, household members
Sheikh Zul Sheikh Sulaiman in the local communities may not have the high levels of concern as depicted by these non-local parties.
Ketua Kampung, Chengal Lempong In fact, household members are currently involved working for many of the factories in the Gebeng
Industrial Estate and have benefited from the various industrial projects
ii. As for the proposed Project, the Ketua Kampung is more focused on how to ensure any job openings
will be given priority to actual local household members, not to other Malaysians, who may be using
2
their relative’s addresses in making job applications. Many jobs in Lynas have not been obtained by
residents of local villages such as from Kampung Chengal Lempong. Balok has approximately 50,000
inhabitants and many are needing jobs. Suggestions are given so that the Human Resource
Development Office of BASF PETRONAS Chemicals:
• To inform the office of local community village heads of job availability to ensure local
households are aware and to facilitate their job applications.
• To seek the inputs or verification from the local community village heads of the authenticity of
the purported job applicants claimed to be local.

Raised concerns on parents and school children of the school, especially whether the existing proposed
Afik M Noor
project site and transporting vehicle will use the same road that will be used by parents and school children
Member,
3 for transporting factory waste for disposal. He has enquired whether the environmental impact assessment
PIBG Sekolah Menengah Chengal
(EIA) will look into the impacts of this matter and whether would the EIA report be made available to the
Lempong
public. To this the EIA consultant has replied in the affirmative
Sharifah Zuriana
Resident, Kg. Balok
She has raised a number of concerns:
i. On the risk of chemical pollution after plant construction to future generation especially school
4 children.
ii. Whether there will be 3 months or 6 months self-monitoring by the Project Proponent
iii. Requests that a complaint management mechanism be created to handle community grievances.
Mahadi Samsudin
Environment Department,
BASF PETRONAS Chemicals
Responded on the concerns raised by Pn. Sharifah
i. There are scheduled environmental monitoring and reporting in compliance to the EIA approval
5 conditions in place to be conducted by the Project Proponent.
ii. There will be continuous reading on air and water pollution under the Continuous Emission
Monitoring System

Athran Zuhail
Member, Malayan Nature Society
Raised on the concerns on traffic impacts, whether the 2-EHAcid raw materials and product be transported
6
by trucks will create any traffic hazards or impacts.
Responded on concerns raised by En. Athran:

Jumahdi Ramli i. The main raw material, ethylhexenal is produced on site and will be channelled directly to the
7 Senior Manager Operations, process, hence there will be no incoming transportation required for ethylhexenal
BASF PETRONAS Chemicals ii. Products will be pumped into either ISO tank trucks or drums
iii. The Project Proponent take note on the feedback on traffic impacts.
Mohd Hishamuddin
Urban Planning Officer,
Majlis Perbandaran Kuantan (Lestari
Jaya)
Highlighted the need of engagement with:
i. Residents, within 5km radius of the project site.
8 ii. Existing workers surrounding project site, for which the response is affirmative. He has suggested
that engagement be undertaken with the Gebeng Industrial Support Group comprising of the
managements of industrial plants within Gebeng Industrial Estate.

Tan Yen Chen
ERE Consulting Group
i. Responded on EIA data collections undertaken of air and water quality and whether there are
potential health risks, such as cancer to local community. Department of Environment and Health
Ministry, Malaysia (KKM) will vet through the health impact assessment section in the EIA report.
9 ii. No construction works yet until approvals of EIA report and other technical requirements are
obtained. It also depends on the decision of the Project Proponent to start construction.
iii. BASF PETRONAS Chemicals management would be encouraged to inform the Gebeng Industrial
Support Group of the intention of the proposed project.

iii) Engagement with Institut Latihan Perindustrian (ILP) Kuantan
A virtual engagement session was conducted with En. Wan Asmawi Wan Shariff,
the Deputy Director of Operations from ILP Kuantan on 13 May 2022 via Microsoft
Teams (Plate 7-5). Representatives from the Project Proponent were also present.
Plate 7-5 Engagement with ILP Kuantan
During the session, there were a few main concerns raised by En. Wan Asmawi:
a) The expected air impacts from the Project
• The Consultant has responded that air quality modelling is in the
progress, and the air quality impacts will be studied in the EIA.
• En. Mahadi from the Project Proponent’s Environmental Department,
also highlighted on the stringent monitoring requirements to be
conducted during the operation stage to ensure that the emission quality
is within the standard limits.
b) There were previous cases of bad odour in the mornings, possibly from
nearby industry and actual source was not known. The smell was mild, and
there were no cases of breathing difficulties or those that require clinical
admissions, even though some students did report having fever, but they
were unsure of the exact cause.
c) It would be great if there are more interactions between big industry players,
like BPC, and ILP Kuantan. During the pre-COVID times, there were some
interactions, however ever since the lockdown, interactions has reduced.
Arrangements of future educational visits to the plant were also suggested
by En. Wan Asmawi.
• The Project Proponent’s Corporate Affairs representative, Ms. Sow
Kheng, agreed with En. Wan Asmawi and stated that there are plans for
local community events and activities in the near future. Currently, they
are starting to reach out to the nearby community and there will be more
interactions to come.

• Ir. Firdaus, the General Manager of the Oxo Complex within the ICS,
highlighted that ILP Kuantan has always provided support in terms of
talent development, i.e., certified chargemen trainings.
iv) Engagement with Gebeng Industrial Support Group (GISG)
A virtual engagement session was conducted with industry players of the Gebeng
Industrial Support Group (GISG) on 9 June 2022 via Microsoft Teams (Plate 7-6). The
attendance of the engagement session comprised of a total of 23 attendees:
• GISG representatives: 4 personnel from Kaneka (Malaysia), 3 personnel from
Polyplastics Asia Pacific, 1 personnel each from BRB Malaysia, Eastman
Chemicals, FGV Biotechnologies, Gas Malaysia Distribution, PETRONAS
Chemicals MTBE, W.R. Grace, Lynas Malaysia and BASF
• Project Proponent: 5 personnel
• EIA Consultant: 4 personnel
Plate 7-6 Engagement with Representatives of the Gebeng Industrial

Support Group (GISG)
The FGD first began with a presentation from ERE Consulting Group, giving a brief
background as well as environmental impacts and mitigation measures of the Project.
The feedback and input received during the engagement are summarized in Table
7-57.

Table 7-57 Feedback Received During GISG Engagement
No. Topic Feedback/Input
• Ms. Aqila from PC MTBE shared that previously they have a mudball activity once a year, which was planned by
the HSE department. The mudballs were prepared the day before the event, and they will throw the prepared
mudballs into the river the next day.
• Mr. Kamaruzzaman from Kaneka also shared on the existing Balok River Adoption Programme (BRAP) which
was a joint effort by 7 companies, including BPC, PC MTBE, Grace, Eastman, Kaneka, RPCM & Polyplastics. The
latest programme with DOE during the MCO period, was called Program Denai Sungai Kebangsaan.
Existing effort to conserve Sg. • Mr. Mat Nafi from Polyplastics also informed that there were annual programmes during pre-COVID times, and
1
Balok and Pantai Balok even programmes or activities to educate the public. Even though the events were on hold during the pandemic
lockdown, there are plans to reactivate it back.
• The communities involved in the activities were mainly the fishermen and local residents. En. Mansor, Ketua
Kampung Balok, will help to coordinate attendees from the local residents. During the COVID period, less
participants attended the activities, where 50-80 pax are from participating companies. During pre-COVID times,
there will usually be about 100 members from Gebeng industry players and approximately 100 to 150 pax from
the community and invited agencies.
• Incoming raw material will be coming from Melaka, so the trucks will mainly be using Gebeng Bypass. Unless
due to unforeseen circumstances, then they will use another access route to the Project site. Transportation of raw
materials will be carried out mainly at nighttime or late evening. This is to prevent any traffic congestions caused
by the incoming trucks.
2 Existing traffic condition • For the outgoing products, they will mostly be sent to Kuantan Port, with a very small proportion, about 5%, to
Singapore region and Klang Port.
• During construction stage, for equipment delivery, there will not be a lot of huge equipment to be transported (2
distillation towers and 2 reactors). The equipment will be delivered from Kuantan Port to ICS and laydown within
the ICS. The route used will be the usual route, i.e., from KPC → Cargill → MTBE

No. Topic Feedback/Input
• Only oxygen will be sourced from Melaka and the rest will be channeled to the production plant through pipelines
within the ICS. Transportation of raw materials will also be coordinate with the vendor to be sent during
nighttime and late evening.
• The Project Proponent also suggested the possibility in sending out an email to GISG to inform and update when
Congestion in front of Jalan the Project will be starting, so the other industry players will be in the know about the traffic updates.
3 Gebeng 1/11, especially • Dato Khor from BASF informed that currently the Project Proponent has also rented an extra lot (A500, at the
during the morning west), which is used as carpark.
• Mr. Akmal from Polyplastics also brought up the incoming vehicles during the construction stage and additional
contractors during the operation stage. Nonetheless, the traffic volume contribution is not solely from the Project
Proponent alone, as all the industries from GIE is using these main access routes. Hence, he has suggested that
maybe GISG can look into this matter and can have an alternative road to Gebeng area.
• Ms. Nora from Kaneka also brought up an important point, where the construction of Federal Road 3 (from
SIRIM to Sg. Ular intersection) has commenced in November 2021 and is currently ongoing. The construction
Concurrent construction of
4 will be concurrent with the construction of the Project, as both will end in July 2024.
Federal Road 3
• The Project Proponent might need to consider and take note on the logistics and traffic issues which may arise
during the construction period.
• Only about 5.5 t/h of raw water will be used for steam generation in the operation stage, and maybe some
amounts for hydrotesting during construction stage.
• There will mostly likely be some increase of raw water consumption during the commissioning stage, and after
5 Raw water supply usage
that the usage will decrease. Generally, the Project will not consume much raw water.
• The Project Proponent will also appoint a utility team to manage the consumption of utilities during the
construction stage.

7.5.8 Health Impact Assessment
Health impact assessment (HIA) is the process of estimating the potential impact of
a chemical, biological, physical or social agent on a specified human population
system under a specific set of conditions and for a certain time frame (EnHealth
Council, 2001; DOE, 2012). The main approach in this HIA for EIA is to assess the
impacts of the Proposed 2-Ethylehaxanoic Acid (EHACID II) Plant in Existing
Integrated Chemical Sites of BASF Petronas Chemicals, Gebeng, Kuantan, Pahang,
on the health of residents of affected communities within the vicinity of the Proposed
Project that may emanate from environmental impacts. The HIA reported here is
based on the Guidance Document on HIA in EIA by the Department of Environment
Malaysia (DOE, 2012). The impacts of the Proposed Project on workers’ health are
not included in this HIA, as it is not within the scope specified in the Guidance
Document.
Health risk assessment (HRA) is a component of HIA. There are two forms of HRA,
namely qualitative and quantitative HRA. Qualitative HRA merely characterizes or
compares the hazard of a chemical relative to others, or in comparison to reference
values or standards, or defines the hazard in only qualitative terms such as mutagen
or carcinogen, which connotes certain risk or safety procedures. In qualitative HRA,
only subjective and comparative risk assessment of environmental hazards are
attempted without generating any quantitative estimate of the risks involved.
Quantitative HRA is a methodological approach in which the toxicities of a chemical

are identified, characterized, analyzed for dose-response relationships, and the data
generated are applied to a mathematical model to produce a numeric estimate
representing a guideline or decision concerning allowable exposure (James, 1985a).
Quantitative HRA generates a numerical measure of the risk or safety of a chemical
exposure. The numerical measure of the risk generated is compared against a
guideline value or an acceptable risk level. When conducting a quantitative HRA,
there are two categories of risks being assessed, namely non-carcinogenic and
carcinogenic health risk.
When interpreting the results of a quantitative HRA, and more so when it is applied
for the purpose of a health impact assessment (HIA), it should be caution that no
mathematical modeling can simulate the human body with high accuracy. Therefore,
the predictions made in this report are to be taken as a guideline, mainly for a more
informed decision-making process, which in this case is whether the operation of the
Proposed Project will incur significant health impacts upon the exposed or affected
population.
For the purpose of this HRA, both qualitative and quantitative HRA will be
employed. There are 6 steps involved in the HRA methodology.

7.5.8.1 Issues Identification
This first step explores the source-pathway-receptor link, the component of each is
essential in the expression of risk. Health impacts are mainly secondary impacts
upon the human community that emanate from primary impacts upon the physical
(air, water and soil); biological (animals and plants) and social environments. Process
wastewater from the Project will be first treated in a wastewater treatment plant
(WWTP). Effluent from the WWTP will be discharged into the Perbadanan Kemajuan
Negeri Pahang (PKNP) drainage system which will then flow in Sg. Balok. There are
no water intake points or any water-related infrastructure points downstream of the
Project site.
In the case of this Proposed Project, the main health impacts will emanate from
human exposure to air pollutants that will be released during the construction and
operation phases of the Proposed Project. The major pathway for human exposure to
the released air pollutants during the construction and operation phases will be
through direct inhalation. Exposure to air pollutants through the ingestion route is
possible but seems unlikely in this case. The Proposed Project site is situated inside
the Project Proponent’s Integrated Chemical Site (ICS) within the Gebeng Industrial
Estate. There is no major farm or food crop being grown in the surrounding area
which can result in contamination of the human food chains.
The quantitative HRA will rely heavily on data generated by the air quality modeling
exercise. Uncertainties inherent in the air quality modeling will also be translated
into uncertainties in the quantitative HRA outcomes. It is the purpose of this
quantitative HRA to minimize these uncertainties related to human health risks, but
the fact that must also be accepted is that these uncertainties can never be totally
eliminated. With that background assumption, the results of this quantitative HRA
need to be interpreted with due caution and a high regard for human health and
safety.
7.5.8.2 Hazard Identification
This second step in HRA involves the identification of potential environmental

hazards and characterization of their innate adverse toxic or health effects. The
purpose is to scope for potential environmental and health hazards that may emanate
from the construction and operation of the Proposed Project. The review indicated
that the major environmental hazards from the Proposed Project will be mainly air
pollutants.

Project Construction Phase
a) Health Impact of Water Pollutants During Project Construction Phase
According to the water quality impact assessment in Section 7.4.3, soil

erosion and sedimentation will be the main cause of water pollution during
the Project construction phase. Construction activities such as foundation
works, piling and exposed surfaces may increase surface runoff into nearby
waterways causing an increase of total suspended solid (TSS) levels. However,
land clearing and earthwork activities for this Project will be minimal as the
platform for the Project has been established previously. Runoff from the
Proposed Project construction site will be channeled into a silt trap prior to
discharge into the stormwater drainage system which will eventually
discharge into the retention pond located within the ICS complex. The
retention pond will then discharge into the Perbadanan Kemajuan Negeri
Pahang (PKNP) drainage system which will finally flow into Sg. Balok. TSS
is identified as the main pollutant contributing source during construction
stage. TSS will not have any significant health impact on humans who may
come into contact with the water of Sg. Balok. Therefore, no further HRA will
be conducted on the TSS in Sg. Balok.
b) Health Impact of Air Pollutants During Project Construction Phase
According to the air quality impact assessment in Section 7.4.1, air emissions
that could potentially affect the ambient air quality surrounding the Project
Site during the construction phase are fugitive dust, including PM10
generated from construction activities such as movement of vehicles over
unpaved surfaces and stockpiling; and dust and gaseous emissions of PM10,
PM2.5, CO, NO2 and SO2 from the combustion of fuel from vehicles, generators
and other equipment. Fugitive dust emissions generated from the Project site
are not expected to travel far enough to cause any adverse impact or nuisance
to the surrounding air sensitive receptors. Moreover, sensitive receptors are
located quite a distance away from the Project site, the nearest being Institut
Latihan Perindustrian (ILP) Kuantan, which is located 2.3 km southeast of the
Project site. Therefore, the impact of fugitive dust is expected to be localized
and not significant to the nearby air sensitive receptors. Similarly, gaseous
emissions from vehicles, generators and equipment are not expected to be
significant to the nearest air sensitive receptor site (ILP). Thus, no further
HRA will be conducted on the air pollutants that will be emitted during the
Project construction phase.

