8 environmental management plan 8-environmental... · esia of lng terminal, jetty & extraction...

1 of 53Environmental Management Consultants

ESIA of LNG Terminal, Jetty & Extraction Facility - Pakistan Gasport Limited

Ref: Y8LGOEIAPDChapter 8

8 ENVIRONMENTAL MANAGEMENT PLAN8.1- IntroductionEnvironmental protection planning is animportant component of overall planning andimplementation of mega-projects. Industrialactivities, including those associated with theconstruction of the PGPL's LNG terminal, arereviewed and approved by Government agenciesthrough a variety of approvals, authorisations andpermits addressing issues ranging from humanhealth and sanitation to fisheries and wildlifehabitat avoidance or protection. TheEnvironmental Management Plan (EMP) is animportant integration document between thevarious approvals, authorisations and permitsissued for specific components and/ or activities ofthe undertaking.

This EMP outlines the contents of constructionand operational phases both. It constitutes acontract document for use in the field by thecontractor(s) and their personnel duringconstruction as well as by the personnel of PGPLduring operations.

PGPL and its construction contractor, through itsengineering and environmental consulting team,is responsible for implementing the EMP andensuring that all personnel are informed aboutthe EMP and the requirement to implement theprocedures it contains. The EMP is intended as aquick reference for Project personnel andregulators to monitor compliance, and isstructured to allow updates and revisions as workcontinues.

8.1.1- PGPL's Commitment toEnvironment, Health and Safety

PGPL is committed to manage and operate itsassets in a manner consistent with its core valuesto protect the health and safety of people and theenvironment and to comply with applicable

Environment Health and Safety (EHS) laws,regulations and internal EHS standards. In thisregard a sketch of environmental policy is beinggiven here which may be a part of PGPL'scorporate level policy once management of PGPLapproves it.

n The management and staff of PGPL arecommitted to preserving and protecting thequality of port area's environment. A cleanenvironment is important for the success ofour business and for that future generationscan also enjoy these precious resources.

In support of this commitment, we strive toconduct clean material and goods export/importpractices at Port area and educate our staff,customers and guests on sound practices. Ouroverall goal is to create awareness among thePGPL staff and protect the environment due toLNG Jetty and Pipeline operations. We willachieve this goal by using a team orientedmanagement approach to help ensure responsibleuse of our air, land, and water resources.

To achieve this goal as a PGPL's management andstaff will put their all practicable efforts to meet orgo beyond compliance with all applicable federal,local and international environmental rules andregulations.

We endeavour to continually improve ourenvironmental performance and to preventpollution before it is produced. All our employeesare expected to support our environmental goalswhile providing clean and environment friendlymeans of working practices and minimumincident rate".

PGPL is a sister organisation of Associated Groupwhich has a structured environmental programthat involves environmental assessment,monitoring, protection and rehabilitation of itsdifferent projects. This EMP will strive for

continual improvement in the LNG jetty activitiesand its operations to maintain a healthy portenvironment.

8.1.2- Purpose of the EMP

The primary purpose of this EMP is to establishthe Environmental Protection Procedures to beimplemented by PGPL staff, consultants andcontractors. PGPL has committed to developingand implementing a comprehensive EMP to helpensure a high level of environmental protectionthroughout this undertaking. This EMP providesthe protection procedures associated with bothplanned activities anticipated for the constructionand operations of the terminal as well as foraccidental events.

The purpose of the EMP is to:

n outline environmental protection measures tobe followed during construction of jetty /pipeline and operations of the facilitiesowned by PGPL such as the storage vessel,pipeline, jetty, etc;

n ensure that commitments to minimiseenvironmental effects are met;

n document environmental concerns andappropriate protection measures;

n provide concise and clear instructions toProject personnel such as PGPL staff andcontractors regarding procedures forprotecting the environment and minimisingenvironmental impact;

n provide a reference document for personnelwhen planning and/or conducting specificactivities;

n provide contingency plans for accidentalevents;

n communicate changes in the programthrough the revision process; and

n Provide a reference to applicable legislativerequirements.

8.1.3- Scope of the EMP

The initial focus of the EMP is the protection ofaquatic habitat and traffic management due toincrease in visiting people as well as thoseactivities under the direct control of PGPLmanagement where activities may give rise tosignificant environmental impacts, the EMPincludes a number of priority strategies andactions relating to these locations. The EMP alsosupports collaboration and joint actions withaffiliated organisations, tenants and contractorswithin the PGPL's sphere of influence.

In line with the Environment Policy, thefollowing criteria will be used to determinepriorities for attention:

n Impact on the physical and biologicalenvironment;

n Contribution to innovation and definition ofbest environmental practice;

n Compliance with statutory requirements andother environmental commitments;

n Availability of resources.

The EMP acknowledges the social and culturaldimensions of responsible environmentalmanagement alongside the biological andphysical, reflecting a holistic view of the PGPL asa "human ecosystem".

The scope of the EMP includes the followingfunctional areas:

n Management systems: Those systemsemployed in the management of the PGPL'soperational activities. It will include financialsystems; engagement and supervision ofcontractors; purchasing policies, etc.

n Knowledge systems: Those processes whichbuild knowledge and capacity onenvironmental issues, principles andsustainable behaviours. It will includetraining; communications; campaigns; linkswith operational departments, etc.




n Energy management: The energy-relatedaspects of the planning, design, construction,operation and maintenance of the PGPL'sfacilities.

n Water management: Aspects of supply,usage and disposal of water pertinent to theplanning, design, construction, operation andmaintenance of the PGPL's facilities.

n Materials management: Those services andactivities which support the avoidance,resource recovery (e.g. reuse and recycling)and environmentally responsible disposal ofsolid and liquid waste materials.

n Planning, design and development: Theplanning, design and development of thePGPL's built form and associatedinfrastructure.

n Pollution prevention: Those aspects ofplanning and management which supportminimisation of air and water pollution andcontamination of land resulting from dailyroutine activities.

n Transport: Programs, projects, systems andprocedures which promote and supportwalking, cycling and public transport fortrip-to-work, accommodation and otherrelated travel.

n Biodiversity and open space: Those aspectsof management and maintenance whichsupport conservation and enhancement ofbiodiversity and environmentally sustainableuse of open space across PGPL and otherproperties.

The proposed scope of the Project subject to theEMP includes all the main components of theProject

n Marine facilities and tanker approach laneout to existing shipping channel;

n LNG terminal and storage facilities;

n Pipeline lateral and directly associatedfacilities (natural gas and natural gas liquid

laterals);

n Access roads; and

n Supporting facilities and infrastructure.

8.1.4- Organisation of the EMP

The EMP will provide the procedures, organizationand instruction to ensure Project personnelunderstand and implement Environmental ProtectionProcedures for routine activities associated with theconstruction and commissioning of marine and landbased facilities. The organization, style and format ofthe EMP is intended to enhance its use by Projectpersonnel in the field and to provide an importantsupport document between overall environmentalmanagement of the Project and various permits andauthorizations issued for specific construction andcommissioning related Project components andactivities.

8.1.5- Maintenance of the EMP

This section will outline the responsibilities andactivities associated with the maintenance of theEMP. The responsibilities of the EnvironmentalMonitor will be detailed and procedures forrequesting EMP revisions will be outlined. EMPrevision procedures will include requirements fornotification of the appropriate government agenciesand First Nations.

