685248382.

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CHAPTER
13
Environmental Impact
Assessment

13.1 Introduction

13.1.1 Purpose of This Document

This Environmental Impact Report (EIR) is an informational document intended to
disclose to the public and decision-makers the environmental consequences of the proposed
“Lube Oil Production by Re-refining of Waste Engine Oil”- a KTI Distillation Process. This
document assesses the environmental impacts due to the project, as well as the cumulative
environmental impacts in the vicinity of the project area. The Pakistan Environmental
Protection Agency requires potential environmental impacts of proposed projects be
evaluated, and that feasible methods to reduce, avoid, or eliminate identified significant
adverse impacts of these projects be included as part of the project. This document is
intended as an information document that, in itself, does not determine whether a project will
be approved, but aids in the local planning and decision-making process.

13.1.2 Project Overview

In December 2000, the United States Environmental Protection Agency (U.S. EPA)
promulgated regulations requiring that the sulfur content in motor vehicle Lube Oil be
reduced from 500 ppm to 15 ppm by June 1, 2006. This lube oil has been processed in a
manner that removes an extremely high proportion of the sulfur bearing compounds that
otherwise would result in air pollutant emissions when combusted.
Thus, a primary objective of the Project is to produce pure lube oil with minimum
sulfur contents as required by the PEPA as well.

The KTI Project would implement a series of modifications and additions focused on three
objectives:
 Produce lube oil containing less than 15 parts per million (ppm) sulfur.
 Allow the Refinery to efficiently use a broader array of used oil as feedstock.
 Improve Refinery efficiency and increase crude throughput capacity. As a result of
this change, gasoline production levels would be maintained at current levels and
there would be an increase in lube oil production.

The KTI Project components would consume 194 gallons per minute of freshwater for
cooling tower service in the new hydrotreater, and would increase Refinery wastewater flows
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to the water treatment plant by 60 gallons per minute. As a part of the Project, we propose
concurrent reductions in fresh water use at the Refinery (a reduction of 200 gallons per
minute). The result would be no net increase in freshwater consumption or wastewater flow.
Electrical power consumption at the Refinery would approximately increase by 5.5
megawatt (MW); the additional power would be generated in the facility’s on-site
cogeneration plant. Normal operations would produce small quantities of hazardous waste
(selenium cake, copper cake and oily contaminated material). In addition, relatively small
amounts (40 cubic yards) of hazardous waste will be created during periodic maintenance
turnarounds.
The incremental used oil that would be processed at the Refinery as a result of the
proposed facilities would generally be imported and transported to the Refinery by an
existing pipeline. The Project would involve very small increases in vehicle, rail, and barge
traffic. The Project would create one additional full-time position (4 to 5 employees) at the
Refinery.

13.1.3 Key Areas of Environmental Concern

This study examined the potential impacts of the proposed project. All of the topics in
the current PEPA Checklist were studied: Aesthetics, Air Quality, Agriculture Resources,
Biological Resources, Cultural Resources, Energy, Geology and Soils, Hazards and
Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral
Resources, Noise, Population and Housing, Public Services, Parks and Recreation,
Transportation/Traffic, and Utilities and Service Systems.

13.1.4 Organization of the Document

This document is organized into the following sections:
• Introduction
• Summary of Environmental Impacts: Summarizes environmental impacts that would
result from implementation of the proposed project. The summaries indicate the level of
significance of those impacts.
• Environmental Settings, Impacts and Mitigation Measures: Contains an analysis of
environmental issue areas. Discussion of each issue area is divided into: a) the setting, which
describes environmental conditions and regulatory information; b) the standards of
significance for determining the degree or level of potential environmental impacts for each
issue; c) potential impacts, which indicate the environmental effects that are anticipated from
the proposed project, and d) mitigation.
• Alternatives: Describes the alternatives to the proposed project and lists their associated
environmental effects.

13.2 Summary of Environmental Impacts

13.2.1 Summary of Impacts of the Proposed Project

This section provides a summary of the environmental impacts of the proposed “Lube
Oil Production By Re-refining of Waste Engine Oil”- a KTI Distillation Process, as
developed during this analysis. The impacts of the proposed Project and the mitigation
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measures that are included as a part of the proposed project have been extracted from the
analyses and evaluations presented. To assist readers with a brief overview of the results of
the analysis contained in this document, Section 13.2.2 presents summary statements of
impacts from each environmental area of study. Each summary statement is a formal
statement of impact and proposed mitigation as well as level of significance before and after
mitigations is applied.

13.2.2 Review of Proposed Project Impacts

13.2.2.a Air Quality

The construction and implementation of the proposed KTI Project would lead to impacts
on both the local and regional air quality. The Project would lead to two potentially
significant impacts.
 Construction of the project could cause local air quality impacts from fugitive dust
and emissions.
 Operational activities associated with the implementation of the Project would
increase air pollutant emissions (mainly H2S ) by potentially significant values.
With the implementation of proposed mitigation measures, both construction and
operational impacts of the proposed Project on the regional and local air quality would be
reduced to a less than significant level.