Project Operation Phase
a) Health Impact of Water Pollutants During Project Operation Phase
According to the water quality impact assessment in Section 7.5.5, the

operation of the Project will discharge water pollutants mainly from the
wastewater treatment plant (WWTP). The WWTP is designed to treat process
wastewater and sewage generated within the ICS complex (refer to Section
5.3.4, Table 5-5). The final treated effluent quality is treated to meet Standard
B of the Environmental Quality (Industrial Effluent) Regulation 2009. The
average raw effluent discharge from the Project is 0.04 m3/h which is a makes
up small portion of current total average discharge of 262 m3/h (refer Section
5.3.4). The sewage will be channeled to a sanitary pit prior to discharge to
WWTP.
To assess the impacts of wastewater discharge from the WWTP on receiving

Sg. Balok, a mixing model was applied under 2 discharge scenarios. Scenario
1 is normal WWTP discharge that meets Standard B limits of the
Environmental Quality (Industrial Effluent) Regulation 2009 during 7Q10
low flow condition, while Scenario 2 is the worst case of untreated effluent
discharged from the WWTP during 7Q10 low flow conditions. The effluent
discharge parameters in terms of biochemical oxygen demand (BOD),
chemical oxygen demand (COD), total suspended solids (TSS) and
ammoniacal nitrogen (NH3-N). Under Scenario 1, all the water quality
parameters will experience some increase in concentration in the receiving
waters, however impact on NH3-N levels will be minimal. Sg. Balok is
classified as Class III River in 2020 by DOE. The Project Site is located in
industrial area where the waterway receives discharge from multiple
industrial complexes. Furthermore, occurrence of 7Q10 low flow incidents is
low hence the flow rate under normal conditions will be higher than flow rate
used for the assessment. Under Scenario 2, the water quality parameters in
the receiving waters are expected to deteriorate, except for NH3-N. However,
the likelihood of Scenario 2 event occurring is minimal as the Project
Proponent will ensure all best management practices related to WWTP are
performed properly. Therefore, no further HRA will be conducted on water
pollutants during the Project operation phase.
b) Health Impact of Air Pollutants During Project Operation Phase
According to the air quality impact assessment in Section 7.5.1, the operation
phase of the Proposed Project is expected to generate both particulate and
gaseous air pollutants. The pollutants that will be emitted include respirable
particulate (PM10), sulphur dioxide (SO2), nitrogen dioxide (NO2), carbon
monoxide (CO), chlorine (Cl2), hydrogen sulphide (H2S), hydrogen chloride

(HCl), ammonia (NH3), non-methame volatile organic compounds (NMVOC),
mercury (Hg), 1-butene (C4H8), methanol or MeOH (CH4O), isoprene (C5H8),
methyl tert-butyl ether or MTBE (C5H12O), pentane (C5H12), butane (C4H10),
hydrogen (H2), n/i-butyraldehyde and 2-ethylhexanal (C8H16O).
Health Implications of the Hazards
Particulate matter, especially the respiratory fraction known as PM10, with

aerodynamic diameters of 10 µm, has a great impact on human health as they can
penetrate beyond the nasopharyngeal region and reach the lower human respiratory
tract (Dockery and Pope, 1994; Dockery and Pope, 1996). Sulphur dioxide (SO2) may
aggravate chronic respiratory diseases and cause increased airway resistance or
bronchospasm especially among asthmatics. Nitrogen dioxide (NO2) may cause
proliferative lung damage, methemoglobinemia, bronchiolitis or viral infections of
the lower respiratory tract (Stern et al., 1984). NO2 may also lead to reduced lung
function, airway responsiveness and respiratory symptoms (Searl, 2004) as well as
airway inflammation in healthy people and increased respiratory symptoms in
people with asthma (USEPA, 2013). Carbon monoxide (CO) leads to the formation of
carboxyhaemoglobin and reduced oxygen transport by blood causing headache,
nausea, rapid breathing, weakness, exhaustion, dizziness, confusion, neurological
and cardiological effects including death (CDC, 2013).
Exposure to low levels of chlorine (Cl2) can result in nose, throat, and eye irritation.
At higher levels, breathing chlorine gas may result in changes in breathing rate and
coughing, and damage to the lungs. Additional symptoms of exposure to chlorine
can be severe (CDC, 2022). Hydrogen sulphide (H2S) is a potentially toxic gas. The
gas can generate hydrogen sulphide anion (HS-), which is a potent inhibitor of
cytochrome oxidase, an enzyme responsible for cell respiration. This inhibition will
interfere with the utilization of oxygen during cell metabolism, even in the presence
of adequate blood supply of oxygen. High concentrations of H2S will lead to a
condition called cytotoxic hypoxia which may results in a respiratory arrest. At lower
concentrations, H2S is an irritant gas that may cause conjunctivitis, inflammation of
the nasal mucosa and pulmonary edema (James, 1985b). Hydrogen chloride (HCl) is
irritating and corrosive to any tissue it comes into contact with. Brief exposure to low
levels causes throat irritation. Exposure to higher levels can result in rapid breathing,
narrowing of the bronchioles, blue colouring of the skin, accumulation of fluid in the
lungs, and even death (ATSDR, 2016).
Ammonia (NH3) is irritating and corrosive. Exposure to high concentrations of

ammonia in air causes immediate burning of the nose, throat and respiratory tract.
This can cause bronchiolar and alveolar edema, and airway destruction, resulting in
respiratory distress or failure. Inhalation of lower concentrations can cause coughing,
nose and throat irritation. Ammonia’s odour provides adequate early warning of its
presence, but it also causes olfactory fatigue or adaptation, reducing awareness of

one’s prolonged exposure at low concentrations (New York State Department of
Health, 2021). Non-methane volatile organic compounds (NMVOC) are a mixture of
volatile organic chemicals which are generally neurotoxic (James, 1985B). They have
high vapour pressure and are highly volatile. They may be related to asthma and
chronic respiratory symptoms (Ware et al., 1993). More specific health effects will
refer to the individual compound that make up the NMVOC.
Mercury (Hg) is known to be neurotoxic (James, 1985b). Methylmercury and metallic

mercury vapors are more harmful than other forms, because more mercury in these
forms reaches the brain. Short-term exposure to high levels of mercury vapors may
cause lung damage, nausea, vomiting, diarrhea, increases in blood pressure or heart
rate, skin rashes, and eye irritation. Exposure to high levels of metallic, inorganic, or
organic mercury can permanently damage the brain, kidneys, and developing fetus.
Effects on brain functioning may result in irritability, shyness, tremors, changes in
vision or hearing, and memory problems (ATSDR, 1999).
1-butene (C4H8) can cause significant irritation especially the eyes. It may act as an
asphyxiant or a slight anesthetic and narcotic at high concentrations. (Cameo
Chemicals, 2022). Contact with methanol or MeOH (CH4O) can cause irritation to the
skin. Inhalation of methanol can irritate the nose, throat and lungs, causing coughing,
wheezing, shortness of breath, nausea, vomiting, diarrhoea and abdominal pain.
Exposure to higher concentrations can lead to loss of consciousness and death (New
Jersey Department of Health, 2016). Contact with isoprene can irritate the skin and
eyes. Inhaling isoprene can irritate the nose and throat causing coughing and
wheezing. Acute exposure can lead to headache, dizziness, light headedness and loss
of consciousness (New Jersey Department of Health, 2008). Isoprene (C5H8) is
possibly carcinogenic to humans (Group 2B) (IARC 2021). Methyl tert-butyl ether
(MTBE) (C5H12O) is a flammable liquid that has been used as an additive for
unleaded gasoline since the 1980s. However, the human health effects from MTBE at
low environmental doses are unknown. Animal studies involving high doses of
MTBE have shown effects such as skin and eye irritation (CDC, 2022). Pentane (C5H12)
can irritate and burn the skin and eyes. Inhaling pentane can irritate the nose, throat
and lungs causing coughing, wheezing and shortness of breath. Higher inhalation
exposure may lead to pulmonary edema. Other symptoms include headache,
dizziness, confusion, loss of balance and consciousness (New Jersey Department of
Health, 2009). Contact with butane (C4H10) can cause frostbite of the skin and eyes.
Exposure to higher concentrations can cause headache, lightheadedness, drowsiness
and loss of consciousness from asphyxia (New Jersey Department of Health, 2008).
Contact with liquid hydrogen can cause severe burns and frostbite to the skin and
eyes. High levels of hydrogen (H2) in the air can cause suffocation with symptoms of
headache, dizziness, weakness, loss of coordination and judgement, loss of
consciousness and death (New Jersey Department of Health, 2016). Contact with
butyraldehyde can irritate and burn the skin and eyes. Breathing butyraldehyde
irritates the lungs causing coughing and shortness of breath. Higher exposures can

cause pulmonary edema and severe shortness of breath (New Jersey Department of
Health and Senior Sevices, 2002). Symptoms of exposure to 2-ethylhexanal (C8H16O)
may be headache, dizziness, tiredness, nausea and vomiting. Symptoms of allergic
reaction may include rash, itching, swelling, trouble breathing, tingling of the hands
and feet, dizziness, lightheadedness, chest pain, muscle pain or flushing (Thermo
Fisher, 2014).
7.5.8.3 Dose-Response Assessment
As mentioned earlier, there is only one possible route of human exposure to the air
pollutants that may originate from the Proposed Project, and that is inhalation
exposure during the Project operation phase.
Inhalation Exposure to Air Pollutants
For qualitative exposure assessment, exposure levels to the air pollutants were
compared against available air pollutant exposure guideline values. Whenever
available, guideline values were taken from the Malaysian Ambient Air Quality
Standard (MAAQS) 2013 (2020). For air pollutants for which MAAQS 2013 guideline
values are not available, references were made to the Malaysian Ambient Air Quality
Guidelines and the Ontario’s Ambient Air Quality Criteria 2020.
For quantitative exposure assessment, the reference concentration (RfC) was used.
The RfC is an estimated daily concentration of a toxicant in air, with uncertainty
spanning perhaps an order of magnitude, of which an inhalation exposure to the
human population including sensitive subgroups, is likely to be without an
appreciable risk of deleterious effect during a lifetime of 70 years. The unit of RfC is
usually in mg/m3. Therefore, the RfC is described in the form of an air concentration
which may be safely inhaled by an exposed person over his entire lifetime of 70 years.
7.5.8.4 Exposure Assessment
Exposure to Air Pollutants
Two air pollution emission scenarios were simulated for the Project operation phase.
One is the normal Project operation scenario, and the other is the abnormal Project
operation scenario. During a normal Project operation scenario, the thermal oxidizer
(TOX) is assumed to work normally, and oxygen off gas will be thermally treated at
the existing thermal oxidizer (TOX) located in the Aroma Plant and hydrogen off gas
in LP Flare Stack X-8101.
Abnormal Project operation scenario is based on a worst-case scenario for a

maximum duration of one (1) hour. There will be continuous offgases (untreated

release) from Stack XX-9680 due to Aroma TOX system failure. Leaky heat exchanger
event for T3200/T4200 (2-ethylhexanal distillation column for 2-EHAcid Plant I and
II) where pressure safety valve (PSV) will channel the fluid into the HP Flare Stack
X-8101 with failure of the ignition system. However, the abnormal Project operation
scenario is very unlikely to happen since online monitoring is available in DCS
console and abnormalities or upset scenario will trigger relevant interlock for Aroma
TOX to get into fail-safe condition. Alarm will also set off when the parameters go
out of the normal operating condition.
Under each Project operation scenario, 4 air sensitive receptors (ASRs) were
identified as shown in Table 7-58.
Table 7-59, which was taken from Table 7-17 in Section 7.5.1, gives the baseline
concentration (BC), maximum average incremental concentration (MAIC) and
ground level concentration (GLC) of the air pollutants at each of the 4 ASRs, under
both normal and abnormal Project operation scenarios. Under the normal Project
operation scenario, all the GLC at the ASRs will meet their respective guideline
values under the Malaysian Ambient Air Quality Standards (MAAQS) 2013 (2020) or
the Ontario Ambient Air Quality Criteria (OAAQC) 2020.
Table 7-58 Air Sensitive Receptors (ASR) For Air Quality Impact
Assessment
No. Air Sensitive Receptor Distance (km) and Direction from the Project Site
1. Taman Seri Perasing 5.0 km southwest
2. Perumahan Balok Baru 3.5 km southwest
3. Taman Balok Perdana 2.8 km south
4. Taman Kg. Gebeng Pantai 5.4 km northeast
Under the abnormal Project operation scenario, there will release of certain volatile
organics over a maximum duration of 1 hour. No guideline value is available for a 1-
hour exposure to these air pollutants. However, the abnormal Project operation
scenario is very unlikely to happen since online monitoring is available in DCS
console and abnormalities or upset scenario will trigger relevant interlock for Aroma
TOX to get into fail-safe condition.

Table 7-59 Predicted Maximum Average Incremental Concentration (MAIC) and Ground Level Concentration (GLC) at Air Sensitive Receptors (ASRs)
ASR 4 - Taman Kg.
ASR 1 - Taman Seri ASR2 - Perumahan Balok ASR 3 - Taman Balok
Air Gebeng Pantai (5.4km Ambient
Averaging Perasing (5.0km southwest Baru (3.5km southwest of Perdana (2.8km south
No Pollutant Unit Dispersion Max MAIC northeast of the Project Limits
Time of the Project site) the Project site) of Project site)
Contour site) (ug/m3)
BC MAIC GLC BC MAIC GLC BC MAIC GLC BC MAIC GLC
Normal Operation
µg/m3 24-Hr Chart 7-6 1.215 42 0.08 42.08 21 0.2 21.2 31 0.2 31.2 39 0.1 39.1 100a
1 PM10
µg/m3 Annual Chart 7-6 0.259 - 0.01 0.01 - 0.04 0.04 - 0.04 0.04 - 0.02 0.02 40a
µg/m3 1-Hr Chart 7-7 1.074 <0.5 0.04 0.04 <0.5 0.06 0.06 <0.5 0.08 0.08 <0.5 0.04 0.04 280a
2 NO2
µg/m3 24-Hr Chart 7-7 0.138 - 0.01 0.01 - 0.02 0.02 - 0.04 0.04 - 0.02 0.02 70a
µg/m3 1-Hr Chart 7-8 2.376 <50 0.1 0.1 <50 0.1 0.1 <50 0.2 0.2 <50 0.1 0.1 250a
3 SO2
µg/m3 24-Hr Chart 7-8 0.306 - 0.02 0.02 - 0.02 0.02 - 0.06 0.06 - 0.04 0.04 80a
µg/m3 1-Hr Chart 7-9 1.677 <1 0.08 0.08 <1 0.1 0.1 <1 0.2 0.2 <1 0.08 0.08 30,000a
4 CO
µg/m3 8-Hr Chart 7-9 0.461 - 0.04 0.04 - 0.06 0.06 - 0.08 0.08 - 0.06 0.06 10,000a
5 Cl2 µg/m3 24-Hr Chart 7-10 3.234 <10 0.2 0.2 <10 0.3 0.3 <10 0.5 0.5 <10 0.3 0.3 10b
6 H2S µg/m3 24-Hr Chart 7-10 0.211 <10 0.02 0.02 <10 0.02 0.02 <10 0.03 0.03 <10 0.02 0.02 7b
7 HCl µg/m3 24-Hr Chart 7-11 3.329 <20 0.2 0.2 <20 0.4 0.4 <20 0.6 0.6 <20 0.4 0.4 20b
8 Hg µg/m3 24-Hr Chart 7-11 0.001 <0.01 0.00001 0.00001 <0.01 0.00001 0.00001 0.04 0.0002 0.0402 <0.01 0.00001 0.00001 2b
9 NH3 µg/m3 24-Hr Chart 7-12 0.127 38 0.008 38.008 63 0.02 63.02 <10 0.02 0.02 <10 0.01 0.01 100b
10 NMVOC µg/m3 24-Hr Chart 7-12 0.042 <10 0.004 0.004 <10 0.004 0.004 <10 0.008 0.008 <10 0.004 0.004 -
Abnormal Operation
1 1-Butene (C4H8) µg/m3 1-hr Chart 7-13 4,067.457 - 200 200 - 200 200 - 300 300 - 200 200 -
2 MeOH (CH4O) µg/m3 1-hr Chart 7-13 456.707 - 20 20 - 20 20 - 40 40 - 20 20 -
3 Isoprene (C5H8) µg/m 3 1-hr Chart 7-14 281.611 - 10 10 - 20 20 - 20 20 - 10 10 -
4 Methyl tert-butyl ether (C5H12O) µg/m3 1-hr Chart 7-14 459.109 - 20 20 - 20 20 - 40 40 - 20 20 -
5 Pentane (C5H12) µg/m3 1-hr Chart 7-15 275.730 - 10 10 - 20 20 - 20 20 - 10 10 -
6 Butane (C4H10) µg/m 3 1-hr Chart 7-15 277.221 - 10 10 - 20 20 - 20 20 - 10 10 -
7 Hydrogen (H2) µg/m3 1-hr Chart 7-16 500.103 - 30 30 - 30 30 - 50 50 - 20 20 -
8 n/i-Butyraldehyde µg/m3 1-hr Chart 7-16 377.588 - 20 20 - 20 20 - 40 40 - 20 20 -
9 2-ethylhexanal (C8H16O) µg/m 3 1-hr Chart 7-17 116,182.426 - 12,000 12,000 - 12,000 12,000 - 18,000 18,000 - 12,000 12,000 -
Notes: a. Standard 2020 of Malaysian Ambient Air Quality Standards (MAAQS), 2013
b. Ontario Ambient Air Quality Criteria
Ground Level Concentration (GLC) = Baseline Concentration (BC) + Maximum Average Incremental Concentration (MAIC)
< means ‘less than the minimum detectable limit’ or ‘not detected’.
- means no data available