8.2- Health & safety

8.2.1- Environmental health andsafety management system

This section will outline an Environmental Healthand Safety Management System which will outlinemitigative measures and best managementpractices. This management is recommended tocarry out a complete assessment, evaluate,monitor, identify and control all potential hazardsand risks arise during the construction, operationand dissertation phases of the proposed project.The management needs to ensure that the Health




and Safety Plan (HSP) along with the Plant Healthand Safety Rules is established and enforced. ThePlan will outline roles, responsibilities andexpected outcomes with respect to theenvironmental health and safety management ofthe construction phase of the Project. Thesemeasures should be implemented to ensure that nosignificant adverse environmental health andsafety impacts are created by activities associatedwith the construction of the Project.

Protection of the public and workforce health andsafety during both construction and operations isparamount to PGPL. Utilising expert personneland the (PGPL) Environment, Health and SafetyManagement System (EHSMS), the potentialhealth and safety hazards and risks will beidentified and assessed, then the subject ofsubstantial planning, organisation andprocedural/facility development.

The LNG facility will be designed to include spillcontainment systems, fire protection systems,multiple gas, flame, smoke and low- and high-temperature detectors and alarms, and automaticand manual shut-down systems. The efficiencyand stability of operations will be maximised bythe use of a high level of automation, regularpreventative maintenance, and safeguards such asback-up systems and the provision for safeemergency shut-downs. Prior to projectcommissioning, all personnel will be required toundertake an extensive training program to ensuresafe operating practices. The training program andsubsequent regular refresher programs willinvolve issues covering operations, hazards, safetyand emergency procedures and environmentalmanagement.

The Plant Health and Safety Rules should includeprovisions for, impediment of and response tonoxious chemicals and gases. It is also theresponsibility of the management to provide thefollowing basic information:

n Description of all potential hazards/ risks.

n Health and Safety implications about allhazards.

n Description about management techniquesincluding inspections, maintenance follow-up, reports, personnel protective gears andmedical monitoring.

n Outline of emergency response proceduresincluding organisational structure of keytrained personnel to act as emergencyresponders action steps for entering andworking within zone of hazards, evacuationprocedures, protective gear requirements,decontamination procedures, lines ofcommunication, emergency call centres'telephone numbers, map of nearest medicalcentres' route, etc.

8.2.2- Worker health and safetyplan

This section will outline a Worker Health andSafety Management System which will outlinemitigative measures and best managementpractices. Roles, responsibilities and expectedoutcomes will be defined. The Plan should beimplemented to ensure that no significant adverseworker's health and safety issues arise fromactivities associated with the construction of theProject. The Plan will apply to all PGPL personnel,employees and contractors.

n Provide adequate worker training.

n Use proper personnel protective equipment.

n Follow fire protection measures.

n Arrange availability of appropriateemergency response, rescue, and first-aidpersonnel and services.

8.2.3- Emergency response plan

Emergency may be defined as a sudden eventcausing or has the potential to cause serious humaninjury and /or environmental degradation of largemagnitude. The best "cure'' for an emergency is, of




course, "prevention".

The probable emergency situation can be:

n Serious fire or explosion

n Release of LNG in large quantities

n Spillage of large quantity of acid/solvent ormajor gas leakage.

n Natural calamity such as heavy rain,flooding, dust storm or earthquake, tsunami,cyclone, etc.

n Bomb threat or any sabotage / terroristactivity

n Any other incident involving all or large partof the premises and its workers.

A Project-specific Emergency Response Plan will bedeveloped which primarily relates to the differentconstruction activities of the Project as well as risksand hazards identified in QRA. It supports the EMPand addresses actions and required responses allPGPL personnel, employees and contractors.

Emergency response management will be providedby a small team of senior managers (the controlcommittee) who in turn will direct all responseactivities through the Emergency response unit,plant security, communications, public relations,safety and environmental affairs and materialprocurement departments. Each of thesedepartments will have specific responsibilities toperform in the event of an emergency.

When the Emergency Response Plan is put intoeffect, Terminal Personnel will assume designatedpositions, each with specific duties as depicted inthe following chart.

A- Objectives

The main objective of this plan is to establish thegeneral guidelines for actions to be taken in theevent of fires, explosion, emergencies, accidents orhydrocarbon spills/leaks and spills of processchemicals, natural disasters and sabotage, aimed atminimizing their effects and consequences, inorder to protect:

The physical integrity or the lives of own or third-party personnel present in the company'sfacilities.

n The physical integrity or the lives of theresidents of the Company's Housing onboard FSRU.

n The physical integrity or the lives of theresidents of the geographical areas near theproject's area of influence.

n The physical integrity of the Company'sproperties or assets.

n The physical integrity or the lives of theecological systems located in thesurroundings of the company's facilities.

The Contingency Plan will be applied in theprocess area, the natural gas receiving area, LNG




Figure 8.1: Emergency Organization

storage and dispatch, industrial services andadministration in view that they are not located inthe area of influence.

A complementary objective is to establish theNotification Procedure to be followed betweenCompany personnel and with GovernmentEntities.

B- Risk Situations

Due to the characteristics of the project, thecontingencies that could arise are the following:

Once received, the gas will undergo the followingprocesses: compression, LNG storage, re-gasification and dispatch for exportation throughsubmerged pipeline on board the FSRU vesselpermanently stationed along the jetty.

Due to the characteristics of the project, thecontingencies that could arise are the following:

C- Internal Risks

Risks arising from operational conditions orhuman error that could result in personalaccidents, spills or fires, such as:

n Uncontrolled gas leak (RLNG, liquefiednatural gas, and propane) into theatmosphere.

n Fire / explosions.

n Hydrocarbon or by-product spills (gasoline,diesel).

n Chemical product spills

n Occupational accidents (serious or fatal), dueto product contamination, failure to complywith operating rules and procedures,negligence of the personnel, falls, internaltraffic accidents, burns, acts of God, bad use ofequipment and personal protection items.

n Environmental Contamination (due to gasleaks into the environment, product spills onland and in the sea).

D- Natural Risks

Natural risks that may affect the facilities andtheir resulting damage to property and thepersonnel.

n Strong earthquake

n Tsunamis (floods)

E- External risks

Risks arising from delinquent actions, terrorismor vandalism.

F- Personnel Transportation Risks

All personnel of the Plant must be instructed thatin the event of automobile accidents while thepersonnel is being transported to/from the Plant,using own or third-party transportation contractedby the company, they must immediately notifythe Environment, Health and Safety EnvironmentDepartment (EHS) so that it will provide thenecessary assistance for the injured, and proceed toissue notices not only to the health care centres butalso to external support institutions (NationalCivil Defence, Police, Fire Fighters, etc).

G- Risk management

The management of contingencies at the

natural gas re-gasification LNG import

terminal plant is based on:

n Early detection (alarms, detectors, settingoff of safety elements);

n Immediate automatic reaction (feed shut-off valves, either of the fluid, electricprocess or other).

n Confinement of emergency area.

n Application of the adequate responseprocedure

n Follow-up and monitoring

n Schedule maintenance




H- Evacuation Plan

The following alarm signal(s) will be used to

begin evacuation of the facility (check all

which applies):

n Bells

n Horns/Sirens

n Verbal (i.e. shouting)

n Other (specify)

n Evacuation map is prominently displayedthroughout the facility.

