Waste Management Procedure AquaChemie Version:

3.6.2.1 Wastewater

Potential sources of wastewater are listed below in Table 3.7. Table 3.7:

Potential Sources of Wastewater

Sr. No. Source of Rate of Expected Approximate Collection and Disposal
Wastewater Generation Characteristics
1. Blender 2 m3/day pH: 8-9, BOD: 1,000- Collected in drums and
washing 1,500 ppm, COD: about 1.5 m3/day will be
3,000-4,000 ppm, TSS: reused in next batch of
> 500 ppm, TDS: > similar material and
3,000 ppm balance 0.5 m3/day will
be disposed as
hazardous waste
through Imdaad.
2. Boiler tower 0.12 m3/day pH: 11.0 to 12.0, Collected in holding tank
blow down Sodium Sulfate: 30-60 and disposed as
ppm, Phosphates: 30- hazardous waste
60 ppm TDS: > 4000 through Imdaad.
ppm, Conductivity: >
5000 mu.s,
Alkalinity: Below 700
ppm
3. Cooling tower 2.16 m3/day pH: 8-9, BOD: < 1,000 Collected in holding tank
blow down ppm, COD: < 3,000 and disposed as non-
ppm, TSS: <500 ppm, hazardous waste
TDS: <3,000 ppm through Imdaad.
4. RO reject 2.5 m3/hr TDS: < 3,000 Collected in holding tank
and disposed to as non-
hazardous waste
through Imdaad.
5. Lab waste 0.015 Collected in holding tank
m3/day and disposed to as
hazardous waste
through Imdaad.
6. Sewage 1.5 m3/day Collected in holding tank
and disposed as trade
waste through Imdaad
 Wastewater will be segregated at source and collected in separate storage
tanks and disposed as discussed in above table.

The potential non-routine sources of wastewater from the project are:

1. Accidental spills and leaks of chemicals due to storage tank overflow.

2. Accidental spills and leaks of chemicals from pipeline leak (due to physical
damage, corrosion, etc.).

3. Contaminated fire water in the event of an incident.

3.6.2.2 Solid Waste

Solid waste will be mainly from non-routine sources. Potential sources of solid
waste are listed below in Table 3.8 below.

Table 3.8: Potential Sources of Solid Waste

Sr. No. Type of waste Disposal
1. Waste chemical bags Sold to approved recycling companies
2. Polyethylene lined cartons Sold to approved recycling companies
3. Damaged IBCs Sold to approved recycling companies
4. Waste wooden pallets Sold to approved recycling companies
5. Waste metal drums Sold to approved recycling companies
6. Waste plastic drums Sold to approved recycling companies
7. Used filters, cotton rags, etc. Sold to approved recycling companies

4.1.1 General

Sr. No. Mitigation Measures

1. Environmental Permits shall be obtained from EHS for specific activities during
construction stage, including dewatering permit (ia ny required) and hazardous
waste disposal.

4.1.2 Air Quality

Sr. No. Mitigation Measure

1. Painting works, if any shall be carried out in paint booths and not in open area.
2. Maintain moisture in loose dusty material so as to minimise generation of dust.
In particular, soil or such material shall be dampened with water during
stockpiling or transport. Open stockpiles of loose, fine-grained materials should
be avoided where possible. The use of temporary bins, tarpaulins and partial
barricades will help reduce dust generation.
3. Ensure that vehicles tyres are clear of mud and dirt from the site.
4. The speed of vehicles shall be restricted. Sign posts displaying the safe maximum
speed limit shall be erected.
5. Ensure that vehicles are switched off when not in use.
6. Loading and unloading should be carried out carefully with minimal drop heights.
7. Trucks shall be covered to avoid any dust nuisance during movement.
8. Adequate personal protective equipment must be provided for workers who are
exposed to locally reduced air quality.
9. Carry out routine maintenance of all construction vehicles and generators to
reduce exhaust emissions.
10. Where possible, electrical motors shall be used to drive equipment in lieu of
diesel operated motors.
11. The contractor shall maintain equipment in accordance with the manufacturer’s
standards.
12. The load carrying capacity of the vehicle, as specified by the manufacturer, will
 Sr. No. Mitigation Measure
be communicated to the users of the vehicles. The specified capacity shall not be
exceeded.
13. The norms for combustion emissions shall be ascertained and communicated to
users.