7.5.8.5 Health Risk Characterization
Two methods were used in the health risk characterization step. The qualitative
method mainly compares the predicted highest ASRs’ GLC with established
exposure guidelines like that of the Malaysian Ambient Air Quality Standards 2013
(2020), and the Ontario’s Ambient Air Quality Criteria 2020.
Air Pollutant Exposure Guidelines
Under the normal Project operation scenario, all the GLC at the ASR will meet their
respective guideline values under the Malaysian Ambient Air Quality Standards
(MAAQS) 2013 (2020) or the Ontario Ambient Air Quality Criteria (OAAQC) 2020.
Under the abnormal Project operation scenario, no guideline value is available for a
1-hour exposure to the released air pollutants. However, the abnormal Project
operation scenario is very unlikely to happen.
Hazard Quotient for Air Pollutants
The hazard quotient (HQ) is a measure of the possibility of seeing chronic, non-
carcinogenic health effects among the exposed population. The HQ due to chronic
inhalation exposure to the air pollutants from the Proposed Project during normal
project operation, in a community location were calculated. This HQ is obtained by
taking the ratio of the ambient air concentration or exposure air concentration (EC)
to the reference concentration (RfC). The unit for EC and RfC is mg/m3 or µg/m3.
𝐸𝐶
HQ = 𝑅𝑓𝐶
𝐶𝑎 𝑥 𝐸𝐹 𝑥 𝐸𝐷
EC = 𝐴𝑇 𝑥 365 𝑑𝑎𝑦𝑠/𝑦𝑒𝑎𝑟
Where,
EC = Exposure concentration (µg/m3)
Ca = air concentration (µg/m3)
EF = Exposure frequency = 350 days/year
ED = Exposure duration = 40 years
AT = Averaging time = ED = 40years
When RfC was not available, it was converted from the reference dose RfD using the
following formula.
𝑚𝑔
𝑅𝑓𝐷 𝑖𝑛 −𝑑𝑎𝑦 𝑥 70 𝑘𝑔 𝑏𝑜𝑑𝑦 𝑤𝑒𝑖𝑔ℎ𝑡 𝑥 1000µg/mg
𝑘𝑔
RfC (µg/m3) = 20 𝑚3 /𝑑𝑎𝑦

A HQ of 1 or greater signifies a hazardous condition, whereby EC equals or exceeds
RfC. A HQ of less than 1 is categorized as an acceptable risk for a non-carcinogenic
health effect by the USEPA.
Table 7-60 shows the hazard quotients (HQ) calculated for the air pollutants for
exposure at the most sensitive ASR site during a normal project operation scenario
for the Proposed Project. As shown in the Table, all the HQ are below 1, indicating
that chronic, non-carcinogenic health effects shown in the last column of the Table is
unlikely to occur, even after a lifetime exposure to the air pollutants.
Table 7-60 Predicted Highest Ambient and Adjusted Exposure

Concentrations, RfC and HQ For Non-Carcinogenic Health Effects of Air
Pollutants for An Exposure at The Most Sensitive ASR Sites During A Normal
Project Operation Scenario
Predicted
Adjusted
highest
Air exposure RfC a Non-carcinogenic
ambient HQ
pollutant concentration (g/m3) health effects
concentration
(EC) (g/m3)
(g/m3)
Chlorine No observed
0.51 0.48 350.0 b 0.0014
(24-hour) adverse effect
Hydrogen
Nasal lesion of the
sulphide 0.031 0.029 2.0 0.015
alfactory mucosa
(24 hour)
Hydrogen Hyperplasia of the
chloride 0.61 0.58 20.0 0.029 nasal mucosa,
(24-hour) larynx and trachea
Hand tremor,
increase in memory
disturbances, and
Mercury slight subjective
0.04021 0.04 0.3 0.13
(24-hour) and objective
evidence of
autonomic
dysfunction
Decreased lung
Ammonia function and
63.022 60.43 500.0 0.12
(24-hour) respiratory
symptoms
Note:
1 Taman Balok Perdana (ASR 3)
2 Perumahan Balok Baru (ASR 2)
Source : a USEPA’s Integrated Risk Information System (Accessed on 29 June 2022).

b RfC converted from RfD

Lifetime Cancer Risk for Air Pollutants
None of the air pollutants identified in Table 7-60 is carcinogenic. Therefore, no

lifetime cancer risk assessment was performed in this HRA.
7.5.8.6 Uncertainty Analysis
Quantitative HRA is not a tool that can emulate or model “reality” with
unquestionable accuracy and precision. The model it generates is a representation of
reality which the current scientific tools will render. Therefore, there is always a
certain degree of uncertainty involved in the quantitative HRA process. This
uncertainty is internalized in the form of assumptions made in generating
parameters such as the RfC, exposure frequency, exposure duration and body weight.
These assumptions are made with respect to the various default values used such as
the average adult body weight of 70 kg, and inhalation rate of 20 m3/day. These
default values refer to that of an average person.
7.5.8.7 Assessment Summary
During the Project construction phase, only TSS is identified as the main water
pollutant. TSS will not have any significant health impact on humans who may come
into contact with the water of Sg. Balok. Therefore, no further HRA was conducted
on the TSS in Sg. Balok.
Fugitive dust emissions during the Project construction phase are not expected to
travel far enough to cause any adverse impact or nuisance to the surrounding air
sensitive receptors. Therefore, the impact is expected to be localized and not
significant to the nearby air sensitive receptors. Similarly, gaseous emissions from
vehicles, generators and equipment are not expected to be significant. Thus, no
further HRA was conducted on the air pollutants that will be emitted during the
Project construction phase.
During the Project operation phase under Scenario 1, all the water quality parameters
will have minimal impacts on the receiving waters and the baseline water quality is
expected to be maintained. Under Scenario 2, the water quality parameters in the
receiving waters are expected to deteriorate, except for NH3-N. However, the
likelihood of Scenario 2 event occurring is minimal as the Project Proponent will
ensure all best management practices related to WWTP are performed properly.
Therefore, no further HRA was conducted on water pollutants during the Project
operation phase.
During the Project operation phase, all the hazard quotients (HQ) calculated for the
air pollutants exposure at the most sensitive ASR site during a normal Project

operation scenario are below 1, indicating that chronic, non-carcinogenic health
effects are unlikely to occur, even after a lifetime exposure to the air pollutants.
During an abnormal Project operation scenario, there will be release of certain

volatile organics over a maximum duration of 1 hour. No guideline value is available
for a 1-hour exposure to these air pollutants. However, the abnormal Project
operation scenario is very unlikely to happen since online monitoring is available in
DCS console and abnormalities or upset scenario will trigger relevant interlock for
Aroma TOX to get into fail-safe condition.
7.6 PROJECT ABANDONMENT

Project abandonment can occur for various reasons and at any stage of the Project
cycle which will result in facilities that are incomplete or completed but not utilized
as intended. There are several potential impacts that may occur, which is as listed in
Table 7-61.
Table 7-61 Potential Impacts During Project Abandonment

Environmental
Potential Impacts
Elements
Fugitive dust generation during movement of heavy machineries
Air Quality
and during demolition works
Temporary increase of ambient noise levels due to vehicular
Noise
movement and demolition/decommissioning
• Accidental spills and leakages from equipment removal
Water Quality works
• Leaching from mishandling of scheduled wastes
• Generation of demolition wastes from unwanted
components, domestic wastes and scheduled wastes
Waste Management • Improper handling and disposal may lead to land
contamination and contamination of water sources
• Proliferation of pests
• Decommissioning and abandonment may bring an end to
Socio-Economic the direct and indirect employment
Impact • Potential economic loss
• Impaired aesthetic from abandoned structures

08 PROPOSED MITIGATION MEASURES
Section 8
PROPOSED MITIGATION MEASURES
SECTION 8 : PROPOSED MITIGATION MEASURES
8.1 INTRODUCTION
This Section outlines the proposed mitigation measures during the Project
construction phase and operational phase. Mitigation measures proposed include
best management practices, practical engineering solutions and control measures
which aim to address issues in a practical and cost-effective manner.
8.2 PRE-CONSTRUCTION PHASE
8.2.1 Project Planning and Site Investigation
No mitigation measures are required for the activities during this phase as the
impacts are expected to be minimal at the Project Site and its surrounding areas.
8.3 CONSTRUCTION PHASE
8.3.1 Air Quality
Even though the impact of fugitive dust is expected to be localized and not significant
to the distant air sensitive receptors, the Project Proponent should still implement
effective and proper air quality control measures at the Project site especially during
hot and dry season or haze condition as described below:
i) Earthwork Activities
• Erect hoarding or equivalent barriers around the construction area;
• Regular water spraying of construction sites, particularly along haul
roads (Plate 8-1); and
• Stockpiles shall be covered. Spraying of water proposed for
uncovered stockpiles to control fugitive dust emissions.

Plate 8-1 Water Bowser Spraying Water along the Haul Road
ii) Movement of Construction Vehicles

• Ensure construction access or haulage route are kept damp by water
bowser on regular basis;
• Impose speed limits within construction sites to reduce dust
generation due to construction vehicle movement;
• Vehicles which carry earth, sand, aggregate or other similar types of
material, shall be covered with tarpaulin, canvas or other equivalent
material before they are allowed to enter public roads (Plate 8-2).
Plate 8-2 Vehicle Load Covered with Tarpaulin

iii) Maintenance of Construction Vehicles
• Fuel-efficient and well-maintained haulage trucks should be used to
minimize exhaust pollution.
• Smoke belching vehicles and equipment should not be allowed to
operate within the Project area;
• Any malfunctioning construction vehicles and equipment should be
repaired immediately; and
• Idling of engines should be discouraged.
iv) Mitigation during dry season

Fugitive dust can be blown further from the disturbed land area within
the Project site during dry season due to the decrease of soil adhesive
coefficients. Thus, the following action should be applied during dry
season:
• The frequency of water spraying should be increased during dry
season to prevent the airborne dust particles; and
• Any spillover of soil onto the BPC’s existing Integrated Chemical Site
(ICS) internal road shall be cleaned up immediately.
Measures to control the increase of noise level will involve the control of noise at
source and the propagation of noise which are described in detail in the following
sections.
8.3.2.1 Control Noise at Source
General Measures
• Avoid unnecessary revving of engines and switch off equipment when not
required;
• Start-up equipment and vehicles sequentially rather than all together; and
• Noisy equipment or activities should be replaced by less noisy alternatives if
noise problems are occurring.
Specification and substitution
• The activities to be employed on site should be reviewed to ensure that they

are the quietest available for that required purpose;
• Noisy equipment or activities should be replaced by less noisy alternatives if
noise problems are occurring; and

Modification of Existing Equipment
• For steady continuous noise that is caused by diesel engines, effective exhaust
silencer system or by designing an acoustic canopy to replace the normal
engine cover is possible to reduce the noise emitted;
• On-site generators supplying electricity for electric motors must be enclosed
and located at least 50 m away from the nearest sensitive receptors;
• Good maintenance of the equipment will result in reduction of noise caused
by resonance of body panel and cover plates by increasing damping effect
with a surface coating of special resonance damping material; and
• Direct metal-to-metal contact during installation of sheet pile (if any) should
be minimized to minimize nuisance to the nearest sensitive receptor.
Use and Siting of Equipment
• Machines such as cranes that may be used intermittently should be shut

down between work periods or should be throttled down to a minimum.
Machines should not be left running unnecessarily;
• Materials should be lowered whenever practicable and should not be
dropped. The surfaces on to which the materials are being moved should be
covered by resilient material; and
• Acoustic covers to engines should be kept closed when the engines are in use
and idling.
Examples for methods of reducing noise levels from typical construction equipment
are given in Table 8-1.
Table 8-1 Examples for Methods of Reducing Noise Levels from

Construction Equipment
Noise Reduction of Plant
A-
Weighted Alternative
Machineries/Equipment Source of Possible
Sound Equipment
Noise Remedies
Reduction
dB
• Fit more
Earth-moving plant: efficient
• Bulldozer exhaust sound
• Compactor reduction
• Crane Engine equipment 5 to 10 -
• Dumper • Manufacturer’s
• Excavator enclosure
• Loader panels need to
be kept closed

Noise Reduction of Plant
A-
Weighted Alternative
Machineries/Equipment Source of Possible
Sound Equipment
Noise Remedies
Reduction
dB
Cranes
Hammer drive piling cables, pile Careful alignment
-
equipment guides and of pile and rig
attachments
Acoustically
dampen metal
Engine
casing Electric-
Compressors and Compressor
Manufactures’ Up to 10 powered
generators or generator
enclosure panels compressors
body shell
need to be kept
closed
Do not hammer
Concrete mixers Cleaning -
the drum
Do not drop
Impact of
Materials handling materials from Up to 10 -
material
excessive height
Source: BS 5228-1:2009+A1:2014 Code of Practice for Noise and Vibration Control on Construction and
Open Sites (Part 1: Noise)
8.3.2.2 Controlling the Spread of Noise
Screening
• A barrier can reflect sound from one receiving position to another and it
needs to be brought as close as possible to either the noise source or the
receiving positions, with no gaps or openings at joints in the barrier material;
• Ordinary building materials normally stored on site (e.g., bricks, aggregate,
timber) can if carefully sited, provide noise screening without additional cost;
and
• Screens should be close either to the source of noise (as with stationary plant
or mobile plant) or to the listener. Careful positioning of noise barriers or
screens may bring significant reductions in noise levels.
In addition, where applicable, the source, path and receiver control option for
construction as outlined in the “Guidelines for Environmental Noise Limits and
Control: Annex D: Best Practice to Minimise Noise Disturbance” issued by DOE
Malaysia can be adopted accordingly as shown in Chart 8-1.

Chart 8-1 Source, Path and Receiver Control Options
8.3.3 Water Quality
Mitigation measures to minimise water deterioration during the construction stage

are described as follows.
Construction Site Runoff
• Contractors shall ensure that all mitigation measures stipulated in Erosion

and Sedimentation Control Plan (ESCP) shall be implemented and
maintained.
• The sediment basins shall be inspected and desilted on a regular basis to
ensure that they function optimally. The silt collected in the sediment basins
must be dredged out once it is about two-thirds full. The desilted material
shall be disposed at the spoil area along with all other unsuitable materials.
• Any disturbed earth caused by construction activities shall be firmly
consolidated and compacted to reduce the rate of possible erosion and release
of loose soil particles.
• Denuded stretches must be re-vegetated after construction works. Suitable
re-vegetation programmes employing leguminous creepers, which are native
grass that require minimal or no maintenance, should be planted as quickly
as possible on exposed areas. Species such as Pueraria javanica, Pueraria
phaseoloides, Centrosema pubescens and Calopogonium muconoides may be used
for this purpose.
• Stockpiles of construction aggregate, spoil and excavated soil should be
located at areas within the Project Site that are generally flat and do not
permit direct run off into any watercourses.
Toilet Facilities
• Proper housekeeping and hygiene will be maintained at all times.

• Based on the Guidelines on Occupational Safety and Health in Construction
Industry (Management) (2019) published by the Department of Occupational

Safety and Health Malaysia, the minimum sanitation facilities specification
required for construction sites are as summarized in Table 8-2.
Table 8-2 Sanitation Facility Specifications

No. of Workers Sanitation Facility Urinal Provision
<25 males 1 water closet or latrine 4 feet
25-250 males 2 water closets or latrines 8 feet
50-100 males 3 water closets or latrines 13 feet
3 water closets or latrines 13 feet
>100 males 1 water closet or latrines for every 50 males 4 feet for every 50 males
excess in excess
<20 females 1 water closet -
1 water closet
<20 females -
1 water closet for every 20 females in excess
Source: Reg. 37(b), Factories and Machinery (Safety, Health and Welfare) Regulations, 1983
• The specifications for toilets at construction sites are as follows:

o Toilets and urinals must be of the water-flush type;
o Where conditions require, running water, connected to mains water
and drainage systems, must be provided for every toilet facility;
o So far as are reasonably practicable, sanitary conveniences must be
kept in a clean and orderly condition;
o Toilets that are not connected to a sewer should be serviced as
required, at least once every six months;
o Locate portable toilets a minimum of 6 meters away from storm drain
inlets, conveyance channels, or surface waters (Plate 8-3).
Plate 8-3 Example of Portable Toilet at Construction Site
Source: toitoi.com (n.d.)