Note: A properly completed Site Plan satisfies

contingency plan map requirements. This

drawing (or any other drawing that shows

primary and alternate evacuation routes,

emergency exits, and primary and alternate

staging areas) must be prominently posted

throughout the facility in locations where it

will be visible to employees and visitors.

i- Emergency Contacts*:

Fire/Police/Ambulance

Phone No. ____________________________

State Office of Emergency Services

Phone No. ____________________________

National Response Centre

Phone No. ____________________________

ii- Post-Incident Contacts*:

Fire Department Hazardous Materials Program

Phone No. ___________________________

EPA Department of Toxic Substances Control

Phone No. ____________________________

Cal-OSHA Division of Occupational Safety and

Health

Phone No. ____________________________

Bay Area Air Quality Management District

Phone No. ____________________________

Regional Water Quality Control Board

Phone No. ____________________________

* These telephone numbers are provided as a

general aid to emergency notification. Be advised

that additional agencies may be required to be

notified.

iii- Emergency Resources:

Poison Control Centre

Phone No. ____________________________

Nearest Hospital: Name: _______________

Phone No. ____________________________

Address: _____________________________

City: ________________________________

iv- Arrangements with EmergencyResponders:

If you have made special (i.e. contractual)arrangements with any police department, firedepartment, hospital, contractor, or State orlocal emergency response team to coordinateemergency services, describe thosearrangements on the lines below:

I- Emergency Procedures:

i- Emergency Coordinator esponsibilities:

(a) Whenever there is an imminent or actualemergency situation such as an explosion, fire, orrelease, the emergency coordinator (or his/herdesignee when the emergency coordinator is oncall) shall:

n Identify the character, exact source, amount,




and areal extent of any released hazardousmaterials.

n Assess possible hazards to human health orthe environment that may result from theexplosion, fire, or release. This assessmentmust consider both direct and indirect effects

(e.g. the effects of any toxic, irritating, orasphyxiating gases that are generated, the effectsof any hazardous surface water run-off fromwater or chemical agents used to control fire, etc.).

n Activate internal facility alarms orcommunications systems, where applicable,to notify all facility personnel.

n Notify National Disaster Management &Rescue Operations Authority as well as theEnvironment Protection Agency (EPA) Sindh.

n Notify the City as well as PQA FireBrigade/Emergency Services

n Monitor for leaks, pressure build-up, gasgeneration, or ruptures in valves, pipes, orother equipment shut down in response tothe incident.

n Take all reasonable measures necessary toensure that fires, explosions, and releases do notoccur, recur, or spread to other hazardousmaterials at the facility.

(b) Before facility operations are resumed in areasof the facility affected by the incident, theemergency coordinator shall:

n Provide for proper storage and disposal ofrecovered waste, contaminated soil or surfacewater, or any other material that results froman explosion, fire, or release at the facility.

n Ensure that no material that is incompatiblewith the released material is transferred, stored,or disposed of in areas of the facility affected bythe incident until cleanup procedures arecompleted.

n Ensure that all emergency equipment iscleaned, fit for its intended use, and available

for use.

n Notify the PQA Fire Department that thefacility is in compliance with requirements b-i and b-ii, above.

ii- Post-Incident Reporting/Recording:

The time, date, and details of any hazardousmaterials incident that requires implementationof this plan shall be noted in the facility'soperating record.

Within 15 days of any hazardous materialsemergency incident or threatened hazardousmaterials emergency incident which triggersimplementation of this plan, a written EmergencyIncident Report, including, but not limited to adescription of the incident and the facility's responseto the incident, must be submitted to the SindhEnvironmental Protection Agency's Department ofToxic Substances Control, Fire DepartmentHazardous Materials Division.

The report shall include:

n Name, address, and telephone number of thefacility's owner/operator;

n Name, address, and telephone number of thefacility;

n Date, time, and type of incident (e.g. fire,explosion, etc.);

n Name and quantity of material(s) involved;

n The extent of injuries, if any;

n An assessment of actual or potential hazardsto human health or the environment, wherethis is applicable;

n Estimated quantity and disposition ofrecovered material that resulted from theincident;

n Cause (s) of the incident;

n Actions taken in response to the incident;

n Administrative or engineering controlsdesigned to prevent such incidents in the




future.

iii- Emergency Equipment:

The Hazardous Materials Storage Ordinancerequires that emergency equipment at the facility belisted. Completion of the Emergency EquipmentInventory tabel (Table-7.1) meets this requirement.

J- Training:

Check all boxes which apply.

i- Personnel

General workers will be trained as per followingprocedures:

ii- Chemical Handlers

Chemical Handlers will be annually trained in thefollowing manner:

iii- Emergency Response Team

Members are capable of and engaged in thefollowing:

K- Emergency response training

Develop and practice a spill clean-up procedureincluding where to find emergency equipment andhow to use it. Make sure all people on site areaware of emergency telephone numbers to call inthe case of a large spill. Spill kit equipment on siteshould include: booms to contain liquids, materialto prevent spills into drains, and material to absorbspills. Keep this absorbent material in a clearlylabeled and easily accessible place.

L- Response levels

Two levels of response must be contemplated:

n With own personnel

n With external government cooperation, suchas Civil Defence, Fire Fighters, NationalPolice, High Ranking Assistance Centres andthe Government Attorney General's Office.

M- Response Strategy

Upon the occurrence of the emergency, the Planwill be developed under the following conditions:

n First Stage: Notification

n Second Stage: Initial assistance/rescue

n Third Stage: Response operations

n Fourth Stage: Evaluation of the Plan anddamages




Personnel Training Procedures

Internal alarm/notification

Evacuation/ re-entry procedures & assembly point locations

Emergency incident reporting

External emergency response organization notification

Location(s) and contents of Emergency

Chemical Handling Training Procedures

Safe method for handling and storage of

hazardous materials

Location(s) and proper use of fire and spill control equipment

Spill procedures/emergency procedures

Proper use of personnel protective equipment

Specific hazard(s) of each chemical to which they may be exposed, including route of exposure(i.e.inhalation, ingestion, absorption)

Hazardous waste Handlers/Managers are trained in all aspects of hazardous waste management specific to their job duties (e.g. container time requirements, manifesting requirements, etc.)

Emergency Response Training Procedures

Personnel rescue procedures

Shutdown of operations

Use, maintenance, and replacement of emergency response equipment

Refresher training which is provided annually

Emergency response drills which are conducted at least quarterly




i- First Stage: Notification

Internal Communication

Radio communication systems, channels and

frequencies will be established for thecommand post, alternative posts and for thepersonnel that forms part of the response Brigade.