13.2.2. b Biological Resources

Placement of the new facilities and modification of other existing facilities could result in
the following impacts on biological resources:
 Increased ship traffic associated with increased refinery capacity has a small but
present potential to result in accidental releases of toxic materials in Arabian Sea that
may affect the waters there, as well as nearby wetlands.
These impacts can be reduced to less than significant levels with the implementation of
the proposed mitigation measures.

13.2.2. c Cultural Resources

Construction of the Project facilities may cause substantial adverse changes to the
significance of currently unknown cultural resources. This potentially significant impact
would be reduced to less than significant by standard mitigation measures and legal
requirements.

13.2.2.d Energy
The Project, as proposed, would not encourage activities that result in the use of large
amounts of fuel or energy, nor would it use fuel or energy in a wasteful or inefficient manner.
The overall impact of the proposed Project on energy resources would be less than
significant. The net increase in electrical energy would be approximately 5.5 MW. This
power would be supplied from the onsite cogeneration Project.
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In addition, the additional heat input for these processes would typically be provided
by refinery gas, but under some supply or market conditions, natural gas would be used to
supplement the use of refinery gas at these facilities.

13.2.2.e Geology, Soils and Seismicity

Several potential impacts related to geology, soils, and seismicity are identified for
this Project. Each of these impacts would be reduced to less than significant by prescribed
mitigation measures. Effects that could occur as a result of the implementation of the Project
are:
 Facilities would be exposed to expansive soils and natural settlement.
 In the event of a major earthquake in the region, seismic ground shaking could
potentially injure persons at the project site due to structural damage of facility
structures. Ground shaking could potentially expose persons and property to seismic-
related hazards, including localized liquefaction, earthquake-induced land sliding and
seismically induced settlement.
The potentially significant impacts would be reduced to less than significant by
compliance with applicable rules and regulations, and incorporation of proposed mitigation
measures.

13.2.2.f Public Health

Public exposure to toxic air contaminant (TAC) emissions from the Project can result
in an increase in health risks. However, the incremental health risks from the Project are
extremely small when compared to typical day-to-day health risks. Since the predicted health
risk increments from the Project are less than the significance thresholds, the impacts are less
than significant. No additional mitigation measures would be required.

13.2.2.g Public Safety

The risks to public safety from potential accidents from the proposed Project are low,
and the impacts from plausible accidental releases would be less than significant. Possible
accidental releases of acutely hazardous substances that might result from the Proposed
Project were evaluated, and none were found to cause an unhealthful offsite impact and occur
within the expected 30-year life of the plant. No additional mitigation measures would be
needed.

13.2.2.h Hydrology and Water Quality

The proposed Project could result in an increase of pollutants in the process
wastewater stream. The refinery is required to adequately treat the increase in effluent
contaminants to avoid exceeding discharge limits. In addition, operation of some Project units
would produce additional wastewater and construction activities could generate wastewater
and storm water runoff volumes that could increase wastewater inflow into the Refinery
wastewater treatment plant. Conservation measures are proposed as part of the Project to
yield no net increase in wastewater or discharge. This resulting wastewater volume would not
exceed the maximum hydraulic capacity or available retention capacity of the wastewater
treatment plant at the Refinery. The potentially significant impacts would be reduced to less
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than significant by standard mitigation measures and legal requirements. No additional

mitigation measures would be required.

13.2.2.i Land Use, Plans and Policies

All land use effects of the Project either would be less than significant or would result in
no impact. No mitigation is required.
 Project construction may result in temporary secondary impacts to adjacent industrial
uses and nearby residences.
 The Project would not conflict with established plans, policies and ordinances.
 The Project would not potentially divide an established community.
 The Project would not affect a habitat conservation plan or natural community plan.

13.2.2.j Noise
The Project would impact the ambient noise environment during both the construction
and operational phases of the Project. Since the Project would be located on refinery
property, Project-related noise impacts would primarily be to offsite residential receptors.
Noise during construction of the proposed Project would temporarily increase the ambient
noise levels at the residential receptors to levels above those specified in the Pak EPA
standards. This impact would be mitigated to a less than significant level with the
incorporation of the proposed mitigation measures.

13.2.2.k Public Services

This review concludes since there was no Initial Study that all effects related to the
implementation of the Project would be less than significant. No mitigation would be
required.
 The Project would not adversely affect the ability of the Fire Department to provide
fire suppression and emergency response services to the refinery.
 The Project would not adversely affect the Police Office ability to provide police
protection services to the Project site and area as a whole.
 The proposed Project would not substantially degrade the quality of existing park and
recreation facilities or require the provision of new or expanded facilities.
 The proposed Project would not adversely affect other public services such as
libraries or hospitals.