Sullage
The canteen is recommended to be equipped with an oil and grease trap to separate
fat, oils, and grease from the wastewater prior to discharge into drainage. A typical
oil and grease trap design is shown in Chart 8-2. The capacity of the selected oil and
grease trap for the approximately 250 workers with the assumption of three meal
preparation per day is described in Table 8-3 below.
Chart 8-2 Schematics of Underground Oil and Grease Type
Source: Kualiti Alam Hijau (M) Sdn. Bhd.
Table 8-3 Design Capacity of Oil and Grease Trap

Oil and Grease
Daily Meals Maximum Grease and Maximum Capacity Trap Design
Prepared Wastewater Trap (L) until Overflow (L) (inches)
(L × W × H)
600 - 1000 287 447 39"x 28" x 25"
Source: Kualiti Alam Hijau (M) Sdn. Bhd.
Scheduled Waste
Storage and handling of scheduled wastes will be carried out according to the
Environmental Quality (Scheduled Wastes) Regulations, 2005. Details for
management of scheduled waste can be referred in Section 8.3.4.2.
Storage and Handling of Petroleum Products & Wastes
Improper discharge, leakage or spillage of petroleum products and wastes shall be

prevented during construction as these substances can cause the pollution of
watercourses and water bodies. Spillage of fuel, lubricants and chemicals will be
prevented by mitigation measures and best management practices for the storage,
handling, and usage of these petroleum products. The mitigation measures that will
be implemented are as described below:
• The presence of diesel machinery and the storage of diesel and petroleum
products may lead to pollution should spillage/leakage occurs. Hence,
adequate attention will be given to storage and refuelling activity;
• The maintenance of machinery will be carried out in a designated area where
spillage or leakage of used oil and lubricants can be contained;
• Oil spills will be cleaned up as soon as possible to prevent possible oil
contamination to the waterways;
• Used oil and grease will be stored in proper drums/containers, labelled and
placed at a designated location with containment facilities as far away as
possible from waterways, prior to disposal by licensed contractors;
• Adequate attention will be given to maintenance of the construction
machines to ensure that leakage does not occur;
• Emergency Response Plan (ERP) must be in place and workers shall be
sufficiently trained to manage spill incidents. Reference can be made to
Emergency Response and Preparedness plan (Appendix J) prepared by
Project Proponent.
The criteria for storage of petroleum products are as follows:
• Structural integrity of primary container, such as tanks, drums, or any

container, used to store petroleum products and chemicals must be strong
enough to hold substances without leaking or bursting.
• Secondary containment system bunds or drip trays:
o The storage area/bund should be concrete paved, bunded with a
capacity to contain 110% of the largest container volume;
o The bund base and walls must be impermeable to water and oil, and
checked regularly for leaks;
o Oil drums must have a drip tray with a capacity of not less than 25%
of the drum’s storage capacity or, for several drums situated together,
25% of the aggregated storage capacity;
o Any valve, pipe used for draining the contaminant system must not
penetrate the bund base and walls. A collection sump for rainwater
is recommended. Water collecting in the base of the bund may be
removed using either a manually operated pump or an automatic
pump;
o Roofing over the storage area should be used to prevent rainwater
getting into the bund;

o Operating schedules will include daily opening of the valve to
remove accumulated water which will also assist in identifying
minor leaks;
o Oil or a mixture of oil and water collected in the bund will be handled
as scheduled waste as per the Environmental Quality (Scheduled
Wastes) Regulations 2005.
o Skid tanks, if any, will be placed at a minimum distance of 750 mm
between the tank and the bund wall and 600 mm between the tank
and the base to enable inspection for leaks. Mobile bowsers will have
a suitably sized drip tray fitted underneath when in use.
8.3.4.1 Solid Waste
Due to the increasing number of waste disposal to landfills, a large number of the
landfills are no longer in operation as they have reached full capacity. Jabor-Jerangau
Landfill has the highest throughput in Pahang, with a throughput ranging from 350
to 500 tonnes per day. Even though there are plans to open more landfills to cope
with the demand, landfills are regarded as one of the major contributors to negative
environmental impact in Malaysia. With limited space for landfills and rising costs
of disposal, there is increased pressure and urgent need to tackle the waste
management issue and reduce the impact on the environment and general well-being
of the population.
Thus, a suitable Waste Management Plan (WMP) is encouraged to be developed and

implemented during the Project construction stage (refer to Appendix K for sample
of WMP). The WMP should be communicated to the Project team, contractors and
subcontractors. This is to ensure that all solid wastes generated are handled, stored
and disposed of according to good waste management practices.
Domestic wastes shall be segregated from construction wastes, and all solid wastes
generated are recommended to be treated according to the waste management
hierarchy: refuse, reduce, reuse, recycle, recover and then only disposal (Chart 8-3).

Chart 8-3 Waste Management Hierarchy
Refuse Most preferred
Reduce
Reuse
Recycle
Recover
Disposal Least preferred
Based on the waste management hierarchy, the most preferred method is to prevent
the generation of waste (refuse) whereas the least preferred method is waste disposal
to landfill. Further elaborations on the mitigation measures based on the waste
hierarchy model is detailed in the following sections.
a) Refuse
Unnecessary single-use disposables such as product packaging can be

avoided during procurement stage. Refusing helps to eliminate a lot of waste
from the start. When working with vendors, refuse unnecessary product
packaging and request reusable or returnable containers. Making smarter
purchasing decisions and setting standards and expectations early in the
process makes it easier for organizations to “refuse” waste in the first place.
b) Reduce
Waste reduction emphasises on the minimisation of materials at the source.

This also helps to reduce the cost for logistics, waste disposal and recycling.
Thorough planning, careful purchasing control and good site management

are important to minimise solid waste generation during construction stage.
Better communication and coordination between engineers and on-site
personnel can avoid unnecessary last-minute changes in designs, which leads
to wastes generation such as unused additional construction materials and
unwanted drawing plans.
Besides that, on-site staffs can also be trained to store and handle construction
materials at designated storage yard with care to reduce the amount of waste
due to damage.

c) Reuse
Materials that cannot be reduced will then be considered to be reused. The

wastes can be either reused again for its original purpose or repurposed into
a different function.
Construction wastes are often preferred to be reused either in other

construction projects or within the same project but in different phases.
Reusing construction wastes can help contractors to save costs on purchasing
the same new materials and on disposal costs. A list of potential reusing
option for different type of construction wastes generated from the Project
during construction phase are shown in Table 8-4.
Table 8-4 Recommended Reusage for Construction Materials

Components Source Recommended Reusage
Crushed and reused as an aggregate in new Portland
Concrete Structure
cement concrete or any other structural layer
Structural
Structure Steel beams can be reused in other projects
steel
Source: Recycle Coach (2019)
Domestic wastes that can be potentially reused includes plastic bottles and
glass jars. These reusable bottles and jars can be refilled and used back instead
of throwing them away. Staffs should also be encouraged to buy reusable
products instead of disposable ones to reduce solid wastes generation.
d) Recycle
Recycling wastes is defined as utilising wastes as raw materials in other

applications. Wastes prior to recycling must be segregated properly in
separate containers as they are generated. Packaging wastes such as wooden
pallets, and construction wastes like concrete and metals can be recycled.
Some construction foremen have stated they can avoid landfills 75% to 95%
of the time by invoking this segregation process. Storage bins can be labelled
accordingly so that waste is separated and stored in an efficient manner (Plate
8-4).

Plate 8-4 Proper Segregation and Storage of Solid Wastes for Construction Sites
Source: Ngem (n.d.)
e) Recover
The process of recovery is the generation of energy from waste materials that
cannot be reused or recycled. This can be carried out via various waste
recovery techniques such as pyrolysis, gasification, incineration, biodigestion
and briquetting. Materials that are separated for recovery can be sent to
licensed material recovery facilities.
f) Disposal
Wastes that cannot be reused, recycled or recovered must be collected and

disposed of at a designated landfill, i.e., Jabor-Jerangau Landfill, on a regular
basis by the respective waste contractor.
8.3.4.2 Scheduled Waste
Scheduled wastes should be managed according to the Guidelines for Packaging,

Labelling and Storage of Scheduled Wastes in Malaysia published by DOE.
Scheduled waste generated by the contractors are required to be managed as per the
procedure in Chart 8-4.

Chart 8-4 Flowchart for Contractor Scheduled Waste Handling
Scheduled wastes generated
Wastes stored in suitable container, i.e., drum/polybag/isotank
All waste (in drums and polybags) to be placed properly on pallets
Wastes should be properly labelled and accompanied with the Waste Card Information
Inform responsible person (from Project Proponent side) and prepare waste card
Responsible Person to fill up a Scheduled Waste Form and notify the Project Proponent's
Environmental Department
Project Proponent's Environmental Department to arrange for transportation of

scheduled wastes generated by contractor to existing scheduled wastes storage area
Scheduled wastes sent to existing scheduled wastes storage area A 342 (Plate 6-5)
The scheduled wastes generated during the construction stage will be stored and
managed according to the existing Scheduled Waste Management Plan (SWMP). The
existing SWMP was formed in accordance with the Malaysian regulatory
requirement.
The Project Proponent should ensure that the scheduled wastes should not be stored
more than 180 allowable days, and an accurate and up-to-date inventory in the in the
Electronic Scheduled Waste Information System (eSWIS). Consignment notes should
also be created where details of the waste, designated transporter and waste receiver
are all recorded within the system.
Labelling of scheduled wastes containers are very important for identification and
warning purposes. This must be carried out according to the Third Schedule of the
Environmental Quality (Scheduled Wastes) Regulations 2005 (Chart 8-5).

Chart 8-5 An Example of Label for Scheduled Wastes Container
Source: DOE (2014)
An example of characteristic labels is as shown in Plate 8-5.
Plate 8-5 Examples of Waste Characteristic Labels
Source: DOE (2014)

8.3.5 Socio-Economic Study
During the project construction phase, various measures have been provided in Table 8-5 to mitigate against the negative impacts perceived as
well as to enhance the occurrence of the positive impacts perceived. These recommended measures have been rated by the respondents surveyed
for adoption by the project proponent.
Table 8-5 Mitigation Measures for the Proposed Project During Construction Phase
Level of Concern
Mean
Measures Very Low Moderate Very High
Low (2) High (4) Score
(1) (3) (5)
Provide noise pollution control i.e., protective walls around the
0.5% 3.9% 23.9% 62.8% 8.9% 3.8
construction site
Provide air pollution control measures e.g., wash truck tires so that they
0.5% 5.4% 27.1% 56.9% 10.1% 3.7
are not dusty on the road and surrounding areas
Implement the Traffic Management Plan i.e., flagman, safety cone etc. 0.2% 6.2% 26.6% 57.6% 9.4% 3.7
Hotline/Channel for complaints 0.2% 7.1% 26.4% 57.6% 8.6% 3.7
Ensure construction sites are properly cleaned to prevent disease 0.2% 6.4% 26.4% 58.1% 8.9% 3.7
Provide safety measures at construction sites 0.2% 5.9% 27.8% 57.4% 8.6% 3.7
Centralized quarters for foreign workers to avoid conflict/stigma 1.0% 6.9% 19.7% 58.9% 13.5% 3.8
Prioritize locals for employment & business opportunities 0.2% 5.9% 19.2% 61.1% 13.5% 3.8
Ongoing public involvement from project proponents 0.2% 7.9% 23.2% 61.1% 7.6% 3.7
Proper management / disposal of construction waste 0.2% 6.9% 22.7% 62.1% 8.1% 3.7
Good hygiene management practices 0.2% 6.9% 23.6% 61.6% 7.6% 3.7
CSR (Corporate Social Responsibility) program with nearby residents /
0.5% 6.2% 27.6% 58.1% 7.6% 3.7
institutions, if any

It can be summarized that during the construction phase, these measures are deemed
important with at least 65% of the respondents having suggested that these
mitigative measures are at least ranked as High (4). Hence, all twelve recommended
mitigation measures during the construction phase have been rated to be at least
above the score of 4.
Considering that there are remaining not more than 35% who also ranked these
measures lower, hence the overall weighted mean scores incorporating all the
responses received suggests scores ranging from 3.7 to 3.8. These imply that a large
majority have close to high levels of preference for the adoption of such mitigative
measures.
The mitigating actions that could directly benefit the local populations concentrated
upon special quotas for employment of local people and career training for local
youths (Table 8-6). To prevent social problems with the local population, centralized
workers quarters are to be provided.
Table 8-6 Special Actions for Direct Benefits of Local Employment

Opportunities
Measures Available to Implement Perceived Positive Impacts During
Percent
Construction Phase
Set up special quota on employment for locals including existing workers at
89.7%
the current plant
Living quarters for local workers 73.9%
Skill development training for local youths 56.9%
8.4 OPERATION PHASE
8.4.1 Air Quality
Air pollutants in hydrogen and oxygen off gases generated from the proposed 2-
EHAcid plant processes do not contribute significantly to the Ground Level
Concentration (GLC) of the pollutants at the identified Air Sensitive Receptors (ASRs)
during normal operation, whereby the highest Maximum Average Incremental
Concentration (MAIC) of all the pollutants modelled is predicted for HCl at ASR 3
(Taman Balok Perdana) with a concentration of 0.6 µg/m3.
Generally, all the GLC of pollutants modelled at all identified ASRs are well within
the Standard 2020 limits of the Malaysian Ambient Air Quality Standard (MAAQS)
2013 and Ontario Ambient Air Quality Criteria. Apart from that, the emission
concentration limits of Aroma TOX are also complying with the limits stipulated in
Control of NMVOC Emissions, Second Schedule and Item I (Chemical and
Petrochemical Industry All Sizes), Third Schedule of the Environmental Quality
(Clean Air) Regulations 2014.
Although no significant air quality impact is anticipated from the additional of
another 2-EHAcid Plant, it is always good to encourage best management practice
where possible. The Project Proponent will ensure all the following mitigation
measures to implemented accordingly:
• Oxygen concentration inside the combustion chamber has to be measured

and controlled by variation of air flow.
• Aroma TOX has to be shut down if the flue gas oxygen content falls below 2%
vol.
• During high organic load or high amount of hydrogen containing off gases,
the natural gas flow has to be reduced to the minimum required amount of
the natural gas burner and the combustion chamber has to be cooled by
adding ambient air via blower. The temperature control value should be
1000oC and if the temperature exceeds 1250oC, Aroma TOX has to be shut
down.
• Steam injection system shall be installed for HP Flare Stack to ensure

smokeless operation of the flare.
• The preventive maintenance of HP/LP Flare Stack (i.e., flare tip, pilot,
labyrinth seal, etc.) and Aroma TOX (i.e., pilot burner, gas nozzles, air
windbox, etc.) components shall be carried out regularly to ensure that the
performance of HP Flare and Aroma TOX is at the optimum condition to be
able to receive and safely treat hydrogen off gas and oxygen off gas from the
proposed 2-EHAcid plant respectively.
8.4.2 Greenhouse Gas Emission
As described in Section 7.5.2, the total GHG emission from steam generation within
the entire ICS is 193,570.98 tCO2e/year. Project Proponent has rolled out several
emission reductions target to achieve their Net Zero ambition by year 2050. Table 8-
7 shows two fundamental components within BASF Petronas Chemicals
Sustainability Pillars (i.e., FC1: Climate Protection and FC4: Circular Economy).
With this framework in place, Project Proponent has shown to be committed in

taking proactive measures to champion the sustainability agenda and decarbonizing
their operations. Overall, the targets set in BASF Petronas Chemicals Sustainability
Pillars are in line with United Nations’ Sustainable Development Goals 9 and 12
(SDG 9 and SDG 12) (Chart 8-6).