Furthermore, message forms will be establishedto record at least the following information:

Table 8.1: Emergency Equipment Inventory

Equipment Category Equipment Type Location Description

Personal Protective Cartridge Respirators

Equipment, Safety, Chemical Monitoring Equipment (describe)

and First Aid Chemical Protective Aprons/Coats

Equipment Chemical Protective Boots

Chemical Protective Gloves

Chemical Protective Suits (describe)

Face Shields

First Aid Kits / Stations (describe)

Hard Hats

Plumbed Eye Wash Stations

Portable Eye Wash Kits (i.e. bottle type)

Respirator Cartridges (describe)

Safety Glasses / Splash Goggles

Safety Showers

Self-Contained Breathing Apparatuses (SCBA)

Other (describe)

Fire Extinguishing Automatic Fire Sprinkler Systems

Systems Fire Alarm Boxes / Stations

Fire Extinguisher Systems (describe)

Other (describe)

Spill Control Absorbents (describe)

Equipment and Berms / Dikes (describe)

Decontamination Decontamination Equipment (describe)

Equipment Emergency Tanks (describe)

Exhaust Hoods

Gas Cylinder Leak Repair Kits (describe)

Neutralizer (describe)

Over-pack Drums

Sumps (describe)

Other (describe)

Communications and Chemical Alarms (describe)

Alarm Systems Intercoms / PA Systems

Portable Radios

Telephones

Underground Tank Leak Detection Monitors

Other (describe)

Additional Equipment

(Use Additional Pages

if Needed)

Name of informant, location and place of theemergency, number of people affected and, ifpossible, an estimate of the type of injuriesand/or damages, among others.

External Communication

In the event of spills, leaks or discharges into thesea or the beach, the Harbour Master's Office ofthe area of influence must be informed throughthe fastest means: telephone and fax; and alsousing the forms of the General Harbour Master'sand Coast Guard Bureau.

n Local Authorities will be advised bytelephone.

n In the case of serious or fatal accidents, theGovernment Attorney General's Office andthe National Police will be notified incoordination with the Legal Counsel.

n The relatives of the injured person, as soon ashe is evacuated to a hospital.

n To the extent possible, the press will benotified after the accident has beeninvestigated and by the person designated byManagement.

n In the case of an accident that has affected thefacilities; the Insurance Company will benotified in Coordination with theAdministration and Finance Management.

ii- Second Stage: initial assistance/ rescue

A joint evaluation will be made of the status of theevent, the conditions of the site, theenvironmental characteristics that warrant a safedevelopment of rescue actions, first aid andtransportation of the injured to a medical unit.

Strategies will be adopted to determine ownmaterial and human resources to be required,the deployment of the resources to the emergencylocation, as well as the estimated response time.

Trained emergency teams must be prepared to actas required, and a reserve team must be available.All personnel who are not essential to fight the

emergency must be evacuated to a safe placewhere there must be communication equipmentavailable to count the number and condition ofthe personnel.

In the event of fire, the execution or fightingphase will be implemented immediately.

iii- Third stage: Response Operations

Response Operations refer to:

n Fire fighting using extinguishers or pressurewater network or foam.

n Spill control (of lubricants or fuel usingabsorbing material) or confinement.

n Dispersion of gas clouds. Access control toaffected area.

n Medical assistance and evacuation of injuredpersonnel.

n Evacuation of all personnel if their lives are indanger (in the event of earthquakes, tsunamisor other factors).

n Application of a monitoring program and amitigation plan.

a) Response guide. In the future, theContingency/Emergency Plan will apply thespecific response procedure for each emergency,which procedure will be described in detail andin a language that is easy to understand. It willform part of the documents to be deliveredduring the induction process and there will be atleast 2 drills per year in order to keep thepersonnel trained.

The communication chain with information oncontacts and notifications must be establishedand maintained.

Furthermore, the logistic chain to replaceequipment and consumables must be established,determining a minimum stock at the Plant, whichfor the case of fire must be in line with the riskstudy and the list of suppliers containing thecontact name, address and telephones availableon a 24-hour basis the 365 days of the year.




iv- Fourth Stage: Evaluation of the Plan andof damages

Once response operations have concluded, thedevelopment and results of the Plan must beevaluated in order to issue recommendations thatallow correcting deficiencies for the purpose ofimproving response operations. Theserecommendations will then form part of revisionand subsequent annual approval of the Contingencyand Risk Prevention Manual.

A record of damages will be prepared as part ofthe final emergency report. The resources used,lost and recovered will be detailed in saidregister.

N- Emergency Response Manuals

Including the proponent's commitment toprepare written emergency plans for the pipeline,plant and marine terminal to cover emergencysituations that could occur, based on the results ofa Quantitative Hazard and Risk Assessment. Itwas agreed that Emergency Response Manualswill be developed for:

n LNG Plant Accident Response;

n Loading Facility and LNG Carrier AccidentResponse;

n Pipeline Rupture Contingency Plan; and

n Platform Emergency Response.

O‑ Responses to Emergencies withinthe Terminal

i‑ Emergency ClassificationDetermination

Controllable Emergency: This is an emergency inwhich the Terminal Operations Personnel canprevent harm to personnel or equipment bytaking reasonable and prudent actions such asvalve manipulations, shutting down equipment,or initiating the Emergency Shutdown System.Examples of Controllable Emergencies that may

occur at the Terminal include:

n LNG spills that are contained within the LNGspill containment system and do not result infire;

n LNG spills that are contained within the LNGspill containment system and result in a firewithin the containment system;

n Overpressure of gas or liquid process piping;

n Collapse of buildings or systems andequipment that does not result in or does nothave the potential to result in the loss ofcontainment of LNG or flammable gases;

n Building fires that do not involve flammablegases;

n Electrical fires that do not involve flammablegases;

n Loss of electrical power;

n Emergency LNG carrier departure –unexpected LNG carrier disconnect;

n Vehicle accidents;

n Severe weather conditions; and

n Breaches of site security that do not result inor have the potential to result in substantialdamage to the Terminal.

Uncontrollable Emergency: An UncontrollableEmergency involves situations that have thepotential to result in exposure of personnel orproperty to natural gas in a liquid, cold vapor, orgaseous state or may result in fire or explosion.Examples of Uncontrollable Emergencies thatmay occur at the Terminal include:

n LNG spills that are not contained by the LNGspill containment system and do not result infire;

n LNG spills that are not contained by the LNGspill containment system and result in anunconfined fire;

n Flammable gas leaks from significant failure




of a pipeline or equipment;

n Building or equipment fires that contain orhave the potential to contain flammable gases

n Structural failure of an LNG storage tank;

n Major fire aboard an LNG Carrier;

n Bomb threats; and

n Severe weather conditions that cause wide-scale damage to equipment and systems thatresult in or have the potential to result in aloss of containment of LNG or flammablegases.

n In addition, a Security Breach that results in ahigh probability of substantial damage to theTerminal that may create an UncontrollableEmergency will be considered anUncontrollable Emergency, even if nodamage has yet occurred.

Examples of this situation include:

n Discovery of an explosive device in closeproximity to an LNG tank or major LNGpipeline or natural gas pipeline; and

n An act of sabotage that may result instructural failure of an LNG storage tank orrupture of an LNG tank or major LNGpipeline or natural gas pipeline.

n An Uncontrollable Emergency is then furtherclassified as a Site Emergency or a GeneralEmergency.

Uncontrollable Emergency – TerminalEmergency: This is an Uncontrollable Emergencythat threatens personnel or equipment withexposure to natural gas (liquid, cold vapor, orgaseous state) or involves a fire or explosion of amagnitude that involves a large portion of thefacility.

A Security Breach that results in a highprobability of substantial damage to the Terminalis considered a Terminal Emergency.