13.2.2.l Transportation
The construction phase of the Project during the major turnaround (which includes both
the turnaround and the Project construction traffic) at the Refinery would generate additional
daily and peak hour trips.
 The proposed construction phase of the Project would result in a potentially
significant impact to the a.m. peak hour operations during peak Project construction.
Operation of the Project would add up to four to five new employees, generating up to
two new a.m. peak hour trips, and two p.m. peak hour trips. The project will increase
operational truck traffic for coke, sulfur and waste trucking.
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13.2.2.m Utilities and Service Systems

The implementation of the Project would not result in an incremental increase in refinery
raw water demand. The Project would have less than significant effects on the other utilities
and services systems:
 The Project would not cause wastewater effluent discharges to exceed wastewater
quality limitations of the Regional Water Quality Control Board.
 Implementation of the proposed Project would not substantially increase the amount
of wastewater treated at the wastewater treatment plant.
 The proposed Project would slightly increase the quantity of spent catalyst and sludge
from the refinery wastewater treatment plant.
No mitigation would be required for effects on other utilities and services systems.

13.2.2.n Agriculture
The Project is located entirely within the developed area of the Refinery. There are no
agricultural resources on or in the vicinity of the project site. All construction and operation
activities would take place in the already developed portions of refinery property. Thus, the
Project’s impact on agricultural land use would be less than significant. The project would
have no impact. No mitigation measures are required.

13.2.2.o Mineral Resources

There are no mineral resources mapped within the vicinity of the Refinery. Therefore,
implementation of the Project would not result in the loss of availability of a locally
important mineral resource recovery site delineated on a local General Plan Maps.

13.2.2.p Population and Housing

Housing or population would not be displaced as a result of the Project, nor would
population growth be stimulated. For these reasons, there would be no significant Project
impacts on population or housing. It is anticipated that up to 4 or 5 new permanent employees
would be required in the long-term operation of the Project. This increase in employment at
the Refinery would be a less than significant impact. No mitigation would be required.

13.3 Environmental Setting, Impacts and Mitigation

To achieve the objectives of the proposed project, the Refinery would modify existing
and install new refining equipment. The nature of the project includes substantial flexibility
as to whether and how to implement the various project components, and therefore, a range
of project variables must be considered in the impact analysis.

13.3.1 Project Impact Analysis

A refinery consists of process units that cannot operate independently. Changes in the
operation of one process unit would result in changes to the operations of other process units.
The individual contributions of each affected interdependent refinery component result in an
impact of the Project that is the sum of these individual contributions. Examples of such
impacts include visual, air quality, noise and traffic impacts. The analysis in this
Environmental Impact Report (EIR) presents the impacts that would result from
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implementing the full Project, which is construction and operation of each and every
component described as part of the project. In nearly all cases, the analysis of the full project
reveals the greatest or worst-case impacts that could occur under any combination of
components and leads to the mitigations that would be necessary to reduce those worst-case
impacts to less than significant.
In a few instances, however, the worst-case impact for a given environmental issue
might not occur under the full Project, but would occur as a result of one of the project
variables. Thus the impact analysis in this EIR also considers the possible effects of the
project “variables”—Design, Location, Schedule and Certainty—in the Project as
proposed, on environmental impacts. If any aspect of these four variables would result in a
substantive difference in the environmental impact of the Project or in the mitigation that
might be applied, those aspects are discussed and the individual effects are traced. If these
variables would not result in an increase in impact or require a material change in mitigation,
they may not be discussed.
In the event that specific operational considerations, dimensions of the components,
equipment locations, and variations in the timing of construction or the absence of any
project component were critical to identifying or mitigating a potential environmental impact
of the project, these considerations are discussed under the related impact or mitigation
presentations in this section.

13.4 Project Alternatives

The discussion of alternatives does not need to be exhaustive. The key issue is
whether the Reasonable range of alternatives is considered that could feasibly accomplish the
basic objectives of the project and could avoid or substantially reduce significant
environmental impacts of the project. Thus, the EIR provides decision-makers and the public
with the mitigation measures and the feasible alternatives available to reduce or avoid those
substantial adverse effects that would result from the proposed project. However, an EIR
need not consider alternatives for which the effects cannot be reasonably determined and for
which implementation is remote and speculative.

13.4.1 Development and Selection of Alternatives

13.4.1.a Alternatives and Project Objectives

The KTI Project would implement a series of modifications and additions that are
focused on three primary objectives, as follows:
• Produce diesel containing less than 15 ppm sulfur.
• Allow the Refinery to efficiently use a broader array of used oil as feedstock.
• Improve refinery efficiency and increase crude throughput capacity.
As a result of this change, gasoline production levels would be maintained at current
levels and there would be an increase in diesel production. A proposed alternative to the
project must permit feasible attainment of the proposed project’s basic objectives, even if that
alternative would be more costly than the project or would not fully attain the project goals.
Expected to be among the likely candidates are the various alternatives that the project
sponsor investigated in the development of the project itself.
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13.4.2 Proposed Alternatives to the Project

Other alternatives available to the project are:
1. Acid Clay Process 2. Phillips DAP Process

These processes are to be used when metallic impurities in the waste oil are in
appreciable amount. In these processes the by-products metallic phosphates and
sulphates are formed which have very adverse effects on the environment. So that’s
why it is preferable to use KTI Process.