Chart 8-6 Sustainable Development Goals

Table 8-7 BASF PETRONAS Chemicals Sustainability Pillars
Fundamental Components and Gaps Strategic Objectives
To establish an integrated energy management dashboard through systematic approach to visualize real time
energy consumption and the time-based energy performance indicators (EnPI) - link to GHG emissions and
FC1: Climate Protection future carbon management
Define pathway to net zero for achieving target & incorporate plan into site development plan (for site level
1. GHG Emission (measuresd in CO2e) projects)
Reduction (Baseline: 2018) Discussion on technology intensive BASF strategic projects and define proposed pathways and timelines -
o Current: 25% reduction in 2021 incorporate in Asset Development Plans
o Desired: 35% reduction by 2030 (Net Collation of data from all OPEX projects related to climate protection under one umbrella - centralized funding
Zero by 2050) approval, optimized funding possibilities, tax benefits, etc.
Identification of funding strategies to have better returns on climate protection projects (GITE, GITA, RECs),
syndication with regulatory agencies for participating in framing of new regulations
FC4: Circular Economy Strategic analysis for every waste created on site from the perspective of 4R (reduce, reuse, recycle and recover)
- linked to climate protection
1. Solid & Liquid Waste Reduction Review of existing disposal principles for more sustainable solutions - projects with external partners or
(Baseline: 2021) solution providers
o Current: 9294t (Oxo Oil) + 1996t (other Focus on non-hazardous waste (domestic waste, plant scrap disposal) - inventorise, segregation, recycling
waste) + 1775 t (WWTP sludge) possibilities - projects with external partners or solution providers
o Desired: TBD (Reduction % by 2025)
2. Reduction in GHG Emissions from Waste

to Steam Initiative (Baseline: 2021) Strategic discussions with PETRONAS and BASF Technology on change of feedstocks or bio-based feedstocks
o Current: 102,643t/a (OA) + 13,129 t/a
(HIB)
o Desired: TBD
Source: BASF Petronas Chemicals (2022)

Further reductions in GHG emissions from the project can be achieved by taking the
following actions that complement the implementation of the policy objectives:
i) Climate Protection
• Develop scoping tool with internal stakeholders
• Internal agreement on way forward with approval in CAPEX
• Development of roadmap based on identified measures and
agreement on strategic measures
• Identification of measures related to waste heat utilizations
• Identify all projects or improvement measures from all complexes on
an annual basis which are related to CO2 emission reduction measures
ii) Circular Economy

• Alternatives to existing disposal method (to change, reuse or recover)
• Implementation of ideas internally or with external solution
• Initiate discussion on change to bio feedstocks or feedstocks
• Identification of possible partners of bio-methane through grid and
creating strategic future planning
Noise from operational phase for industrial activities is long term and will cause
nuisance to the nearby sensitive receptors if not properly mitigated. The
recommended approach in noise control measures is as Chart 8-7:
Chart 8-7 Hierarchy of Noise Control
Elimination
Most
Effective
Substitution
Engineering Controls
Administrative
Controls
Least
Effective
PPE
Some of the general mitigation measures to reduce noise levels during operational
phase can be categorised as follows:
i) Substitution:
• Replace noisy equipment with silenced or muffled equipment.

ii) Engineering controls:
• Install effective silencer system to exhausts and valves;
• Provide proper enclosures for noisy equipment, i.e. gas turbine,
crushing system, generator set etc.;
• Isolate equipment in rooms, i.e. water pumps;
• Regular maintenance of the equipment (lubricate gears); and
• Practice standard operating procedures.
iii) Administrative controls:

• Train personnel to carry out proper and scheduled maintenance of
equipment in order to keep the equipment in good condition; and
• Reducing length of time the worker is required to work in noisy area.
iv) PPE:
• Provide workers with necessary personal protective equipment, i.e.
ear muffs.
In addition, where applicable, the source, path and receiver control option for
industrial premises is outlined in the “Guidelines for Environmental Noise Limits
and Control: Annex D: Best Practice To Minimise Noise Disturbance” issued by DOE
Malaysia can be adopted accordingly, as shown below (Chart 8-8):
Chart 8-8 Source, Path and Receiver Control Option for Industrial
Premises
8.4.4 Risk
The following measures are recommended based on the findings of the study.
Applying certain or all of these recommendations will ensure that risk is reduced to
a level as low as reasonably practicable (ALARP) and adherent to the DOE
Guidelines, December 2004.
• The existing ICS’s Emergency Response Plan (ERP) shall be updated to

address all potential scenarios in relation to those identified in this QRA;

• Design changes during the subsequent engineering phases post EIA should
be analysed to determine the severity of the potential hazards (via safety
studies i.e. hazard identification and HAZOP) due to the proposed changes.
The revised risk levels shall be in line with the governing risk criteria adopted
by DOE;
• The proposed facility is deemed to be a major hazard installation, in
compliance to the CIMAH Regulations 1996, its safety report and emergency
response plan shall be updated and submitted to the Department of
Occupational Safety and Health’s Major Hazard Division 3 months prior to
commissioning; and
• The proposed plant management has to ensure the implementation of an
effective health and safety management system which governs a safe
operating condition for the proposed facility. This will help minimise the risk
posed by the plant’s operation to be maintained within the acceptable limits.
8.4.5 Water Quality
The mitigation measures during operational phase are concerning the management
of WWTP and scheduled waste. The WWTP receives and treats both industrial
process wastewater and sewage generated from entire ICS complex. Mitigation
measure to prevent water quality degradation is discussed in this section.
Wastewater Treatment Plant
The WWTP treats the influent wastewater to comply with Standard B discharge
parameter as prescribed in Fifth Schedule of Environmental Quality (Industrial
Effluent) Regulation 2009. The operation of WWTP shall strictly adhere to the
Wastewater Treatment Plant Supervisory Manual prepared by the Project Proponent
(Refer to Appendix L).
• WWTP is designed to treat wastewater with maximum COD loading of 600

kg COD/hour. Incoming raw wastewater which exceeds the permissible
COD loading shall be diverted to off-spec wastewater tank to reduce COD
loading in the system.
• The quantity and quality of discharged effluent shall be recorded in a
dedicated logbook and made available during DOE’s inspection.
• Analytical equipment applied for monitoring effluent quality shall be
inspected and calibrated at suitable interval to ensure accuracy of
measurement.

8.4.6.1 Solid Waste
Solid waste generated during the operation phase mainly consists of domestic wastes,
such as office supplies waste and packaging wastes generated from the existing 2-
EHAcid staff. Some of the best management practices recommended are based on
the waste management hierarchy as shown in Chart 8-2 in Section 8.3.4.2.
a) Refuse
Unnecessary single-use disposables such as product packaging can be

avoided by helping to eliminate a lot of waste from the start. Making smarter
purchasing decisions early in the process makes it easier for organizations to
“refuse” waste in the first place.
b) Reduce
Awareness in reducing solid waste within the staff should be raised through
proper education and training programmes. Ensure sustainable and
responsible consumption within the staff can help to reduce unnecessary
solid wastes. Encourage staff to print only when necessary and to print
double-sided to reduce paper waste.
c) Reuse
Food packaging such as plastic bottles and glass jars can be reused to store
other food items instead of being disposed. Staffs should also be encouraged
to reuse paper that are only printed on one side, and binders or file folders
that are still in good condition.
d) Recycle
Solid wastes should be segregated in separate bins, where recyclable items

like cardboards, used paper, newspaper, unwanted bottles etc. can be
collected by Alam Flora Sdn. Bhd. to be recycled.
For wastes that cannot be easily segregated and recycled, consider alternative
products that are more easily recycled to be used.

e) Recover
Recovery of solid wastes can be carried out via various waste recovery
techniques such as pyrolysis, gasification, incineration, biodigestion and
briquetting. Materials that are separated for recovery are sent to licensed
material recovery facilities.
f) Disposal
Residual wastes must be sent to the nearest landfill, which is potentially

Jabor-Jerangau Landfill. Solid wastes that cannot be reused, recycled or
recovered must be stored properly prior collection from waste contractor.
8.4.6.2 Scheduled Waste
The scheduled wastes generated on site will be managed by the following competent
persons for Certified Environmental Professional in Scheduled Waste Management
(CePSWaM) (Table 8-8). A copy of the CePSWaM certifications can be referred in
Appendix M.
Table 8-8 List of Competent Persons for Scheduled Waste Management

Name Serial No.
Nur Asiah binti Che Noh CePSWaM/00129
Mahadi bin Samsudin Undergoing field training since 20/1/2022
Note: * CePSWaM Certification result for Mahadi bin Samsudin is attached in Appendix M
Scheduled wastes during operation stage are expected to be generated from both the
2-EHAcid production process and the maintenance works. Scheduled wastes
generated from the maintenance works like spent hydraulic oil, disposed
contaminated containers, and contaminated rags, must all be stored in the existing
scheduled waste storage areas (Plates 8-6 and 8-7).

Plate 8-6 Existing Scheduled Wastes Storage (A 345)
Plate 8-7 Existing Scheduled Wastes Storage (A 342)
For e-wastes management, the Project Proponent has a specific procedure to provide
a guideline for the disposal of e-wastes. There are specific e-waste bins located within
the entire ICS area, and there is e-waste bin located at the Oxo Complex’s control
building. The procedure for managing e-waste is as detailed in Chart 8-9.

Chart 8-9 Flowchart for E-Waste Handling
Employees must dispose respective e-waste into the e-waste bins
Responsible person (person-in-charge of the e-waste at the designated complex/area) to

fill up and submit forms once the bins are nearly full (estimate of 80%)
Project Proponent's Environmental Department will collect the waste and replace the bin
plastic lining
Project Proponent's Environmental Department will transfer all wastes into polybag
Project Proponent's Environmental Department will make arrangement to dispose this

material at DOE approved disposal facilities
The charge to complexes/areas will be based on the number of bins collected
The date of generation is the date when all e-waste is collected and transferred into
polybag
The main scheduled wastes generated during the operation stage is waste catalyst.
Waste catalysts are to be stored in drums in the existing scheduled wastes storage
area in the ICS, complete with labels and waste information as detailed in the
Environmental Quality (Scheduled Wastes) Regulations 2005. Apart from referring
to the handling and storage requirements listed in the DOE guidelines, the SDS of
the catalyst should also be referred for cleaning up, taking up or handling and
storage methods.
a) Methods for cleaning up or taking up in case of accidental release:

• Avoid dust formation and do not breathe in dust. Avoid contact with the
skin, eyes and clothing. Use personal protective clothing
• Dampen, pick up mechanically and dispose of. Dispose of absorbed
material as SW 409
b) Methods of handling and storing:

• Avoid dust formation and avoid inhalation of dusts. Avoid contact with
the skin, eyes and clothing. Processing machines must be fitted with local
exhaust ventilation.
• Containers should be stored tightly sealed in a dry place.

With regards to accidental release, the perimeter drainages and collection sumps
within the ICS are also equipped with emergency isolation valves, which aims to
prevent any possible discharge of accidental leakages or spillages to the external
drainages (Plates 8-8 and 8-9).
Plate 8-8 Emergency Isolation Valve Plate 8-9 Emergency Isolation Valve
at Drainage within ICS at Scheduled Waste Storage Area

Besides that, the existing scheduled wastes storage is also compared with the storage design criteria as per the Guidelines for Packaging, Labelling and Storage of Scheduled Wastes in Malaysia. A summary of the
comparison and recommendations for improvement is listed in Table 8-9.
Table 8-9 Storage Design of Existing Scheduled Waste Storage Area

Existing Scheduled Waste Storage Area Recommendations / Suggestions of Improvement
No. Storage Design Criteria1 Scheduled Waste Scheduled Waste Storage
Scheduled Waste Storage (A 342) Scheduled Waste Storage (A 345)
Storage (A 342) (A 345)
The storage area should provide 25% extra storage
1 capacity of the actual maximum amount of waste Complied Complied None None
generated
Storage duration of scheduled waste should not be
2 more than 180 days or as prescribed by the Complied Complied None None
Department of Environment
The entire storage area must be fenced-in and It is recommended to add

regarded as restricted area. Adequate signage should “DANGER” signage at
3 be put up clearly and visible with the word None Schedule Waste Storage Area
“DANGER” and “SCHEDULED WASTES A 345 and a chainlink fence
STORAGE”. for the storage area A 345.
Visible signages outside the scheduled wastes storage
Visible signage within fenced area with swing gate. Only

authorized personnel can enter A300 area.
The floor of the storage area and loading and

4 unloading area must be covered with concrete or any None None
suitable lining material, free of cracks and gaps

Storage (A 342) (A 345)
Floors are lined with concrete and free of cracks and gaps Floors are lined with concrete and free of cracks and gaps
The storage place should be sheltered or roofed or
5 Storage area A 342 is roofed Storage area A 345 is roofed None None
covered with suitable covering material
The entire storage area should be surrounded by a

concrete dike or other equivalent structure designed
to contain any spillage of the waste under the worst-
6 None None
case scenario. The capacity of the containment should
be 110% of the largest container stored in the storage
area.
Storage area A 345 is bunded. Sump pit is sufficient to

Storage area A 342 is surrounded by a structure
contain the accidental spillages.
There should not be any opening in the dike to None
7 Complied Complied None
prevent any leakage of waste from the storage area.
8 The dike area should be graded to a sump. Complied Complied None None
The storage area should be properly managed to None
9 prevent rain water or surface water from entering the Complied Complied None
storage area.
Any surface water run-off should be channeled to a

10 proper drainage system to avoid the water from None None
entering the storage area.
Proper drainage system available Proper drainage system available

The loading and unloading area should be designed Proper drainage system with gate valve available to
11 Proper drainage system available to contain spillages. None None
to contain any spillage. contain spillages.
The storage area should be equipped with ventilation Scheduled waste storage area is designed to be well- Scheduled waste storage area is designed to be well-
12 None None
system for volatile wastes. ventilated. ventilated.
Separate compartments should be provided for
different groups of incompatible wastes. The
13 compatibility of scheduled wastes can be referred to Complied Complied None None
Fourth Schedule, Regulation 2 of the Environmental
Quality (Scheduled Wastes) Regulations 2005.

Storage (A 342) (A 345)
Storage area should be designed to provide adequate
14 Complied Complied None None
emergency escape route.
Fire extinguishers and spill kit at A342

The storage area should be equipped with fire fighting
and other emergency response equipment as well as
15 None None
spill kit and comply fully with the requirements of the
Fire and Rescue Department of Malaysia.
Shared fire extinguisher and spill kit located at A342
Fire extinguisher and emergency shower outside

scheduled wastes storage A 342
Source: 1. DOE, 2014

8.4.7 Socio-Economic Study
During the project operation phase, nine measures to mitigate against the negative impacts perceived as well as to enhance the occurrence of the
positive impacts perceived have been recommended by the communities surveyed to be essential and have to be adopted by the project
proponent (Table 8-10).
Table 8-10 Community Preference and Ratings on Their Expectations of Implementation of Mitigation Measures Against Negative
Impacts During Operation Stage
Expectations
Mitigative Measures Very Low Moderate High Very Mean
Low (1) (2) (3) (4) High (5) Score
Use filters to control air pollution and odors from factory smoke 0.0% 3.7% 23.2% 63.3% 9.9% 3.8
Water is recycled for operational purposes and liquid waste is treated first before being
0.0% 3.2% 26.4% 61.3% 9.1% 3.8
discharged into the river
Practicing Best Management Practices (BMP) in the factory area i.e. storage of chemicals 0.0% 4.2% 26.6% 61.3% 7.9% 3.7
Allocate an adequate buffer zone to separate the plant operating area with the nearest
0.0% 3.7% 24.9% 63.3% 8.1% 3.8
residential area
Ensure all factory workers comply with traffic rules 0.0% 4.4% 24.9% 62.6% 8.1% 3.7
Effective safety measures in the factory area to prevent accidents to workers and the public 0.2% 3.7% 25.6% 62.3% 8.1% 3.7
Ensure that foreign workers practice social ethics and understand the culture of the locals
0.0% 1.5% 27.3% 62.6% 8.6% 3.8
by holding briefing sessions for them
Ensure waste management system i.e. scheduled waste, solid waste is effective and orderly 0.0% 2.7% 24.1% 65.8% 7.4% 3.8
CSR (Corporate Social Responsibility) program with nearby residents / institutions, if any 0.0% 3.9% 26.4% 61.6% 8.1% 3.7
Overall 0.0% 3.4% 25.5% 62.7% 8.4% 3.8

It can be summarised that:
• These measures are deemed important with at least 70% of the respondents
having suggested that these mitigative measures are at least ranked as High
(4). Hence, all nine recommended mitigation measures during the operation
phase have been rated to be at least above the score of 4.
• The weighted mean scores incorporating all the responses received suggests
scores ranging from 3.7 to 3.8 that confirmed the observations made earlier
that a large majority have close to high levels of preference for the adoption
of such mitigative measures.
Similarly, the respondents suggested a number of other actions to be taken to ensure

the local population could benefit from the proposed project during project operation
(Table 8-11). Among these actions that could directly benefit the local populations,
there was special emphasis being given to the setting up of quotas for employment
of local people that was given a mean score of 3.9 (approaching high priority) out of
a maximum score of 5 by the respondents. In this respect, the proposed project could
assure existing workers at the current project site of job placement and skill
development. The other measures recommended also are approaching high
priorities with mean scores exceeding 3.7. These measures are about the promotion
of recycling and reduction of waste programmes, adoption of environmentally
friendly practices, and the production of supplementary products with commercial
value.