Uncontrollable Emergency – General

Emergency: This is an Uncontrollable Emergencythat threatens the public with exposure to naturalgas (liquid, cold vapor, or gaseous state) orinvolves a fire or explosion of a magnitude thataffects persons or property off-site. At theinstruction of the Terminal Emergency Director,emergency help will be requested by the PublicInformation Contact from off-site emergencyorganizations during a General Emergency.

Additionally, the Terminal Emergency Directormay recommend an evacuation of the localcommunity in accordance with Section 3.3.2 ofthis Emergency Response Plan.

ii‑ Emergency Classification Summary

In summary, there are ultimately three types ofemergencies:

n Controllable Emergency;

n Uncontrollable Emergency resulting in aTerminal Site Emergency; or

n Uncontrollable Emergency resulting in aGeneral Emergency.

iii‑ Terminal Alarm System, HazardDetection and Mitigation System andShutdown System

The following describes the hazard detection andmitigation system that is installed on board andwhich will be used to alert to and mitigate theimpact from the Controllable Emergency andUncontrollable Emergency situations.

Hazard Detection Systems: A Hazard Detectionand Mitigation System (HDMS) are installed toprevent the occurrence of physical situations thathave the potential to result in injury to personneland/or damage to property and the environment.The HDMS accomplishes this by detecting andalerting operating personnel to the presence offire and flammable gas leak hazards.

The hazard detection system consists of acombination of heat detectors, flame detectors,




smoke detectors, high and low temperaturedetectors and flammable gas leak detectors.

Emergency Shutdown Systems: An EmergencyShutdown System (ESD) is installed to initiateclosure of valves and the shutdown of processdrivers during emergency situations. All othershutdowns that are not ESD are designated asprocess related trips.

LNG Carriers that arrive at the Terminal havetheir own ESD system, which will be connected tothe Terminal ESD system through an umbilicallink, which will be established prior to unloadingLNG.

8.3- Responsibilities, trainingand communication

8.3.1- Responsibilities

The roles and responsibilities of PGPL's ProjectManager, the Engineer, the environmentalinspection/quality assurance team, thecontractors, all EMP holders and all personnelwill be defined in this section. An organizationalchart of the LNG Terminal Project EnvironmentalManagement Roles and Responsibilities will beincluded in this section.

A- General Manager (Operations)

Environmental management plan will beregulated by the General Manager (Operations) ofPGPL. Some of the key role and responsibilitiesare described below:

n To consider and react to issues and solutionsproposed by the HSE department.

n To cooperate and consult with relevantenvironmental agency in order to perform inbetter way.

n To approve any change in decision makingand authorities in consultation with ManagerHSE, if appropriate.

B- HSE Manager

The role of HSE manager is vital. The success ofan EMP always depends on Proper and effectivemanagement provided by HSE manager.Following are some of the roles andresponsibilities given should be provided by HSEmanager:

n To identify issues and where possiblepropose solutions for inclusion in themanagement plan review process.

n To ensure that the points of view of staff,contractor and HSE officers are considered andplaced in the EMP accordingly.

n To improve coordination and exchange ofinformation between top management,employees, contractors etc.

n To contribute towards the actions to deliverthe management plan and ensure itscontinual development.

n To review EMP every year under thesupervision of top management, taking issuesand change EMP accordingly with thesolutions and suggestions.

n To monitor the progress, development andimplementation of this management plan.

C- HSE Officer

The role of HSE manager will be empowered byHSE manager. The superficial responsibilitieswhich an HSE officer will have to performinclude:

n To integrate, as far as possible, the aims andobjectives of different users within an agreedplan.

n To maintain balanced, holistic approach tothe solution of concerned issues inaccordance with the compliance to thelegislative requirements.

n To provide professional guidance onquestions relating to the environmental




management and issues raised bycontractors/relevant personals.

n To progress the EMP process throughdevelopment towards implementation.

D- Construction Contractor

On behalf of chief construction contractor, the mainresponsibilities for all matters pertaining toenvironment will be looked after by fieldConstruction Contractor and he will be responsibleto report directly to HSE Manager. Major roles to beperformed by construction contractor are givenbelow:

n To carry out construction activates inenvironmentally sound manner.

n To coordination with the HSE officer toresolve issues arise during constructionphase.

n To manage construction crew and reduce theenvironmental impacts.

n To appoint a dedicated environment officersthat will understand and tackleenvironmental issues more easily.

n To discuss weekly progress report with HSEManager and issues concerned toenvironmental management.

E- Environmental Inspector

n An Environmental Inspector (EI) isresponsible to supervise the environmentalcompliance and inspection process.

n Environmental inspector is also responsibleto communicate with Environmentalmanager and the chief constructions officers.

n Environmental inspector provide key liaisonrole in coordinating attendees and facilitatingagreements in the field, as appropriate, withagency representatives.

n Coordinate daily with constructioninspectors, the contractor, when construction

activities are scheduled in all requiringmonitors.

n The EI will play a significant role suggestingmethods to bring construction activity intocompliance and/or to temporarily haltcertain activities that may cause damage tosensitive environmental resources.

n In addition to these responsibilities, theenvironmental inspector contributes to theEnvironmental Management Team bydeveloping swift and innovative solutions tounanticipated environmental issues whichdevelop during construction.

F- Site (Operation) Manager

n The site manager is responsible andaccountable for the site's HSE performance.

n Establishes, implements, and maintains aformal written plant-HSE program thatencompasses applicable areas of lossprevention and is consistent with corporatepolicy.

n Establishes controls to assure uniformdepartment performance to the HSEmanagement system. The establishment ofcontrols should include corrective action andfollow-up. Develops, by action and example, apositive HSE culture and a clear understandingof specific responsibilities for direct reports.

n Approves and adopts local HSE policies,rules and procedures.

n Chairs the Executive HSE Committee (or itsequivalent).

n Personally investigates fatalities, serious LostWorkday cases, environmental incidents ormajor property losses.

n Assigns management members to serve onvarious HSE committees.

n Reviews monthly HSE activity report andperformance statistics.




n Reviews Lost Workday Injury/IllnessInvestigation Reports.

n Reviews loss-control reports submitted byoutside agencies.

n Makes plant-HSE audits on a regular basis inorder to appraise program effectiveness andto correct and reinforce behavior.

n Reviews annually the program effectivenessand makes adjustments where necessary.

n Evaluates the functional performance of theHSE staff and provides guidance trainingwhere necessary.

n Personally reviews, signs, and approves ofcorrective action planned for Lost Workdaycases.

G- Department Manager (Department Head;Area Superintendent)

n Contacts each supervisor/foreman/leadperson frequently (daily) on HSE.

n Includes HSE as a meeting topic in staffmeetings.

n Makes daily observations ofsupervisor/foreman/lead person's HSEactivities.

n Reviews and approves all job proceduresgrowing out of Job Safety Analysis; installsapproved procedures; requires direct reportsto check on use of procedures.

n Approves all departmental HSE rules andregulations and reviews annually; maintainsstrict enforcement; and develops plan toensure employee instruction and re-instruction.

n Establishes acceptable housekeepingstandards, defining areas of responsibility;assigns areas to supervisor/foreman/leadpersons; makes daily spot check of some area;holds formal inspection withsupervisor/foreman/lead persons at least

once per month; submits written report withassignments and deadlines for correction.

n Authorizes purchases of tools and equipmentto comply with plant specifications andgovernmental regulations as required.

n Develops an indoctrination plan, whichincludes specific job instruction, for new ortransferred employees; issues protectiveequipment and follow-up checks bysupervisor/foreman/lead persons.

n Reviews the HSE performance of his area ofresponsibility.

n Personally investigates all "Lost Workday"cases and significant losses and reports toplant manager. Follows-up on correctiveaction.

n Adopts standards for assigning protectiveequipment to employees; insists upon strictenforcement; and makes spot field checks todetermine compliance. Also reinforces safebehavior.

n Evaluates supervisor/foreman/lead persons'HSE performance.

n Develops strong HSE culture and a clear-cutunderstanding of specific duties andresponsibilities in each member ofmanagement.