4.1.3 Noise Quality

Sr. No. Mitigation Measure

1. Select equipment with low noise generating fixtures, such as mufflers, wherever
possible and practical.
2. Use properly tuned engines, proper mountings and equipment fitted with
mufflers and or silencers. This is particularly important for pneumatic breakers
and compressors.
3. Provide temporary enclosures around heavy noise producing equipment.
4. Ensure good maintenance and repair of heavy equipment and locate it away
from sensitive areas to the extent possible.
5. All equipment shall be switched off when not in use. Use of hydraulic equipment
can minimize noise impacts.
6. The contractors will be required to use best practicable means to minimize noise
during the construction period.
7. Workers working with equipment generating high noise levels shall be provided
with protective equipment (e.g. ear muffs).

4.1.4 Water

Sr. No. Mitigation Measures

1. All construction vehicles and equipment shall be properly and regularly
maintained to prevent leaks and spills of fuel and oils.
2. To prevent contamination, the storage areas, vehicles, and equipment shall be
inspected at regular intervals for possible leaks or spills.
3. Recycle or properly dispose of the following: grease, oil, brake fluid, cleaning
solutions, hydraulic fluids, batteries, transmission fluids, and filters.
4. Activities involving chemical solutions, such as paint mixing or oil changing, shall
be conducted in locations with a sealed surface (i.e. not permeable to the
ground).
5. Any polluted water, diesel, oil, paint, thinners and other chemicals being used
on the site shall be stored in impermeable containers at designated sites so that
such wastes do not infiltrate through soil and sand.
6. A permit from Trakhees shall be obtained if any dewatering is required on site.
7. There shall no cleanings of vehicles on site.
8. Construction sites must be established and operated in a manner such that
there is no unauthorized discharge of oil and grease, waste materials, or sewage
to groundwater or harbour water. Proper waste handling and disposal
procedures and facilities shall be maintained on site.
 Sr. No. Mitigation Measures
9. The following measures shall be followed while changing fuel/oils from
construction vehicles.

 Changing of oil/fuel from construction vehicles shall be undertaken in

designated areas only.
 Use drip pans for above activities.
 Drain and crush oil filters (and oil containers) before recycling or disposal.
 Store crushed oil filters and empty lubricant containers in a leak
proof container/receptacle.
 Use non-chlorinated solvents and cleaning agents.
 Store mechanical parts and equipment that may yield even small quantities
of contaminants (i.e. oil and grease) under cover.
 Recycle or properly dispose of the following: greases, oils, antifreeze, brake
fluid, cleaning solutions, hydraulic fluids, batteries, transmission fluids, and
filters.
 Clean up spills as they occur.
10. All sewage generated on site shall be collected in leak proof holding tanks
(concrete or fibre glass) and disposed through Imdaad.
11. Holding tanks shall be emptied and disposed on a regular basis after obtaining
all required approvals.
12. Accidental leakage or spill of any hazardous liquids is to be immediately
contained and cleaned up.
13. Spill kits shall be provided for response to potential leaks or spills. Contractor
personnel must be trained in the use of spill kits and in effective incident
response procedures.

4.1.5 Land/Soil

Sr. No. Mitigation Measure

1. Maintain good housekeeping. A tidy site reduces waste generation.
2. Contractors shall segregate waste by providing separate waste containers
(drums, bins, skips or bags) for hazardous waste, general waste, metal scrap and
construction rubble for recycling and or disposal to minimise costs and
unauthorized disposal. The nature of the waste shall determine the
method/mode of waste disposal.
3. Provide appropriate containment around fuel tanks and material stores to enable
reuse and prevent contamination.
4. Hazardous waste shall not be mixed with other wastes and shall be disposed to
DM hazardous waste area as per Trakhees and DM guidelines.
5. Metal scrap shall be collected separately and disposed through approved
recycling companies.
6. Every effort shall be made to recycle waste.
 Sr. No. Mitigation Measure
7. In order to minimise the generation of hazardous waste during construction the
following need to be considered:

 Avoid sealant and glazing formulations which use lead as a drying agent.
 Use lead-free paint and primers, varnish and wood staining systems.
 Minimise the use of solvent-based paints or replace with water-
based materials.
 Substances containing CFCs (chlorofluorocarbons) and HCFCs
(hydrofluorocarbons) shall not be used.
8. Construction employees shall be made aware that unauthorised disposal of
materials to the environment is unlawful and can result in serious penalties.
9. The contractor shall be responsible for arranging the timely collection of waste
material to prevent indiscriminate disposal of rubbish. Good housekeeping shall
be maintained at all times.
10. The contractor shall appoint an individual responsible for the regular inspection
of the site and site housekeeping.
11. All waste shall be disposed at approved waste disposal site of Dubai Municipality
through DM approved waste disposal contractors. Records of all waste disposal
shall be maintained.

4.1.6 Biological/Ecological Effects

As there are no ecological assets on site, no mitigation and or enhancement measures are
required and hence not recommended.

4.1.7 Aesthetic and Visual Effects

The proposed project is within an existing site which is fully developed as an industrial area.
Hence, construction of the project will not cause any adverse effects on the aesthetic value
of the area and hence no further recommendations are required.

SECTION 6 ENVIRONMENTAL MANAGEMENT PLAN

An essential element of the IEE/EIA process is to develop measures to eliminate, offset or reduce
impacts to acceptable levels during construction and operation of projects. The integration of such
measures into project implementation and operation is supported by clearly defining the
environmental requirements within an environmental management plan (EMP).

The Environmental Management Plan (EMP) for the proposed project aims to mitigate the
potentially adverse impacts on the environment. It is also necessary that continued compliance with
existing environmental regulations is ensured.

An Environmental Management Plan (EMP) has been developed as part of the present IEE study
describing the environmental protection measures to be put in place. The EMP focuses on:

 Objectives/targets
 Mitigation measures to be applied in the field to minimize potential adverse impacts and achieve
objectives/targets
 Management practices and responsibilities (procedural measures) and staff training
 Environmental Organization
 Environmental monitoring and audits

6.1 ENVIRONMENTAL OBJECTIVES AND TARGETS

The environmental objectives and targets are environmental legislation that shall be
complied with. All applicable environmental standards and legislation are discussed in detail
in Section 1 of this report.

ACME believes in bringing together of good business management, innovation and safety
and environmental protection. Therefore ACME proactively has developed and EHS
Management System and is certified to ISO 14001: 2015 and OHSAS 18001: 2007.

6.2 FRAMEWORK ENVIRONMENTAL MANAGEMENT PLAN – CONSTRUCTION PHASE

A framework Construction Environmental Management Plan (CEMP) is developed for the on-
going and balance construction activities of the project.

The construction contractor shall prepare a CEMP based on the framework CEMP presented
in this report. The CEMP to be developed shall include as a minimum the following:

 Introduction
 Objectives of the CEMP
 Structure of the CEMP
 Overview of the project development
 Details of the construction activities with statement of work methods
 Tabulated list of identified environmental aspects and impacts.
 Corrective actions/measures to control and manage the identified construction-related
impacts.
 Monitoring methodology, list of environmental quality parameters, and the frequency
of sampling or scope of monitoring
 Incident/Emergency Preparedness and Response
 Data management and reporting
 Statement of responsibilities, whether jointly or separately, of Contractors, Consultants,
and/or Project Owner.

6.2.1 Mitigation Measures

Measures to mitigate adverse environmental impacts during construction phase are

discussed in detail in Section 4.5 and the same shall be implemented.

6.2.2 Waste Minimization

Waste is an excess material resulting from any activity which is discharged as reject and
unwanted or any surplus material whether as a total useless matter or those that can be
rendered useful again by recycling, treatment or recovery thru a different process from
which it was originally produced.

Potential waste sources during construction phase of the proposed project are as follows:

 Construction waste
 Domestic sewage
 Domestic refuse
 Hazardous waste (e.g. waste paint cans)

Waste minimization is an integral part of an EMP. By focusing on waste avoidance and

reduction through the use of better construction methods and practices, pollution control
and waste disposal costs can be lowered.