Implementation of Enhancement Activities Of Positive Impacts During
Operation Stage
Level of Support
Mean
Measures Very Low Moderate High Very
Score
Low (1) (2) (3) (4) High (5)
Setting of quotas for local
employment in advanced
technology sector including 0.0% 1.5% 18.5% 67.7% 12.3% 3.91
for existing workers at the
plant
Use environmentally
friendly processes in the 0.2% 2.5% 22.7% 67.2% 7.4% 3.79
plant
Practice recycling and waste
0.2% 3.0% 22.2% 66.3% 8.4% 3.80
reduction activities
Production of
supplementary products 0.2% 3.4% 26.1% 63.1% 7.1% 3.73
with commercial value
Overall 0.2% 2.6% 22.4% 66.1% 8.8% 3.81

8.4.8 Health Impact Assessment
During the Project construction phase, preventive measures should be undertaken to

control fugitive dust and vehicular emissions, even though the impact is expected to
be localised and will not reach nearby air sensitive receptors. Measures such as water
spraying on dusty roads and surfaces should be diligently practiced.
During the Project construction phase, control of disease vectors like insects and
reservoirs like rodents should be carried out. This include keeping the construction
site free of garbage and construction wastes which may act as breeding sites for
insects, especially mosquitoes and cockroaches, and habitats for rodents and stray
animals.
Even though an abnormal Project operation resulting in the release of volatile

organics is very unlikely to happen, a contingency plan like plant shutdown and an
emergency response plan must be in place to cater to such an incident.
8.5 PROJECT ABANDONMENT

In the event that the Project is abandoned, the following measures shall be taken:
• Project abandonment plan must be submitted to DOE Pahang for review and
acceptance at least three (3) months prior to the abandonment of the Project;
• Any temporary site facilities, such as site offices, must be demolished;
• Construction wastes and domestics wastes must be disposed off from the
Project site at a landfill approved by the local authority; and
• Scheduled wastes must be transported out from the Project site and managed
adequately by DOE licensed contractors.
8.5.1 Project Abandonment Plan
If the Project is abandoned during the construction or operation stage of the Project,
the Project Proponent is required to prepare a Project Abandonment Plan to address
and mitigate potential environmental impacts that may arise due to the
abandonment of Project facilities and wastes. The Abandonment Plan should be
prepared in accordance with the EIA Guidelines for Petrochemical Industries (2018)
published by the DOE, to address the relevant issues for the construction or
operation stage as necessary. It will serve as a guide for safe closure and/or
decommissioning of the Project. The process of Project abandonment should be
carried out with prior engagement and consultation with the relevant authorities
including DOE.

The Abandonment Plan serves to control and minimize impacts and risks to the
environment and the public such as proliferation of pests and disease vectors in
abandoned structures, hazards to the on-site staff and workers due to the
deterioration of structures and facilities, and accidental spillage or leakage of
chemicals etc. The preparation should look into pre-abandonment activities,
abandonment activities and post abandonment activities.
8.5.1.1 Pre-Abandonment Activities
Based on the Abandonment Plan preparation framework outlined in the EIA

Guidelines for Petrochemical Industries (2018), a Best Practical Environmental
Option (BPEO) assessment should be performed to determine the Project’s best
decommissioning / abandonment option. The assessment and the outcome shall be
described and presented in the Abandonment Plan. The BPEO concept is as
illustrated in Chart 8-10.
Chart 8-10 Best Practical Environmental Option Concept
Public Perception / Acceptability
Regulatory Framework
Environment
Health and
Safety
BPEO Cost
Technological
Feasibility

The BPEO study is recommended to be undertaken using the following method,
within the broader context of public perception/stakeholder acceptability:
• Identification of potential options;
• Assessment of the options identified based on strategic conditions,
environmental, health and safety considerations, and cost in terms of capital
and maintenance/operational costs; and
• Comparison of the performance of the options and identification of the BPEO.
8.5.1.2 Abandonment Activities
During the abandonment phase, the following activities are expected for the Project:
• Tendering process and awarding of contract for decommissioning and
demolition work;
• Removal and disposal of scheduled wastes, demolition materials and refuse;
• Disassembling equipment and plant;
• Removal of plant piping, cabling, storage facilities and reusable components;
• Demolition of building and breaking up for removal;
• Site levelling; and
• Site stabilization/rehabilitation, if necessary.
With reference to the potential environmental impacts associated with the Project
abandonment (as listed in Section 7.6), the aspects and associated management plans
below, not limited to the following, are expected to be presented in the Abandonment
Plan:
• Procedures for dismantling or demolishing;
• Procedures for managing excess materials and wastes that would be
generated as a result of the decommissioning of the facility;
• Identify all hazards and risks associated with the decommissioning activities
and outline mitigation measures to minimize such hazards; and
• Emergency response and communication procedures to address concerns
related to the decommissioning activities.
8.5.1.3 Post Abandonment Activities
Appropriate site remediation and restoration activities shall be described if residual

site contamination, due to accidental leaks and spills, is detected. A post
decommissioning monitoring programme should also be conducted to assess the
environmental changes and implications of the selected decommissioning option
and to monitor any potential residual impacts.

09 ENVIRONMENTAL MANAGEMENT PLAN
Section 9
ENVIRONMENTAL MANAGEMENT
PLAN (EMP)
SECTION 9 : ENVIRONMENTAL MANAGEMENT PLAN (EMP)
9.1 INTRODUCTION
This Section documents the environmental management framework which covers
the construction phase of the Project. The framework explains the basic mechanism
of the organizational set-up and the environmental monitoring system of the Project.
An Environmental Management Plan (EMP) for the Project will be prepared and
submitted to the Department of Environment (DOE) Kuantan for approval prior to
the commencement of the construction work.
9.2 ENVIRONMENTAL MANAGEMENT OBJECTIVES

The main objective of the EMP is to ensure that the conditions stipulated by the
mitigation measures specified in the Environmental Impact Assessment (EIA) report
are implemented and all regulatory environmental standards and criteria are
adhered with. The long-term objectives of the EMP are:
• Planning the environmental management of the Project in order to comply

with the requirements of the DOE and other legal requirements;
• Monitoring the effectiveness of mitigation measures to address
environmental issues through monitoring programs;
• Reporting plans and actions to maintain a lasting record of environmental
plans and activities of the Project;
• Reviewing current and past practices in order to assess their effectiveness
within the Project;
• Communicating the Project’s environmental policy as well as environmental
management practices to all relevant parties; and
• Paving the way for the long-term sustainability of the environmental quality.

9.3 ORGANISATION STRUCTURE
9.3.1 Chain of Responsibilities
An effective environmental management requires a clear understanding of the roles

and responsibility of each party involved in the Project. Another important aspect is
clear definition of lines of communication and reporting in ensuring that proper
actions can be carried out and implemented towards effective environmental
management at site.
9.3.2 Department of Environment
DOE will not be directly involved in the environmental management of the Project,
but rather will act as the regulatory authority to administer the environmental laws
and regulations that BASF PETRONAS Chemicals Sdn. Bhd., contractors and sub-
contractors must adhere to.
9.3.3 Project Proponent
BASF PETRONAS Chemicals Sdn. Bhd. is responsible in the effective

implementation of mitigation measures in accordance to the EMP as well as the
environmental quality on-site. The responsibilities also include reporting the
environmental compliance of the Project to DOE Pahang as well as compliance to all
related regulations and requirements.
9.3.4 Environmental Consultant
BASF PETRONAS Chemicals Sdn. Bhd. may appoint an Environmental Consultant

to assist in the management of the EMP and to provide advice on the environmental
related issues arise from the development activities. The responsibilities of the
Environmental Consultant may include, but not limited to, the following:
• To provide professional advice and guidance to BASF PETRONAS Chemicals

Sdn. Bhd., contractors and sub-contractors on issues which may arise with
regards to the implementation of the EMP and the monitoring program; and
• To advise BASF PETRONAS Chemicals Sdn. Bhd., contractors, and sub-
contractors on the improvement of mitigation measures needed to minimize
and prevent adverse environmental impacts.

9.3.5 Environmental Officer
The Contractor shall designate a site personnel as Environmental Officer to oversee

all day-to-day environment-related matters and be responsible for the
implementation of the mitigation measures, and to liaise with the relevant agencies
pertaining to all matters related to the environment. The responsibilities of the
Environmental Officer shall include, but not limited to, the following:
• To monitor the various environmental parameters as stipulated in the EMP

or subsequent revisions of the EMP;
• To review environmental monitoring data as well as to access the
effectiveness of the monitoring program and the adequacy of the
implemented mitigation measures;
• To prepare and compile all relevant environmental reports for submission to
DOE Pahang;
• To arrange and conduct regular site inspections, at least once per week;
• To inspect Contractors’ equipment and work methodologies with respect to
pollution control and environmental mitigation;
• To anticipate potential environmental issues that may require mitigation;
• To adhere to the agreed protocols or those in the Contract Specifications in
the event of non-compliance or complaints;
• To provide advice on environmental matters; and
• To promote environmental awareness in line with the Project Proponent’s
environmental policy.
9.3.6 Establishment of Environmental Performance Monitoring

Committee (EPMC)
BASF PETRONAS Chemicals Sdn. Bhd. will establish a project Environmental

Performance Monitoring Committee (EPMC) to monitor the environmental
performance and effectiveness of pollution prevention and mitigation measures
(P2M2), and the status of regulatory compliance of the Project.
The EMPC shall be represented by all relevant parties involved in the Project
implementation and chaired by a senior member representing the BASF PETRONAS
Chemicals Sdn. Bhd. The chairman shall be responsible for ensuring the decisions of
the meeting are responsibly executed. The EMPC shall meet at a minimum, once in
a quarter and the minutes of the meeting shall be maintained.
9.3.7 Meeting and Reporting System
Environmental management will be part of the Project meeting agenda to ensure that
the environmental issues are adequately addressed. The Environmental Consultant

and Environmental Officer will be involved during the Project meetings to work
together with other site staff in order to carry out effective environmental
management on-site.
Reports will be submitted to the DOE Pahang or other relevant local authorities (if
necessary). The reporting shall cover:
• Compliance to and effective of environmental control measures detailed in the

EIA approval conditions;
• Monitoring results of river water quality, air quality, noise and other
environmental elements; and
• Record of public complaints (if any) and the responses taken to address the
complaints.
9.4 POLLUTION PREVENTION AND MITIGATION

MEASURES (P2M2)
The EMP shall be prepared by an appointed Environmental Consultant registered
with DOE and submitted to DOE Pahang for approval. Construction works will
commence only after EMP approval is obtained. The EMP will adhere to the
requirements stated in “Chapter 6 – Post Submission Stage of EIA Report,
Environmental Impact Assessment Guidelines in Malaysia 2016”.
The main focus of the EMPs will be based on the impacts and mitigation measures
identified in Sections 7 and 8 of this EIA report:
Water Pollution
Air Pollution
Waste Generation
Noise Pollution
9.5 PROPOSED MONITORING PROGRAMME

Environmental monitoring is necessary and important to gauge the effectiveness of
all the mitigation measures implemented on-site. The environmental monitoring will
be carried out at regular intervals for all relevant environmental parameters. The
program will require sampling and personnel competent in interpretation of the
parameters and identifying its relationship with the ongoing works. The important
environmental components to sample shall include:
• River water quality monitoring;

• Air quality monitoring; and
• Noise level monitoring.

The monitoring of these components can be further categorized into Performance
Monitoring (PM), Compliance Monitoring (CM), and Impact Monitoring (IM) as
discussed in the following subsections.
The proposed monitoring program is shown in Tables 9-1 and 9-2 and the proposed
sampling locations are shown in Figures 9-1 and 9-2.
9.5.1 Performance Monitoring
Performance monitoring will focus on inspecting the effectiveness of the mitigation

measures put in place. During construction, the performance monitoring will focus
on sedimentation control while during operation, focus will be on monitoring of
wastewater treatment plant and water injection system for air emission.
9.5.2 Compliance Monitoring
Compliance monitoring refers to the monitoring of all the P2M2 implemented to

ensure compliance to the EIA Conditions of Approval (COAs). This will include the
monitoring of surface run-off discharge during construction, air emission, noise level
and wastewater discharge during operation.
9.5.3 Impact Monitoring
Impact monitoring will be conducted to verify that the findings of the EIA study of
the potential impacts identified during EIA scoping process are correct, appropriate
mitigation and prevention measures are properly implemented, and the measures
are effective in mitigating the adverse impacts to the environment. This usually
involves the monitoring of ambient levels.
9.5.3.1 Water Quality
Water quality monitoring will include the monitoring of surrounding rivers. Water
samples are proposed to be collected at the existing six (6) water sampling points
during the construction and operation stage (Figures 9-1 and 9-2). The parameters to
be monitored during construction and operation phase are listed in Tables 9-1 and
9-2. The water sampling and analysis must be carried out by a SAMM accredited
laboratory. Environmental Monitoring Report (EMR) will be submitted to DOE
Pahang on a quarterly basis.

9.5.3.2 Air Quality
Monitoring for ambient air quality will take place at three (3) points during the
operation stage (Figure 9-2). The parameters to be monitored as well as the allowable
limit are shown in Table 9-2. The sampling and analysis should be carried out by a
SAMM accredited laboratory on a quarterly basis, while reporting to the DOE
Pahang is to be also made on a quarterly basis.
9.5.3.3 Noise Level
Noise impact monitoring will take place at three (3) points during the construction
stage and three (3) points during the operation stage (Figure 9-1 and Figure 9-2). The
parameters to be monitored as well as the allowable limit are shown in Table 9-1 and
Table 9-2. The sampling and analysis should be carried out by a SAMM accredited
laboratory on a quarterly basis, while reporting to the DOE Pahang is to be also made
on a quarterly basis.
9.6 ENVIRONMENTAL AUDITING

A third-party environmental site audit is proposed to be carried out once every four
(4) months during the construction phase and on annual basis during operation. The
main objective of the audit is to ensure that the environmental management
implemented at site is conducted according to the relevant environmental laws,
regulations as well as requirements stipulated in the EIA and EMP approval
conditions, in addition to all the other existing environmental compliances.
Any specific instances of non-compliance with legislative standards and the probable
cause of such non-compliance will be identified. This will ensure that the Project
Proponent fulfils their Environmental Pledge as attached in the beginning of this
report. The third-party auditor will be appointed by BASF PETRONAS Chemicals
Sdn. Bhd.
9.7 ENVIRONMENTAL MAINSTREAMING AND

GUIDED SELF-REGULATION
BASF PETRONAS Chemicals Sdn. Bhd. is committed to mainstreaming
environmental protection into the Project and towards self-regulation to ensure the
quality of environment is protected during the construction and operation of the
CHP plant.
BASF PETRONAS Chemicals Sdn. Bhd. is also fully committed and will take full
responsibility and accountability for instituting effective pollution prevention and

mitigation measures (P2M2) and regulatory compliance at all phases of the Project
implementation. This self-regulation is also very important to BASF PETRONAS
Chemicals Sdn. Bhd. as part of its good governance.
BASF PETRONAS Chemicals Sdn. Bhd. will ensure organisational commitment to

environmental regulatory compliance by all personnel and at all levels of the
organisation, including its consultants, contractors, sub-contractors, suppliers and all
other parties involved in the Project implementation. Competent persons will be
appointed to operate the various pollution control and waste management systems
of the Project.
9.7.1 Environmental Policy
BASF PETRONAS Chemicals Sdn. Bhd. will adopt the existing Health, Safety and
Environmental policy of the company to convey the environmental commitment to
all parties involved in the Project, including external stakeholders (refer to Appendix
P).
9.7.2 Environmental Budgeting
Sufficient environmental budgeting (EB) will be set aside solely for the purpose of
implementing measures to comply with environmental regulations and other
environmental protection measures. The budget will include the installation of
pollution control facilities, provision of personnel and purchase of performance
monitoring equipment during construction phase. The environmental budget for
each phase will be detailed out in the EMP Report.
9.7.3 Environmental Monitoring Committee
The Environmental Performance Monitoring Committee (EPMC), chaired by BASF

PETRONAS Chemicals Sdn. Bhd., will monitor the environmental performance and
effectiveness of P2M2 and status of regulatory compliance of the Project.
The EPMC will be represented by all parties involves and will be chaired by senior
management personnel from BASF PETRONAS Chemicals Sdn. Bhd. The chairman
will be responsible for all the decisions made during EPMC meetings. The meetings
must be held regularly, at least once a quarter, and the minutes of meeting properly
documented and maintained. Additionally, an Environmental Regulatory
Compliance Monitoring Committee (ERCMC), which meets at least once a year, shall
be chaired by the Project Director.