H- Supervisor/Foreman/Lead Person

n Makes daily safety observations of the workarea and corrects unsafe behavior andreinforces safe behavior.

n Arranges for development of job safetyanalysis; reviews all job safety analysis; andsubmits to department manager for approval.

n Develops a workable housekeeping program,defining areas assigned to work teams; makesdaily spot checks of an assigned work area;makes periodic housekeeping inspections,reporting results of inspection to department




manager and indicating condition andcorrective action.

n Ensures the indoctrination of new ortransferred employees.

n Develops protective apparel requirements,according to occupation; and makes spotfields checks to determine compliance.

n Reports all injuries or illnesses of employeesto department manager as soon as practical;reviews Accident Report with employeesand, in case of injury, submits reports todepartment manager after taking correctiveaction.

n Makes thorough investigation of all accidentsand serious incidents occurring to employeesin assigned work area; makes personalinspection; and develops preliminaryinformation.

n Conducts scheduled and assigned HSEtraining meetings.

n Participates on HSE committees as specifiedby plant policy.

n Reviews unsafe conditions and unsafebehavior and directs daily HSE activities tocorrect these causes.

n Instructs employees in HSE rules andregulations; records instruction; and enforcesall HSE rules and regulations at all times.

n Makes daily inspections of assigned workarea and takes immediate steps to correctunsafe or unsatisfactory conditions; reportsto department manager those conditionswhich cannot be immediately corrected;instructs employees on housekeepingstandards.

n Instructs each new employee personally onjob HSE requirements in assigned work areas.

n Enforces the plant's medical departmentrecommendations with respect to anemployee's physical limitations; reports an

employee's apparent physical limitations todepartment manager.

n Enforces wearing of protective equipment;makes spot checks to determine thatprotective apparel is being used; and makesperiodic checks to appraise condition ofequipment.

n Sees to it, in case of serious injury, that injuredemployee receives prompt medical attention;isolates area or shuts down equipment, asnecessary; and immediately reports to thedepartment manager the facts regardingemployee's accident or illness and the actiontaken. In serious incident cases, thesupervisor/foreman/lead person determinescause, takes immediate steps to correctcondition, and isolates area and/or shutsdown equipment, as necessary.Supervisor/foreman/lead personimmediately reports facts and action taken tothe department manager.

n Checks changes in operating practices,procedures and conditions at the start of eachshift and before relieving the "on-duty"supervisor/foreman/lead person, notingfacts related to HSE which have occurredsince his last working period.

n Makes, at the start of each shift, an immediatecheck to determine absentees. If plant injuryis claimed, an immediate investigation isinstituted and department manager notified.

n Makes daily spot checks and takes thenecessary corrective action regardinghousekeeping; spills and storage of hazardouswaste & materials; unsafe behavior orpractices; unsafe conditions, tools, ladders,wire rope, chains, clevises, pins, spreaders,etc.; job procedures, and adherence to HSErules.

n Instructs personally or provides on-the-jobinstruction in HSE and efficient performanceof assigned jobs.




n Takes action on all employee HSE complaintsand suggestions.

n Maintains HSE signs and bulletin boards in aclean and legible condition, in assigned area.

I- HSE Supervisor/Manager

n Provide overall coordination and guidance tothe site HSE efforts.

n Develop programs that are designed toreduce exposure to loss via personal injury orillness, loss by fire, loss due to spill ofhazardous materials or waste, and complywith governmental regulations.

n Supervise and coordinate the efforts of theHSE department staff.

n Collaborate on a routine basis with the sitemanager in appraising the performance of alldepartments.

n Develop recommendations for improvementof procedures, practices and activitiesdirectly or indirectly involved in effectiveexecution of HSE functions by sitemanagement.

n Advise and/or represent site management inall matters concerning compliance withfederal and state HSE regulations.

n Audit the site from a regulatory andmanagement system perspective andrecommend actions to address deficiencies.

n Maintain membership in necessary outsideHSE organizations.

n Participate in the review of all seriousincidents, fatalities, and major disasters.

n Collaborate with the site manager in thedevelopment and preparation of ExecutiveHSE Committee Meeting agenda.

n Serve as a member of site committees forspecial HSE studies and programdevelopment.

n Consult with the Manufacturing Engineeringdepartment on original plans; see that all plansand specifications for new or proposedchanges in processes, equipment or methodsare reviewed from compliance with HSEstandards before being accepted.

n Function as liaison with insurancecompanies, Corporate HSE, local fire andrescue organizations, etc.

n Provides leadership to the site for theimplementation of new technologies such asbehavioral-based safety managementconcepts.

n Reinforces safe behavior and corrects unsafebehavior.

J-HSE Coordinator

n Assist the site manager in coordinating allHSE activities.

n Reinforces behavior and corrects unsafebehavior.

n Be constantly alert for unsafe conditions andbring such conditions to the attention of thesupervisor and, if necessary, the site manager,without delay.

n Participates on the site's Executive HSECommittee.

n Accompany outside inspectors representinginsurance carriers of fire, casualty, andworkers' compensation insurance.

n See that HSE promotional and referenceliterature, such as monthly handouts, areavailable.

n Be thoroughly familiar with company HSEstandards and assist the site manager inimplementing them.

n Maintain injury and incident statistics.

n Assist the site manager in analyzing incidentrecords, develop supervisory and employeeeducational programs and stimulate a high




level of interest in HSE through variousemployee-involvement activities.

n Understand current Federal and state HSEregulations.

n Serves as the liaison between Corporate HSEand the site.

n Provides leadership to the site for theimplementation of new technologies such asbehavioral-based safety managementconcepts.

n Regardless of the position the HSECoordinator holds in the plant organization,his function as HSE Coordinator must be onlyadvisory. Any corrective actions must be takenby the concerned line supervisor. It is mostimportant that the HSE Coordinator's position

be recognized as one of guidance notenforcement

K- Personnel Safety Supervisor

Every supervisor has at least three responsibilitieswith which Environmental Safety can provideassistance. These responsibilities are employeetraining, provision of personal protectiveequipment and accident & injury reporting.

i- Employee Training

Supervisors are responsible for ensuring that eachnew employee, whether temporary or permanent,receives appropriate safety training at the start ofemployment. Supervisors are responsible forensuring that their employees receive thenecessary safety training based on the work thattheir employees perform.