Waste Minimization sets out the following hierarchy for waste management options:

 waste avoidance/reduction
 reuse, and recycling
 waste treatment
 waste disposal

Preference shall be given to waste avoidance or reduction, ahead of recycling and reuse.
Waste treatment and the least preferred alternative of waste disposal should be considered
only if the waste avoidance/reduction and reuse options are not feasible or possible.

Waste minimization during construction and commissioning phases of the project are
already discussed in Section 4.5.4 and 4.5.5 of this report. Additional waste minimization
measures are presented in Table 6.1 below.

Table 6.1: Waste Minimization Plan during Construction Phase

Sr. No. Waste Minimization
1. Plan locations for depositing and stacking of materials before delivery.
2. Separate waste for recycling wherever possible. Provide recycling skips and
 Sr. No. Waste Minimization
ensure compliance with waste stream sorting by all trades.
3. Contain plastic film, cardboard, glue and paint tins in closed bins.
4. Use bins with lids to reduce windblown litter.
5. Use DM approved waste service providers.
6. As far as possible use waste aware sub-contractors.
7. All contracts with contactors/sub-contractors shall include clauses requiring
waste minimization practices.
8. Colour code or label waste skips and protect them from contamination, rain and
wind.
9. Provide regular waste bins for food scraps and domestic waste during
construction.
10. Lock special skips (e.g. skips used for stored waste chemical or paint cans) at
night and weekends to prevent others dumping rubbish in them.
11. Tidy up the site often. This reduces the potential for windblown litter and
safety hazards on site.
12. Minimise the time between delivery and installation to reduce the risk of
damage or theft.
13. Ask suppliers to collect or recycle packaging.
14. Have fragile materials and fixtures delivered and installed close to completion
date.
15. Check quantity, condition and quality of goods on delivery. Report discrepancies
immediately.
16. Reject inferior goods or materials if their quality will result in additional waste.
17. Report careless delivery staff to the supplier.
18. Use sub-boards and plan wiring to reduce wiring distances, quantities, waste
and cost.
19. Recycle offcuts. Strip insulation from copper.
20. As far as possible use cable products that are highly recyclable and be aware
that some PVC coatings used to contain heavy metals.

All wastes shall be disposed only through authorized and licensed waste collection
companies.

Teamwork and commitment from construction staff, supported by strong management and
effective management systems, should enable sustainable and continuous performance
improvement. The construction contractor’s top managements' commitment shall include a
policy statement on waste minimization which shall be circulated and made known to all
staff. The statement shall include responsibilities of staff.

An essential part of waste minimization is an understanding of the wastes being produced

and the source of waste generation. Besides establishing a baseline against which
improvements can be assessed, this data will allow waste reduction options to be evaluated.

A useful starting point for a waste minimization program is to prepare a construction waste
management plan (WMP). The first step to preparing a WMP is a waste audit, which involves
identifying the sources, types and quantities of wastes generated during construction. The
waste audit should:
• identify all waste streams;
• establish how each waste stream is generated;
• quantify and characterize the waste streams

After the waste audit is completed, a waste assessment shall be conducted. This involves
identifying the options available to minimize each of the waste streams.

The WMP shall contain an implementation timetable and description of the method of
implementation, and the anticipated costs and environmental benefits.

The waste minimization program shall be periodically reviewed to ensure the WMP is being
adhered to, and to identify any new waste minimization opportunities. The waste
minimization program should be an integral part of the contractor’s approach to
environmental management.

The above suggested measures are summarized below.

 Establish a management policy supporting waste minimization.

 Establish a waste management team.
 Conduct a waste audit.
 Prepare and implement a WMP including waste reduction options.
 Monitor and evaluate the effectiveness of the WMP.

6.2.3 Environmental Organization

Environmental organization during construction phase is discussed in Section 6.4.

6.2.4 Management Practices and Responsibilities

ACME through their project consultant and or construction contractor shall ensure that
during construction phase the EMP is communicated to the relevant sub-contractors (if any),
to enable sub-contractors to incorporate the EMP’s requirements into their daily operations
and management plans.

The contractors shall take steps to comply with all environmental mitigation measures and
standards mentioned in this IEE report and that stipulated by Trakhees and DM. The overall
responsibilities of the contractor’s team are presented below in table 6.2.