9.7.4 Environmental Facility
The Environment Facilities (EF) include best management practices, scheduled waste
management, sewage treatment system, performance monitoring equipment during
the construction. The assessment of the adequacy of the EFs installation and their
effectiveness in complying with the regulatory standards and requirements or
conditions approval will be rated and documented as part of the Guided Self-
Regulation (GSR).
9.7.5 Environmental Competency
Environmental Competency (EC) prescribes that competent persons will be

appointed to operate the various pollution control and waste management systems
of the Project. In addition, a comprehensive training programme to produce
competent persons and trained support staff will be provided to ensure full
compliance with the DOE requirements. The names of the competent persons and
the training plans will be submitted to DOE Pahang.
The monitoring programme will be supervised by the competent personnel who are
able to understand, interpret and analyse the results in relation to the on-going
construction works or possible external factors that leads to any non-compliances.
9.7.6 Environmental Reporting and Communication
9.7.6.1 Internal Reporting
In accordance with the DOE’s requirements, other internal environmental reports

will be prepared, including:
• Environmental Performance Monitoring Document (EPMD); and

• Performance Monitoring Report (PMR).
In addition to the reports mentioned above, other documents that need to be

prepared and maintained include the Checklist of P2M2s List Sheet, Installation
Sheet, Maintenance Sheet, Site and P2M2 Inspection Sheet, Photograph Folder Sheet,
Corrective Action Sheet, Performance Monitoring Sheet and others. The EPMD and
PMR will be maintained for three years after completion of Project development.
9.7.6.2 Environmental Performance Monitoring Document
Before the commencement of site works for each phase, the EO will prepare the
EPMD. The EPMD will describe in detail how the contractor will comply with the

EIA COAs as well as ensuring that all the P2M2s are functioning and effective in
mitigating the impacts. The details will include, among others: performance
monitoring equipment/instruments, sampling protocols and analysis, monitoring
parameters, sampling frequency, preventive and corrective maintenance procedure
for the P2M2, discharge compliance, record keeping and others. The EPMD will also
include CM and IM, wherever relevant.
9.7.6.3 Performance Monitoring Report
Environmental monitoring will be conducted as specified in the EPMD and the

findings or results obtained from the monitoring exercise will be discussed in the
PMR. The results or findings will be analysed and evaluated to gauge the
effectiveness of the P2M2s implemented at the Project site. Comparison will be made
against the recommended standards or guidelines. Statistical techniques and
graphical presentations of the results will be prepared wherever appropriate. The
PMR will also make definitive conclusions on the overall performance of the P2M2s
and suggest improvement measures to be taken, if necessary. The PMR will be
submitted to the EPMC of the Project and the document shall be kept and maintained
for inspection by DOE officers.
9.7.6.4 Environmental Transparency
The best option to implement the environmental transparency (environmental

sustainability report/web-site/billboards/fliers, etc.) will be taken into
consideration and implemented at a later date during construction and operational
phases. Environmental sustainability reporting is proposed to be incorporated into
the company’s corporate reporting.
9.7.6.5 Environmental Mainstreaming Tools Compliance Report
The Environmental Mainstreaming Tools Compliance Report (EMT Compliance

Report) will be submitted to the DOE Pahang, at least thirty days before the
commencement of work on site. The example of the template is shown in Chart 9-1.


Table 9-1 Proposed Monitoring Programme and Auditing during Construction Phase
Monitoring
Location Frequency Parameters Compliance Levels Reporting Requirements
Components
• Design of ESCP to comply with the Guidelines for Erosion and
• Structural integrity, functionality,
Sediment Control in Malaysia
• Weekly practicality and frequency of • Weekly reporting in
• Performance monitoring to be conducted by EO or equivalent
Performance Monitoring: • After rainfall maintenance for all ESCP Performance Monitoring
personnel
• All ESCP on site event of > 12.5 Report (PMR). PMR to be kept
mm • TSS on-site for DOE inspection.
• 50 mg/l
• Turbidity
• 250 NTU
Silt Trap/Sediment Basin
Silt Trap/Sediment • TSS • 50 mg/L to maintain baseline TSS level
Basin • Turbidity
• Monthly
EQ (Sewage) Regulations 2009 - (Standard B)
Compliance Monitoring: • After rainfall
Septic Tank • 5.5-9.0
• Silt trap or sediment basin discharge event of > 12.5 Quarterly to DOE Pahang
mm • pH • 200 mg/l
• Septic tank
• COD • 50 mg/l
• BOD • 100 mg/l
Septic Tank
• TSS • 20 mg/l
• Quarterly • NH3-N • N/A
Water Quality
• E. coli
Impact Monitoring:
• W1: Upstream of Sg. Balok
(N 03° 58’ 32.2” E 103° 21’ 26.3”)
Parameters: NWQS Class III:
• W2: Downstream of Sg. Balok
(N 03° 58’ 25.7” E 103° 21’ 28.0”) • Temperature • Normal ± 2°C
• W3: Upstream of retention pond • pH • 5–9
discharge into PKNP drainage • DO • 3-5 mg/l
(N 03° 59’ 02.3” E 103° 22’ 11.6”) • BOD • 6 mg/l
• W4: Downstream of retention pond • Quarterly • COD • 50 mg/l Quarterly to DOE Pahang
discharge into PKNP drainage • NH3-N • 0.9 mg/l
(N 03° 58’ 45.2” E 103° 21’ 57.3”) • TSS • 150 mg/l
• W5: Stormwater drainage within ICS • Turbidity • N/A
boundary • O&G • N
(N 03° 58’ 52.4” E 103° 22’ 01.5”) • Faecal coliform • 5000 count/100 ml
• W6: Retention Pond downstream of
WWTP discharge
(N 03° 58’ 46.4” E 103° 21’ 57.0”)

Monitoring
Components
Impact Monitoring:
• N1: Northwestern boundary of the ICS-
A300 Blockfield
(N 03° 59’ 02.7” E 103° 21’ 39.0”) Sixth Schedule of Guidelines for Environmental Noise Limits and
Parameter:
Noise Level • N2: Southeastern of the ICS-D600 • Quarterly Control Third Edition 2019: Quarterly to DOE Pahang
Blockfield • L10 : 24 hour – day, evening, night
• L10 = 80 dBA
(N 03° 59’ 06.3”, E 103° 22’ 09.4”)
• N3: Southeastern of the ICS-D200
Blockfield
(N 03° 59’ 02.3”, E 103° 22’ 10.5”)
Environmental • Once every four Every four months to DOE
• Project Site N/A • EIA COA, existing legislation and regulations
Audit months Pahang
Notes:
1. N/A means not available. 3. NWQS means National Water Quality Standards.
2. N means No visible floatable materials or debris, no objectional odour or no objectional taste. 4. MAAQS means Malaysian Ambient Air Quality Standards, 2013.

Table 9-2 Proposed Monitoring Program and Auditing during Operation Phase
Monitoring
Components
Weekly reporting in Performance Monitoring
Performance Monitoring: Structural integrity, functionality,
Weekly Following design specifications Report (PMR). PMR to be kept on-site for DOE
• Wastewater treatment plant practicality and frequency of maintenance
inspection.
EQ (Industrial Effluent) Regulations 2009 –

Parameters:
Standard B
• Temperature
• 40°C
• pH
• 5.5-9.0
Compliance Monitoring: • COD
Monthly • N/A • Quarterly to DOE Pahang
• BOD
• Discharge from WWTP • 50 mg/l
• NH3-N
• 20 mg/l
• TSS
• 100 mg/l
• Colour
• 200 ADMI
• O&G
• 10 mg/l
Impact Monitoring:
Water Quality • W1: Upstream of Sg. Balok

(N 03° 58’ 32.2” E 103° 21’ 26.3”)
• W2: Downstream of Sg. Balok Parameters: NWQS Class III:
(N 03° 58’ 25.7” E 103° 21’ 28.0”)
• Temperature • Normal ± 2°C
• W3: Upstream of retention pond
• pH • 5.0-9.0
discharge into PKNP drainage
• DO • 3-5 mg/l
(N 03° 59’ 02.3” E 103° 22’ 11.6”)
• BOD • 6 mg/l
• W4: Downstream of retention
Monthly • COD • 50 mg/l Quarterly to DOE Pahang
pond discharge into PKNP
• NH3-N • 0.9 mg/l
drainage
• TSS • 150 mg/l
(N 03° 58’ 45.2” E 103° 21’ 57.3”)
• Turbidity • N/A
• W5: Stormwater drainage within
• O&G • N
ICS boundary
• Faecal coliform • 5000 count/100 ml
(N 03° 58’ 52.4” E 103° 22’ 01.5”)
• W6: Retention Pond downstream
of WWTP discharge
• (N 03° 58’ 46.4” E 103° 21’ 57.0”)

Monitoring
Components
Impact Monitoring:
• N1 : Northwestern boundary of
the ICS-A300 Blockfield
(N 03° 59’ 02.7” E 103° 21’ 39.0”)
(N 03°59'4.92", E 103°21'59.38") Parameter: Second Schedule of Guidelines for Environmental
Noise Quality • N2 : Southeastern of the ICS-D600 Quarterly • LAeq Day (7:00 am – 10.00 pm) Noise Limits and Control Third Edition 2019: Quarterly to DOE Pahang
Blockfield • LAeq Night (10.00 pm – 7:00 am) • LAeq = 75 dBA (day); 75 dBA (night)
(N 03° 59’ 06.3”, E 103° 22’ 09.4”)
• N3 : Southeastern of the ICS-D200
Blockfield
(N 03° 59’ 02.3”, E 103° 22’ 10.5”)
EQ (Clean Air) Regulations 2014
Parameter: • 50 mg/m3
• 100 mg/m3
• Total PM
• 700 mg/m3
• Sum of NO and NO2, expressed as NO2
• 650 mg/m3
• Sum of SO and SO2, expressed as SO2
• 7.5 mg/m3
Compliance Monitoring • CO
• 200 mg/m3
Quarterly • H2S Quarterly to DOE Pahang
Stack XX-9680 • 76 mg/m3
• HCl
• 32 mg/m3
• NH3
• 0.05 mg/m3
• Cl
• 20 mg/m3
• Hg
(in case of halogenated hydrocarbons)
Air Quality • NMVOC
150 mg/m3
(other than halogenated hydrocarbons)
Impact Monitoring
• A1: North western boundary of Parameter: Standard 2020 of MAAQS
the ICS-A300 Blockfield • 100 µg/m3
• PM10 (24 hour)
(N 03°59'2.7", E 103°21'39.0")
• PM2.5 (24 hour) • 35 µg/m3
• A2: South western of the ICS-
Monthly • SO2 (24 hour) • 80 µg/m3 Quarterly to DOE Pahang
A100 Blockfield
• NO2 (24 hour) • 70 µg/m3
(N 03°59'7.1", E 103°21'49.5")
• O3 (8 hour) • 100 µg/m3
• A3: South eastern of the ICS-D600
• CO (8 hour) • 10 µg/m3
Blockfield
(N 03°59'6.3", E 103°22'09.4")
Environmental
• Project Site Annually N/A • EIA COA, existing legislation and regulations Annually to DOE Pahang
Audit
Notes:
1. N/A means not available.
2. N means No visible floatable materials or debris, no objectional odour or no objectional taste.
3. NWQS means National Water Quality Standards.

Chart 9-1 Environmental Mainstreaming Tools Compliance Report
Name of Company /Organisation:
Address:
DOE’s reference file:
Name of EMT Compliance Report preparer:
Designation:
Date:
Signature
ENVIRONMENTAL MAINSTREAMING TOOLS COMPLIANCE TABLE

Date of Self-assessment of Comments
EMT
Implementation strength of EMT (if any)
EP
EB
EPMC
ERCMC
BMPs
EMC
IETS
APCS
SWMI
LABF
EF PMI
Others
CSEC
CePIETSO
CePSWAM
EC
CePSO
CeBFO
Others
CC
DA
ERC
IR
Others
ESR
WS
ET
BB
FL

EP = Environmental Policy
Give the date the EP was formulated and the review date, if EP review was made. If EP is newly
formulated, give the date of its formulation. Make your own assessment of the strength of the
message of environmental commitment in you EP by assigning your own rating (1: Poor; 2: Fair; 3:
Average; 4: Good; 5: Excellent). Submit your current EP as evidence
EB = Environmental Budgeting
Give the date your organisation started or will start allocating budget specifically for
environmental purposes. Make your assessment of the adequacy of the EB for implementing
measures to comply with environmental requirement of the EQA and its regulations or approvals
conditions by assigning your own rating (1: Poor; 2: Fair; 3: Average; 4: Good; 5: Excellent). Provide
a statement stating the amount of EB for the previous year as evidence.
EMC = Environmental Monitoring Committee

Give the dates the EPMC and ERCMC were set up or will be set up in your organisation. Make
your own assessment of the strength of the representativeness of the members of the committees
by assigning your own rating (1: Poor; 2: Fair; 3: Average; 4: Good; 5: Excellent). Submit the
organisation charts of the EPMC and ERCMC as evidence.
EF = Environmental Facility
IETS = Industrial Effluent Treatment System; APCS = Air Pollution Control System; BMP= Best
Management Practices; SWMI= Scheduled Waste Management Infrastructure; LABF= Laboratory
Facilities; PMI= Performance Monitoring Instruments.
Give the dates the EF components were installed or will be installed in your organisation. Make
your own assessment of the adequacy of the EFs installation and their effectiveness in complying
with the regulatory standards and requirements or approval conditions by assigning your own
rating ((1: Poor; 2: Fair; 3: Average; 4: Good; 5: Excellent). Provide information on EF components
which are relevant to your organisation.
EC = Environmental Competency
CSEC = Certified Sediment and Erosion Control; CePIETSO = Certified Environmental
Professional in IETS Operation; CePSO = Certified Environmental Professional in Scrubber
Operation; CeBFO = Certified Environmental Professional in Bag Filter Operation; CepSWAM =
Certified Environmental Professional in Scheduled Waste Management.
Give the date the organisation’s personnel were certified or will be attending the certification
course(s). Make your own assessment of the adequacy of the number of personnel required by
your organisation to comply with the regulatory requirements or approval conditions by assigning
your own rating (1: Poor; 2: Fair; 3: Average; 4: Good; 5: Excellent). Provide the name of the
Competent persons in your organisation or submit your training plan to get your staff certified as
evidence. Provide information only on EC requirements which are relevant to your organisation.

ERC = Environmental Reporting and Communication
CC = Communication Channel; DA = Data Analysis; IR = Internal Reporting.
Give the dates your organisation started to implement or will start to implement the ERC
components (CC, DA and IR). Make your own assessment of the adequacy of the ERC components
and their effectiveness in ensuring environmental concerns are immediately reported to the
responsible persons in your organization for appropriate action by assigning your own rating ((1:
Poor; 2: Fair; 3: Average; 4: Good; 5: Excellent). Submit CC flow chart as evidence.
ET = Environmental Transparency
ESR = Environmental Sustainability Report; WS= Website; BB=Billboard; FL = Fliers
Your organisation may want to implement this EMT immediately or you may want to study the
best option to implement this EMT in your own situation and implement it at a later date. If
possible, give the dates your organisation is planning to start implementing the ET components
(ESR, WS, BB, flier issuance, or others). Make your own assessment of the implementation status
of the implementation of ET components in your organisation by assigning your own rating (1:
Poor; 2: Fair; 3: Average; 4: Good; 5: Excellent). Submit CC flow chart as evidence.