GENERAL ORGANIZATION FOR ENVIRONMENTAL MANAGEMENT

ii- Personal Protective Equipment

OSHA requires each supervisor assess the hazardsof the work area to determine the type ofprotective equipment needed and to providetraining on its use. This review must bedocumented. Completing the Hazard AssessmentForm meets this documentation requirement. ThePersonal Protective Equipment Plan includesdetailed information to assist in selecting theproper protective equipment.

iii- Accident and Injury Reporting

It is the supervisor's responsibility to report allaccidents or injuries that occur to their employeeswhile at work. Each supervisor must ensure that anyemployee who is injured while at work completes andsigns the Employee's Report of Work-Related InjuryForm. Additionally, the supervisor must receive theemployee form, Accident Witness Statement Form (ifthe accident was witnessed by another person), and fillout a corresponding Supervisor's Report of Work-Related Injury Form.

L- Public Relation (PR) Manager

The Public Relations (PR) Manager will haveresponsibility for managing client's corporatepublic relations efforts, reporting to the VicePresident of Corporate Communications. ThePublic Manager will develop and execute anintegrated public relations plan based onmarketing strategy and reflecting the individualdivisional (service line) public relations objectives.The role requires careful cross companycollaboration and will necessitate both strategicleadership and practical execution. This is acorporate role with broad responsibility formanaging both corporate and product PRprograms, also responsible for collaborating withand advising international public relation PublicRelation PR teams/agencies.

M- Individual Employees

n Employees must assume a high level ofresponsibility to work safely and strive for an

incident-free workplace by:

n Considering the consequences of their acts ontheir safety and that of fellow employees.

n Following all general and job related HSEwork procedures and practices.

n Detecting, reporting and correcting unsafework behavior or conditions.

n Applying HSE work practices both on and offthe job.

n Making or suggesting enhancement to thejobs at hand to reduce or eliminate the risk orstresses associated with job performance.

n Reinforcing safe behavior.

n Working safely and with regard for theenvironment is a condition of employmentand no employee should ever consciouslyperform an unsafe act.

8.3.2- Training

It's an important step for the implementation ofthe EMP. All the employees will require to betrained to work appropriately on EMP. Trainingcoordinator will organize trainings inconsultation with HSE Officer. It will make surethat employees understand the issues associatedwith the proposed activities. Trainings should bearranged on regular basis with notification that itshould be attended all respective employees.

HSE Officer will determine the trainingrequirements during both construction andoperation phases. Induction will be the basis of alltraining courses for contractor and subcontractorduring construction phase.

Trainings identified in EMP are given below:

n Site induction course

n Training for emergency response andpreparedness

n Training for familiarization with siteenvironmental controls




n Specific environmental training for relevantemployees e.g. installing erosion andsedimentation controls, daily checks tomaintain controls, cleaning up pills, wasteminimization.

The Plant and Terminal will have (i) DistributedControl System to monitor and control the plantprocess and operation, (ii) Fire and gasdetection and alarm system, and (iii) anemergency shut off system. Each of thesesystems will be separated from each other, toprovide data and communication transmission.

A permanent fire fighting system will beinstalled, which shall include fire fightingwater, foam generators and CO2 extinguishers.The personnel will be trained in the use andoperation of said systems.

Equipment such as fire trucks, fire fightingequipment, medical hospital equipment,ambulances and environmental protection andspill control equipment will also be provided sothat they will be available in the event of anemergency.

The aim is to instruct all personnel on theoperation of this equipment and on the procedureto be followed in the event of spills, fire orexplosions.

A- Personnel training

Both the personnel in charge of unloadingoperations at the LNG jetty terminal and on shoreLPG terminal, as well as the Terminal personnel,are conveniently trained to carry out their workand respond to any emergency.

i- Identification of training requirements

a) Procedure to respond to a spill in thewharf

n Any spill that takes place in the wharf area,originating from a Ship or from connection hoses,will be immediately reported to the Safety Area.

n Unloading operations must be immediatelyhalted in coordination with the Ship.

n Every possible ignition source in the areamust be eliminated.

n If a spill occurs on the wharf, the planmust be always activated because there is apossibility that the product might spill intothe water, or there may be other situationsthat could jeopardize other facilities withinthe Terminal.

n Containment equipment must be readilyavailable to contain as much as possible the spillof the product onto the wharf or adjacent areas.

b) Procedure to respond to a spill on theground

n The area must be isolated and unauthorizedpeople should not be allowed to enter thespill site.

n Every possible effort should be made to stopthe spill, if at all possible, without runningany major risks.

n Every possible effort should be made tocontain the spill and thus prevent the spillfrom spreading on the ground. In this case,makeshift dams will be constructed orcontainment booms will be installed, ifpossible.

n For large spills, every possible effort shouldbe made to contain the spill with makeshiftdams or fences, or with absorbent material orcontainment booms, in order to then becollected.

n Flammable substances that could explode orcatch fire, located in areas surrounding thespill, should be taken out of the area.

n Basic fire-fighting procedures.

n Three basic procedures should be borne inmind in fighting a fire.

n Fuel should stop being supplied (valves




should be closed, transfers should stop, etc.).

n Air should not come into contact with thefuel; therefore, the fire area should be coveredwith foam.

n The heat produced by the evaporation of theproduct should be eliminated, becausevapour is combustible, and water is the mosteffective agent for this purpose.

n To control any fire at the Terminal, the firststep will be to isolate and evacuate the area,besides taking the following precautions:

n Remove all containers from the area exposedto fire and heat, if it is possible to do it in asafe manner.

n Cool the sides of the containers that areexposed to the flames or heat, using water.

n If the fire is intense in the loading areas,support-mounted hoses operated at a distanceor monitor guns should be used.

c) Procedures to respond to a fire on theship

n If a fire breaks out on a ship, then, besides thebasic fire fighting procedures, the followingsteps will be taken:

n If the fire breaks out next to the mooringwharf, loading operations must beinterrupted immediately and the ship mustget ready to weigh anchor.

n If the fire breaks out aboard the ship, then thecaptain and the crewmembers should giveimmediate notice thereof to the technicalpersonnel working at the Terminal for thelatter to halt all operations.

n Crewmembers must identify the type of firein order for the personnel working at theTerminal to mobilize the appropriate internalor external resources required to promptlyrespond to the incident.

d) Procedures for flammable substances

(methane).

To respond to a seepage involving a flammableproduct, the following steps should be taken:

n Isolate the area.

n Eliminate every source of ignition in the area.

n Use duly grounded armoured equipment inthe Hot Area.

n Try to seal the seepage, if it is possible to doit in a safe manner.

n Try to contain the product to prevent it fromfiltering into drainage networks or otherplaces.

n Monitor flammability indices in the risk areato analyze the need to isolate a broader area.

n Remove the product with absorbentmaterial or other mechanical means in orderfor wastes to be properly disposed of.

e) Procedures for toxic substances

In situations involving the seepage of liquidsubstances classified as toxic, the most importantthing to do is to wear appropriate breathingequipment.

If there is any doubt regarding the concentrationof the substance in the environment, breathingequipment that affords the highest possibleprotection will be worn, that is, self-containedcompressed-air breathing masks and appropriateclothing.