Table 6.2: Construction Contractor’s Responsibility

Sr. No. Contractor’s Responsibility
1. Nominate and designate a site in-charge as the contact and responsible person
(e.g. Environmental officer) for all environmental implementation and reporting
purposes. Any replacement of staff responsible for environmental management
shall be subject to prior approval by the project consultant and ACME.
2. Communicate closely with the project consultant and ACME.
3. Allocate adequate resources to implement the EMP.
4. Instruct staff about relevant environmental sensitivities and specific measures
that each employee needs to implement to meet environmental protection and
management standards defined in the EMP.
Sr. No. Contractor’s Responsibility
5. Perform day-to-day tasks necessary to monitor the performance of the sub-
contractors with regard to the requirement of the EMP.
6. Liaison with the client in the event of accidents, or non-compliance.
7. The contractor shall also act as an advisor to sub-contractors on EHS issues
during all stages of construction. This can be achieved by on-going inspections,
identification of problem areas and provision of action plans to avoid
environmental damage.
8. Provide all necessary personnel protective equipment (PPE) and ensure their use
by workers.
9. Ensure that adequate sanitation facilities, clean drinking water, and clean area
for eating are provided to workers.
10. Ensure protection of environment, health and safety of workers and prevent any
damage or deterioration of surrounding environment.
11. Ensure good housekeeping and timely disposal of all waste to designated areas
through authorized waste collectors.
12. Familiarize with existing information regarding the project area and the EMP.
13. Familiarize with Trakhees and DM standards, regulations and guidelines.
14. The EHS delegate shall have experience in environmental management and shall
be able to evaluate the effectiveness of specified management measures and be
familiar with environmental management techniques. He/she should be able to
propose solutions to identified problems.
15. Reviewing all available project reports, construction documents and drawings
and understand the EHS issues of the projects.
16. Preparing and implementing policies, procedures and programs on construction
safety and environmental issues that comply with Trakhees regulations.
17. Preparing site emergency response plan and evacuation plan
18. Obtaining all necessary waste disposal permits from Trakhees and DM.
19. Monitoring to ensure implementation of various mitigation measures and for
alleviating adverse environmental impacts.
20. Ensuring compliance with standards.
21. Updating the Environmental Management Plan as and when required.
22. Instruct staff about relevant environmental sensitivities and specific measures
that each employee needs to implement to meet environmental protection and
management standards defined in the EMP.
23. Establish and conduct regular (weekly) EHS meetings with subcontractor
representatives and issue minutes of meeting and interface with project staff and
each subcontractor EHS representatives relating to EHS regulations to ensure
proper compliance.
24. Investigating reports on dangerous working conditions and submit the report and
recommendations to senior management.
25. Reviewing reports on workplace injuries, and investigating the causes.
26. Arranging training programs on EHS measures in the workplace.
27. Representing the construction company in meetings with government bodies and
other agencies on EHS matters, if required.
 The Project Consultant shall delegate a site supervisor or representative to oversee the
contractor`s work. The consultant’s site in-charge shall be responsible for enforcement of
environmental protection and legal compliance.

The responsibilities of the Project consultant’s site supervisor are presented below in Table
6.3.

Table 6.3: Project Consultant`s Site Supervisor Responsibilities

Sr. No. Project Consultant Site Supervisor Responsibility
1. Ensure implementation of EMP.
2. Regular meetings with contractor’s staff to review EMP and its compliance.
3. Regularly check conformance of the contractor to the environmental guidelines
and standards.
4. Co-ordinate with Trakhees upon any environmental incidents.
5. Co-ordinate with contractor after any environmental incidents.

6.2.5 Environmental Monitoring

As the construction phase will be only for 3 months no environmental monitoring is

recommended for the construction phase.

6.2.6 Regulatory Standards

The basic aim of the EMP is to maintain the levels of pollutants within stipulated limits and
to comply with the regulatory standards. It is necessary that the construction contractor
complies with all relevant environmental regulatory standards stipulated by Trakhees EHS.

All wastes to be disposed outside the JAFZA shall meet Trakhees and DM standards and
regulations.

6.2.7 Summary of Framework CEMP

A summary matrix of the framework environmental management plan for construction

phase is presented in Appendix-7 which indicates the potential impacts and the applicable
mitigation measures.