South
Terengganu China
Sea
Pahang !
Gebeng
!
Balok
Beserah
!
N2
S g.
Rasau N1 N3
W3
W5
W6
W4
Kg Hulu Baluk
Ja
la n
W1
Ge
be
n g 1/11
W2
o
Date 05-07-2022
LEGEND Proposed Monitoring Location
Project No EJ 727
Project Site Water Quality Produced by HMZ
ICS Boundary Noise Level Revision A
0 125 250 500
Water Body
Major Road
Proposed Environmental
Meters
Monitoring Locations During FIGURE 9-1
GCS WGS 1984
Map Units: Degree
Construction
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 9-1 Monitoring Construction)
Source: ERE Consulting Group (2022), Earthstar Geographics, Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community
South
Terengganu China
Sea
Pahang !
Gebeng
!
Balok
Beserah
!
A2 N2 A3
S g.
Rasau N1 A1 N3 W3
W5
W6
W4
Kg Hulu Baluk
Ja
la n
W1
Ge
be
n g 1/11
W2
o
Date 05-07-2022
LEGEND Proposed Monitoring Location
Project No EJ 727
Project Site Air Quality Produced by HMZ
ICS Boundary Noise Level Revision A
0 125 250 500
Water Body
Major Road
Water Quality Proposed Environmental
Meters
Monitoring Locations During FIGURE 9-2
GCS WGS 1984
Map Units: Degree
Operation
\\192.168.1.6\gis\GIS-Data\Project\EJ 727 2- Ethylehaxanoic Acid BASF\Maps\APRX\EJ727 BASF\EJ727 BASF.aprx (Fig 9-2 Monitoring Operation)
Source: ERE Consulting Group (2022), Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community, Maxar
10 STUDY FINDINGS
Section 10
STUDY FINDINGS
SECTION 10 : STUDY FINDINGS
The Project involves the construction and operation of a 2-EHAcid Plant within the
Integrated Chemical Site of BASF PETRONAS Chemicals Sdn. Bhd. The study
findings are summarized in Table 10-1 below.
Table 10-1 Summary of the Study Findings

Environmental Impact
No. Study Findings
Elements Significance
Construction Phase
• Fugitive dust emissions generated from the
Project site are expected not to travel far
Not
1 Air Quality enough to cause any adverse impacts or
significant
nuisance to the surrounding air sensitive
receptors
• No incremental noise is predicted from the
Not
2 Noise construction activities towards the existing
significant
noise level and sensitive receptors
• Surface runoff generated from construction
activities is expected to be minimal
3 Water Quality Low
• The impact can be mitigated through the
usage of existing
• Most of the solid wastes will be comprised of
domestic wastes, where the estimated
generation quantity during maximum
Waste
4 Low number of staff is 102.5 kg/day
Management
• Scheduled wastes that are mainly generated
will be from the maintenance of construction
vehicles and machinery on site.
• Most local residents around the Project site
feel that the proposed Project would bring
positive impacts rather than negative
impacts.
Operation Phase

No. Study Findings
• During normal operation, the predicted
maximum average incremental
concentration (MAIC) and Ground Level
Concentration (GLC) at the sensitive
receptors will all meet their respective
1 Air Quality Low guideline values under the MAAQS 2013
(2020) or the OAAQC 2020
• Under abnormal operation scenario, there
will be a release of certain volatile organics
over a maximum duration of 1 hour, but this
scenario is very unlikely to happen
• Proposed Project represents only 1.9% of the
total GHG emission from the ICS, indicating
Greenhouse Gas Not that the Project will contribute to only an
2
Emission significant insignificant emission increment compared
to the overall emissions from the operation
of the entire ICS
• No incremental noise is predicted from the
Not
3 Noise operation of the Project towards the existing
significant
noise level and sensitive receptors
• Upon discharge of Standard B limit
effluents, BOD, COD and TSS levels is
expected to increase during 7Q10 low flow
event. Nonetheless, the Project Site is located
in industrial area where the waterway
receives discharge from multiple industrial
complexes. Furthermore, occurrence of 7Q10
low flow incidents is low hence the flow rate
4 Water Quality Low under normal conditions will be higher than
flow rate used for the assessment
• The BOD, COD and TSS levels is expected to
deteriorate receiving waterways during raw
effluent discharge. However, the likelihood
of Scenario 2 event to occur is minimal as
Project Proponent will ensure all best
management practices related to WWTP are
performed properly
• Estimated solid waste generation during the
operation stage will increase from 7.38
kg/day to 9.43 kg/day due to an addition of
Waste
5 Low 5 new operation staff for the Project
Management
• Scheduled wastes generated will mainly
consist of waste catalyst (2.3 MT/yr) from
the production process
Operation Phase

No. Study Findings
• All hazard quotients calculated for the air
pollutants exposure at the most sensitive air
sensitive receptors during a normal Project
operation scenario are below 1, indicating
that chronic, non-carcinogenic health effects
are unlikely to occur, even after a lifetime
exposure to the air pollutants
Health Impact • No further HRA was conducted for air and
6 Low
Assessment water quality impacts during construction
stage as no significant health impacts on
humans are expected from fugitive dust
emissions and TSS
• No further HRA was conducted for water
pollutants during the Project operation as
the likelihood of raw wastewater discharge
is very unlikely
• Level of awareness of local residents
towards the proposed Project is very low,
nonetheless, a majority of them have
moderate to very high support
• The 1 x 10-5 per year IR contour of the
proposed Project remains within the
established industrial development
Quantitative
• The 1 x 10-6 per year IR contour of the
8 Risk Low
proposed Project remains within the
Assessment
established industrial development only
and do not encompass involuntary
recipients of industrial risks.


REF REFERENCES
REFERENCES
REFERENCES
ATSDR (Agency for Toxic Substances and Disease Registry). 1999. Mercury-
ToxFAQs. https://www.atsdr.cdc.gov/toxfaqs/tfacts46.pdf. (Accessed on
12 February 2022).
ATSDR (Agency for Toxic Substances and Disease Registry). 2016. Hydrogen
chloride. https://www.atsdr.cdc.gov/toxfaqs/tfacts173.pdf. (Accessed on
24 November 2016).
A.W. Cox, F. L. (2000). Classification of Hazardous Locations. Totton: Hobbs the Printers
Limited.
BASF. (2021). Sustainability Along the Value Chain.
Bernama.com. (2022, March 10). KASA Implements Flood Disaster Risk Assessment
Based on Climate Change Projections. Kuala Lumpur, Malaysia .
British Standards Institution. (2014). BS 5228-1:2009+A1:2014 Code of Practice for Noise
and Vibration Control on Construction and Open Sites - Part 1: Noise. British
Standards Institution.
Cameo Chemicals. 2022. 1-butene.
https://cameochemicals.noaa.gov/chemical/18041.
(Accessed on 28 June 2022.
CDC (Centers for Disease Control and Prevention). 2013. Carbon monoxide.
http://www.cdc.gov/niosh/topics/co-comp/. (Accessed 31 December
2013).
CDC (Centers for Disease Control and Prevention) 2022. Chlorine.
https://www.cdc.gov/niosh/topics/chlorine/default.html#:~:text=Exposu
re%20to%20low%20levels%20of,harmed%20from%20exposure%20to%20chl
orine. (Accessed on 28 June 2022).
CDC (Centers for Disease Control and Prevention). 2022. Methyl tert-butyl ether
(MTBE) factsheet.
https://www.cdc.gov/biomonitoring/MTBE_FactSheet.html.
Chemsain Konsultant Sdn Bhd. (2014). Detailed Environmental Impact Assessment for
the Proposed Development of a New 30 kT/Y 2-Ethylhexanoic Acid Plant at the
Integrated Chemical Site in Gebeng, Kuantan Pahang. Subang Jaya: Chemsain
Konsultant Sdh Bhd.
Decker, F. (2018, March 13). How to Convert Steam to BTU. Retrieved from Sciencing:
https://sciencing.com/convert-steam-btu-8495235.html
Department of Environment. (2004). Environmental Impact Assessment Guidelines for
Risk Assessment. Putrajaya: Department of Environment.
Department of Environment. (2005). Environmental Quality (Scheduled Wastes)
Regulations 2005. Department of Environment (DOE) Malaysia.
Department of Environment. 2012. Guidance document on health impact assessment
in environmental impact assessment. Putrajaya: Department of Environment.
Department of Environment. (2014). Guidelines for Packaging, Labelling and Storage of
Scheduled Wastes in Malaysia. Department of Environment Malaysia.
Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Department of Environment. (2019). Guidelines for Environmental Noise Limits and
Control (Third Edition) (Reprint 2021). Putrajaya: Department of Environment.
Department of Environment, Malaysia. (2018). Environmental Impact Assessment
Guidelines for Petrochemical Industries. Putrajaya: Department of Environment,
Malaysia.
Department of Statistics, Malaysia. (2022). Key Findings: Population and Housing
Census of Malaysia 2020. Putrajaya: Department of Statistics, Malaysia.
Dockery, D.W. and Pope, C.A. 1994. Acute respiratory effects of particulate air
pollution. Annu. Rev. Public Health, 15 : 107-32.
Dockery, D.W. and Pope, C.A. 1996. Epidemiology of acute health effects : Summary
of time series studies. In : Wilson, R. and Spengler, J.D. (eds.). Particles in our
air : Concentrations and health effects. Boston : Harvard University Press.
Dr. Nik and Associates Sdn. Bhd. (2021). Proposed Development of a Permanent Disposal
Facility (PDF) for Water Leach Purification (WLP) Residue on Lot 31375, Gebeng
Industrial Estate, Pahang Darul Makmur. Kuala Lumpur: Dr. Nik and
Associates Sdn. Bhd.
East Coast Economic Region Development Council (ECERDC). (n.d.). ECER Master
Plan 2.0 - The Next Leap (2018 - 2025).
Economic Planning Unit. (2021). Twelfth Malaysia Plan (2021-2025). Putrajaya:
Economic Planning Unit.
EnHealth Council. 2001. Health impact assessment guidelines. Canberra :
Commonwealth Department of Health and Aged Care.
Geosyntec Consultants Sdn. Bhd. (2014). Final Report Soil and Groundwater Study at
the Kawasan Perindustrian Gebeng Industrial Estate. Petaling Jaya: Geosyntec
Consultants Sdn. Bhd.
Global Demand for Plasticizers Continue to Rise. (2017). Additives for Polymers, 10-11.
Hassan, N. K. (2020, December 17). Puluhan Kereta Terkandas Banjir Kilat di Sungai
Ular. Kuantan, Malaysia.
Health and Safety Executive. (2017, November 6). Failure Rate and Event Data for Use
Within Risk Assessments.
IARC (International Agency for Research on Cancer). 2021. Agents classifed by the
IARC Monographs, Volumes 1–130.
https://monographs.iarc.who.int/agents-classified-by-the-iarc/. (Accessed
on 10 February 2022).
IHS Markit. (2021, May). Plasticizers - Chemical Economics Handbook. Retrieved from
ihsmarkit.com: https://ihsmarkit.com/products/plasticizers-chemical-
economics-handbook.html
Ironside Farrar Environmental Consultants. (2021). Best Practicable Environmental
Option (BPEO) Assessment. Ironside Farrar Environmental Consultants.
Jabatan Alam Sekitar Malaysia. (2020). Buku Kompendium Jabatan Alam Sekitar
Keluaran 2020. Putrajaya: Jabatan Alam Sekitar, Kementerian Alam Sekitar
dan Air.
Jabatan Perancangan Bandar dan Desa Negeri Pahang. (2019). Rancangan Struktur
Negeri Pahang 2050.

James, R.C. 1985a. Risk assessment. In : Williams, P.L. and Burson, J.L. (eds.).
Industrial toxicology. New York : Van Nostrand Reinhold..
James, R.C. 1985b. Neurotoxicity : Toxic effects in the nervous system. In : Williams,
P.L. and Burson, J.L. (eds.). Industrial toxicology. New York : Van Nostrand
Reinhold.
Majlis Perbandaran Kuantan. (2017). Rancangan Tempatan Daerah Kuantan 2035
(Penggantian). PLANMalaysia.
Ministry of Health Malaysia. 2008. Annual report 2008.
Ministry of Health Malaysia. 2020. National Health and Morbidity Survey, 2019.
Shah Alam: Institute for Public Health, Ministry of Health Malaysia.
Ministry of Health Malaysia. 2021. Health facts 2021: Reference data for 2020. Kuala
Lumpur : Health Informatics Centre, Planning and Development Division,
Ministry of Health Malaysia.
New York State Department of Health. 2021. The facts about ammonia: Technical
information.
https://www.health.ny.gov/environmental/emergency/chemical_terroris
m/ammonia_tech.htm#:~:text=Exposure%20to%20high%20concentrations
%20of,and%20nose%20and%20throat%20irritation. (Accessed on 5 April
2021).
New Jersey Department of Health and Senior Sevices, 2002. Hazardous substance
fact sheet: Butyraldehyde.
https://nj.gov/health/eoh/rtkweb/documents/fs/0299.pdf. (Accessed on
29 June 2022.
New Jersey Department of Health. 2008. Hazardous substance fact sheet: Isoprene.
New Jersey Department of Health. 2009. Hazardous substance fact sheet: Pentane.
New Jersey Department of Health. 2008. Hazardous substance fact sheet: Butane.
New Jersey Department of Health. 2016. Hazardous substance fact sheet: Methyl
alcohol.
New Jersey Department of Health. 2016. Hazardous substance fact sheet: Hydrogen
Ngem, S. (n.d.). Waste Management in Construction Sites. Retrieved from sutori.com:
https://www.sutori.com/en/story/waste-management-in-construction-
sites--Y5wRGWXZ5ojSvzvGkH9piL1x
Risktec Solutions DMCC. (2022). Quantitative Risk Assessment (QRA) - Integrated
Chemical Site (ICS) & Port Tank Farm (PTF) QRA. Risktec Solutions DMCC.
Searl A. 2004. A review of the acute and long term impacts of exposure to nitrogen
dioxide in United Kingdom. Edinburgh: Institute of Occupational Medicine.
Research Report TM/04/03.
Stern, A.C., Boubel, R.W., Turner, D.B. and Fox, D.L. 1984. Fundamentals of air
pollution, 2nd edition. London : Academic Press, Inc.
Thermo Fisher Scientific. 2014. Safety data sheet : 2-ethylhexanal.
USEPA 2013. Nitrogen dioxide.
http://www.epa.gov/air/nitrogenoxides/health.html (accessed on 31
December 2013).

Ware J.H., Spengler J.D., Neas L.M., Samet J.M., Wagner G.R., Coultas D., Ozkaynak
H. and Margo S. 1993. Respiratory and irritant health effects of ambient
volatile organic compounds: The Kanawha County Health Study. American
Journal of Epidemiology, 137(12): 1287–1301.
Yahoo Finance. (2021, December 31). Outlook on the Plasticizers Global Market to 2030 -
Featuring BASF, ExxonMobil Chemical and LG Chem Among Others -
ResearchAndMarkets.com. Retrieved from Yahoo!Finance:
https://finance.yahoo.com/news/outlook-plasticizers-global-market-2030-
161400830.html?guccounter=1&guce_referrer=aHR0cHM6Ly93d3cuZ29vZ2
xlLmNvbS8&guce_referrer_sig=AQAAAIIv1He2LD2EcDQxg_Lo_R5e2Sh5
EiFu274Uv5Q_PzSx3mefle7rTsW0o6V_Nqs89UD1pF9DIS1O5WlNfq8uAGY
0

Volume 1 - Main Report

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Volume 1 - Main Report

Uploaded by

Copyright:

Available Formats

PROPOSED 2-ETHYLHEXANOIC ACID II

PLANT IN EXISTING INTEGRATED

Environmental Impact Assessment

Environmental Impact Assessment (EIA)

Project Code EJ 727

Files H:\ERE Projects\EJ 727 2-Ethylhexanoic Acid

PROPOSED 2-ETHYLHEXANOIC ACID II PLANT IN EXISTING

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

I declare the following:

Signature : Official Stamp:

Date : 4 July 2022

1. Joyce Wong B. Eng. (Chemical) - - - Waste Deva Kumari

2. Arularasu B. Sc. (Marine - - - Water Quality Sharmila Devi

SECTION 1 : INTRODUCTION 1-1

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ES-i

SECTION 3 : STATEMENT OF NEED 3-1

SECTION 4 : PROJECT OPTIONS 4-1

SECTION 5 : PROJECT DESCRIPTION 5-1

ii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

SECTION 6 : EXISTING ENVIRONMENT 6-1

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA iii

iv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

SECTION 7 : EVALUATION OF IMPACTS 7-1

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA v

vi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

SECTION 8 : PROPOSED MITIGATION MEASURES 8-1

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA vii

SECTION 9 : ENVIRONMENTAL MANAGEMENT PLAN (EMP) 9-1

viii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

SECTION 10 : STUDY FINDINGS 10-1

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA ix

Appendix A Existing 2-EHAcid Plant DEIA Approval

2-EHAcid 2-Ethylhexanoic Acid

x Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xi

xii Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Figure 1-1 Project Location Plan 1-11

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xiii

Table 1-1 Coordinates of the Project Site 1-2

xiv Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xv

xvi Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA

Proposed 2-EHAcid II Plant in Existing ICS at BPC: EIA xvii