6.3 ENVIRONMENTAL MANAGEMENT PLAN – OPERATION PHASE

The EMP for operation phase is discussed below.

6.3.1 Mitigation Measures

Measures to mitigate adverse environmental impacts during operation phase are discussed
in detail in Section 4.7 and the same shall be implemented.

6.3.2 Waste Minimization

Potential waste sources during operation phase of the proposed project are:
 Blender washing
 Boiler and cooling tower blowdown
 RO reject
 Laboratory waste
 Accidental spills and leaks from storage tanks, drum filling, etc.
 Domestic sewage
 Waste/damaged drums/IBCs, waste pallets, waste raw material bags, and cartons
 Domestic refuse

Waste generation may be reduced by simple actions presented in Table 6.4 below.

Table 6.4: Waste Minimization Plan during Operation Phase

Sr. No. Waste Minimization
1. Use SOPs for various operations.
2. Adopt regular preventive maintenance schedules.
3. Ensure efficient response to leaks, collect leaked material and prevent further
leakage.
4. Keep all equipment in a good state of repair, so that oil spills and leaks are
minimized.
5. Use trained staff.
6. Establish procedures for regular auditing of materials delivered and dispatched
and waste discharges.
7. Make special efforts to reduce losses in containment, transfer and handling of
products by constant monitoring of product flows.
8. Waste segregation and waste classification to determine its quality, storage area,
and determining its value or usability can assist good housekeeping.
9. Glass, plastic, paper waste and domestic refuse shall be segregated. Separate
bins shall be provided at strategic locations in the tower for collection of
recyclables like plastics, glass, metals and paper and disposed to recycling
companies.
10. Staff shall be encouraged to segregate waste prior to its disposal.
All wastes shall be disposed only through authorized and licensed waste
collection companies.

Teamwork and commitment from terminal staff, supported by strong management and
effective management systems, should enable sustainable and continuous performance
improvement. ACME top managements' commitment shall include: a policy statement on
waste minimization to be circulated and known by all staff and each responsibility, the plans
and the progress of the program, and in return to everybody's initiation is giving recognition
as appropriate to staff involved.

An essential part of waste minimization is an understanding of the wastes being produced

and the source of waste generation. Besides establishing a baseline against which
improvements can be assessed, this data will allow waste reduction options to be evaluated.

A useful starting point for a waste minimization program is to prepare a waste management
plan (WMP). The WMP can be prepared by ACME management. The first step to preparing a
WMP is a waste audit, which involves identifying the sources, types and quantities of wastes
generated from the project. The waste audit should:

• identify all waste streams;

• quantify wastes;
• establish how each waste stream is generated

The WMP shall contain an implementation timetable and description of the method of
implementation, and the anticipated costs and environmental benefits.

The waste minimization program shall be periodically reviewed to ensure the WMP is being
adhered to, and to identify any new waste minimization opportunities. The waste
minimization program should be an integral part of the company’s approach to
environmental management: it should be a key element when an environmental
management system is established.

The above suggested measures are summarized below.

 Establish a management policy supporting waste minimization.

 Establish a waste management team.
 Conduct a waste audit.
 Prepare and implement a WMP including waste reduction options.
 Monitor and evaluate the effectiveness of the WMP.

A number of measures for waste minimization are already discussed in section 4.7.4 and
4.7.5 of this report.

6.3.3 Environmental Organization

Environmental organization during operation phase is discussed in Section 6.4.

6.3.4 Management Practices and Responsibilities

The environmental performance of the project is highly dependent on the awareness of

the Company’s staff. Staff shall be aware of their role in environmental management.
ACME shall reinforce the message that environmental protection matters to the company.
One way to do this is to have environmental performance as a part of annual performance
assessments.

Specific procedures shall be in place to avoid problems as a result of poor communication

among operations staff during shift changes and maintenance or other engineering work.

ACME shall ensure that during operation the EMP is implemented and it is communicated to
all relevant employees.

Implementation of mitigation measures to minimize the environmental impacts associated

with the proposed project requires management support for efficient conduct and
supervision for handling, as well as for waste reduction.
ACME is already accredited for ISO 14001: 2015 and OHSAS 18001: 2007.

ACME shall delegate a management representative as an EHS officer for the proper
implementation of EMP during operation phase. The responsibilities of ACME and EHS
delegate are presented in Table 6.5.

Table 6.5: ACME Responsibility for Implementation of EMP

Sr. No. ACME’s Responsibilities
1. Ensure compliance to ACME’s EHS policies and procedures at all time.
2. Ensure compliance with EMP and implement all EHS regulations and standards
applicable to the project.
3. Ensure availability of sufficient resources and funds for EHS requirements.
4. Incident reporting, recording and management.
5. Communicate incidents to senior management.
6. Pollution prevention and waste minimization spill response, incident reporting,
etc.
7. Train facility personnel in EHS issues, etc. Alternatively, already trained staff shall
be utilized in the project.
8. Use of available Standard operating procedures (SOPs) for the project (e.g. batch
sequence, raw materials recipe, chemicals handling, etc.). The SOPs shall include
efficient operation, good housekeeping, minimizing use of water and power,
noise quality monitoring requirements, use of personnel protection equipment
(PPE), instructions for operators to prevent spills, waste discharges, and
directives for notification of proper authorities in the event of an accidental
release of chemicals.
9. Project EHS rules shall be established and enforced. They shall include:
 Provisions to prevent and respond to accidents.
 Ongoing training in project EHS and good housekeeping practices.
10. Implementing the planned schedule shall be followed for maintenance of
firefighting equipment.
11. Carry out environmental monitoring as required, review monitoring results and
take appropriate actions to mitigate any non-compliance, if any.
12. Conduct EHS audits annually.

Effective management is central to environmental performance. It requires an actual

commitment to establishing objectives, setting targets, measurement and revision according
to results. The following sections provide information on the main types of procedural
mitigation measures.

6.3.5 Senior Management Commitment

Senior management commitment is demonstrated through the existing Environmental,

Health and Safety Policy signed by the Company Directors of ACME.

6.3.6 EHS Procedures

EHS procedures shall be established to implement mitigation measures. These shall include
procedures relating to the following presented in Table 6.6 below.
 Table 6.6: Project EHS Procedures
Sr. No. Particulars
1. Access to project regulations, e.g. personnel identification, permitted/restricted
areas, EHS regulations, safety procedures and emergency information.
2. Reporting and investigation of incidents, review of accidents, near misses, etc.
3. Work permit system for maintenance works.
4. Personal Protective Equipment, type, numbers available, location, contact
persons for collecting, etc.
5. Housekeeping, working areas waste management, etc.
6. Waste storage and disposal
7. EHS performance reporting
8. Environmental specifications
9. EHS management of contractor personnel
10. Management of change
11. Emergency planning

6.3.7 Maintenance

Standard Operating Procedures (SOPs) and Standard Maintenance Procedures (SMPs) shall
be developed for the project. The SOPs, and SMPs, in conjunction with appropriate training,
will contribute to the mitigation of EHS impacts.

Procedures shall be in place to authorize modifications and to undertake checks after

modifications and before process start-up.

6.3.8 Waste Audits

Waste audits shall be carried out annually (can be carried out internally) to assess the EHS
status of the project.

Waste audit shall be carried out as per Trakhees EHS Guideline No. ID EN-038 “Guidelines for
Conducting Waste Audit” in PCFC.

These audits can be part of the EHS management systems.

6.3.9 Training

Training to be provided to staff during operation phase are presented in Table 6.7 below.

Table 6.7: Staff Training

Sr. No. Particulars
1. All staff shall be aware of the regulatory and statutory implications of the process
and their work activities.
2. Training shall be provided to all staff involved in the project and this shall include
environmental implications of their work and the procedures for dealing with
incidents. There should be records of the training given to staff.
3. It is essential that all personnel to be involved in the project must undergo a
basic training program prior to performing assigned work at the facility. The
training shall include the following:
 Sr. No. Particulars

 Detailed briefing on the project/facility and its operation, including impacts,

hazards.
 Training in operation and maintenance.
 Hazards of all chemicals handled and stored.
 Emission and discharges and their control.
 Base features of the emergency response.
 Principles of fire fighting, first aid and PPE.
 Internal safety and environmental procedures training concerning
work permit system, emergency response plan, etc.
4. A “Basic training course” shall be conducted to make facility’s operators familiar
with the project and to teach the project fundamentals with the use of standard
training aids.
5. A training file should be established for each employee, listing the subject and
the date trained. Proper records of all training and audits shall be maintained.

6.3.10 Environmental Organization

Environmental organization for operation phase is discussed in Section 6.4.

6.3.11 Environmental Monitoring

Environmental organization is discussed in Section 6.5.

6.3.12 Regulatory Standards

The basic aim of the EMP is to maintain the levels of pollutants within stipulated limits and
to comply with the regulatory standards. It is necessary that ACME comply with all relevant
environmental regulatory standards stipulated by Trakhees.

Trakhees operate a system of prior approval of a process and no operation can begin until
the completed facility has been inspected and the authority is satisfied that it meets their
requirement and is fit for use when an Operation Fitness Certificate is issued.

All wastes to be disposed outside the JAFZA shall meet Trakhees and DM standards and
regulations.

6.3.13 Summary of EMP

A summary matrix of the framework environmental management plan for operation phase
is presented in Appendix-8 which indicates the potential impacts and the applicable
mitigation measures.

6.4 ENVIRONMENTAL MANAGEMENT ORGANIZATION

6.4.1 Construction Phase

An environmental organization for construction phase is presented in Figure 6.1 below.

 Figure 6.1: Construction Organization Chart

6.4.2 Operation Phase

The top management of ACME shall be responsible for providing all the necessary funding
and administrative support to the EHS staff and the EMP; and be ultimately responsible for
carrying out this project with total commitment to environmental matters.

The overall organization chart of ACME is presented in Figure 6.2 below.

Figure 6.2: ACME Organization Chart

The HSE coordinator shall be responsible for coordinating all the HSE aspects of the project
which include:

Sr. No. HSE Coordinator Responsibility

1. The coordinator shall hold a meeting of concerned staff at least once a month to
review the implementation of Environmental Management Plan and take
suitable steps for updating it, if necessary.
2. Monitoring to ensure implementation of various mitigation measures and for
alleviating adverse environmental impacts.
3. Training of staff on EHS issues.
4. Ensuring compliance with EHS standards.
5. For updating the Environmental Management Plan based on data obtained from
monitoring vide 1-3 above.

All staff shall be made aware of all existing Trakhees, DM, and federal Environment, Health
and Safety laws and regulations.

A program for implementation of Environmental Management Plan, Environmental

Monitoring and Preventative Maintenance shall be prepared and approved by the top
management in consultation with the HSE Officer. All concerned departments shall be made
aware of the program and its schedule.
6.5 ENVIRONMENTAL MONITORING

The environmental monitoring to be carried out during operations phase of

the project is presented below in Table 6.8.

All monitoring and analysis shall be carried out by Trakhees or DM/Dubai

Accreditation Center (DAC) approved laboratory.

Table 6.8: Environmental Monitoring Plan

Sr. No. Environmental Parameters Frequency Location
Component
1. Ambient Air Total Particulate Once every year One Location Near
Quality Matter, PM10, Sulfur for 1 day (24 main gate
Dioxide (SO2), hours)
Nitrogen Oxides
(NOx), Carbon
Monoxide (CO) and
Volatile Organic
Compounds (VOC)
2. Point Source Total Particulate Once every year Stack attached to
Matter, and PM10, Scrubber
and VOC
3. Point Source Total Particulate Once every year Stack attached to
Matter, PM10, Sulfur Boiler
Dioxide (SO2),
Nitrogen Oxides
(NOx), and Carbon
Monoxide (CO)
4. Wastewater pH, Oil and Grease, Prior to disposal -
Total suspended
Solids (TSS), Total
Dissolved Solids
(TDS), Biochemical
Oxygen Demand
(BOD), Chemical
Oxygen Demand
(COD), Heavy Metal
(Zn, Pb, Cu, Ni, Cr,
Cd)
5. In-plant Noise Noise Levels in Once every year At 1 meter from
dB(A) for 1 day (8 blender, and
hours) outside
compressor room
6. Plant Boundary Noise Levels in Once a year for 8 At fence line (near
Noise levels dB(A) hours. Readings entrance gate)
shall be noted at
30 minutes
interval