In addition, the following steps will be taken:

n Isolate and evacuate the area that poses adanger immediately.

n Try to seal the seepage, if it is possible to doit in a safe manner.

n Try to contain the product to prevent it fromfiltering into drainage networks or otherplaces.

n Permanently monitor the concentration of




vapors in the risk area to analyze the need toisolate a broader area.

n Remove the product with absorbent materialor other mechanical means in order forwastes to be properly disposed ofDecontaminate all clothing, equipment,materials and areas reached by the product.In addition to the above training, workersshould be aware of the following:

ii- Operations involving oily substances

a) Person in charge

The person in charge of the plant will personallysupervise all operations involving oilysubstances. Said person will closely cooperatewith and remain in close contact with the personin charge of the loading of oily substances in thevessel and with the wharf personnel.

b) During loading operations

Loading will begin at the minimum pumping rate,in order to be able to quickly stop the supply ifthere is any problem. The pressure of supply pipeswill be checked to make sure that the maximumworking pressure is not being exceeded. Thehydrocarbon supply tank will be frequentlymeasured.

Upon completion of loading operations uponcompletion of loading operations, and once allflexible pipes have been drained, a drip tray will beleft below the flexible pipe connections, whenloading hydrocarbons. Flanges will then bedisconnected and a blind flange will be installedon one end of the hose.

iii- Check list

a) Before loading Hydrocarbons

n There should be a clear signalling system inplace to report the commencement of loadingoperations, reduction in the loading rate, theend of loading operations, and emergency

shutdowns.

n All intake and discharge valves in the seashould be closed.

n Blind flanges should be connected to allvalves that are not going to be used.

n High-capacity drip trays should be placedbelow pipe connections.

n Flexible pipes and loading arms should be ina good condition, properly connected, andcorrectly supported.

n There should be sufficient and readilyavailable absorbent material in place.

n The valve in the tank where the product is tobe loaded should be open and duly aligned.

b) While loading Hydrocarbons

n There should be no leaks in flexible pipes orpipe connections.

n The reduction in the pumping rate during thelast phase of loading operations should bereported well in advance.

n Proper notice should also be given whenloading operations are intended to bebrought to a full halt.

n Sufficient room should be left in the tanks inorder to be able to drain flexible pipes and theentire pipeline system used in the respectiveloading operations.

c) Upon completion of loading operations,check whether:

n Distribution valves have been closed.

n Flexible pipes and loading arms have beendrained before being disconnected.

n Blind flanges have been installed in theaforesaid pipes.

n The valves in the loading system have beenclosed, including intakes in the hydrocarbon




supply tank.

iv- Training schedule

As part of its policy, emergency drills will becarried out at least twice a year, which will allowthe personnel to carry out and learn the actionsthey must take and the attitude they must have inthe face of real emergency situation

During training, consideration of following areasof knowledge and experience are essential:

n Appreciation of properties of hazardous substancese.g., toxic, flammable, reactive etc, as well as, levelsat which they pose a considerable menace requiringprotective measures.

n Knowledge of early-warning indicators,hazard/risk identification and ability to recognisepotentially hazardous situations.

n Acquaintance with engineering control to evade theincidence of hazardous situations.

n Familiarity with capability and restraints of facilityto respond the hazardous emergencies, ventilatingsystems, plumbing systems, shut off systems,containment strategies and emergency responsemeasures.

n Awareness of use, repair/ maintenance ofemergency response equipments as well asroutine equipments to health and safetymonitoring and protection.

n Awareness of methods and trials fordecontamination personnel equipments and facilityfollowing potential chemical contaminations.

8.3.3- Communications

For effective monitoring, management anddocumentation of the environmentalperformance during the operation, the Health,Safety and Environmental (HSE) matters will bediscussed during daily meetings held on site.Environmental concerns raised during themeetings will be mitigated after discussionsbetween the HSE officer and the contractor. Any

issues that require attention of highermanagement of PGPL will be communicated tothem for action. The HSE officer and thecontractor will also prepare a weeklyenvironmental report. Duplicates of the reportwill be provided to the higher managements ofPGPL and of the contractor. Communicationwill play a vital role in good managementpractices. Steps given below will assist ineffective communication and documentation.

A- Kick-off Meeting

The aim of organising the kick-off meeting is todefine the environmental responsibilities,awareness to EMP to the managing staff and tostreamline the work plan according to the EMP.This meeting will be arranged prior tocommencement of activities.

B- Quarterly Meetings

Initially quarterly meetings will be held after kick-offmeeting however if situation demands for monthlymeetings, it will be rearranged accordingly. Aim ofthis meeting is to review the progress of activitiesperformed, explore ideas and problems, and discussabout the progress in acquisition and analysis ofinformation. Dead lines are re-evaluated in it and ifnecessary, the project program is revised in thesemeetings.

C- Peer Review

The aim of this review is to predict and modify theconclusions and interpretation of assessment phasesin the light of other professional opinions thatmainly not involved in the proposed project, butjust for the provision of a critical appraisal of thestyle and expression of documentation produced.

D- Minutes of Meetings

In the end of quarterly meetings, minutes will beissued which comprises of the discussion made in themeeting, issues discussed and decisions taken with thetime frame for their implementation. Main points of




minutes for general employees may be incorporated inthe record register. These meeting minutes will also beprovided to the higher authorities of PGPL and thecontractor for their own record.

8.4-Regulatory requirements

8.4.1- Approvals, authorisationsand permits

The list of potential approvals, authorizations andpermits required for the Project from variousagencies including, federal, provincial, municipalare given below:

n Sindh Environment Protection Agency, forwhich this document would be submitted forgrant of permission and approval of theproject.

n Port Qasim Authority

n Maritime Security Agency

n Sanction of utilities from concern departmentsuch as KESC, SSGC, KW&SB, PTCL and othercivic agencies including City District Governmentof Karachi, etc.

8.4.2- Environmental qualityobjectives

This section will outline criteria for management'squality objectives related to generation of solidwaste and wastewater quality, air and noisequality. The management of PGPL shall makeEnvironmental Objectives every year and try tocomplete them in the stipulated time frame.

This will also include any applicable treatmentcriteria meeting the National EnvironmentalQuality Standards (NEQS) as per PakistanEnvironment Protection Act 1997.

8.4.3- Compliance monitoring

It would be required by the management of PGPL tocomply with the Environmental Monitoring Plan laidin the subsequent section. The compliance shall also

required periodic reporting of the monitoring results inform of report submitted to the EnvironmentalProtection Agency. During the construction phase, itwill be on bimonthly basis and during the operationphase it will be done on quarterly basis.

It is also understood that monitoring shall be done byan independent consultant/ organisation. It would befurther required to make the annual environmentalreport public as laid under the Equator Principles.

Equator Principles (EP) requirements were taken careoff in this EIA report and it is one of the mandatoryrequirement of EP to report all the stakeholders andannounces their EHS performance publically atleastonce a year.

8.5- Standard OperatingProcedures

8.5.1- Barge and supply shipoperations

A- Purpose

n To achieve the desired productivity.

n To delineate the method for handling of cargofrom and to vessel efficiently, effectively andsafely.

B- Scope

This procedure applies to all vessels calling theterminal.

C- Definitions

A barge is a flat-bottomed boat, built mainly for riverand canal transport of heavy goods. Most barges arenot self-propelled and need to be moved by tugboatstowing or towboats pushing them.

D- Procedure

i- Information Required

Shipping efficiency is highly dependent upon the




quality and timing of information made availableto the Terminal Planning Section. This section isresponsible for, amongst other activities,preparing quay crane utilization plans andcontainer discharge and load sequences.

Information sources are:

a- Shipping Line: responsible for providinginward bay plan information, container statuslists, reefer container information, dangerouscargo declarations and any particular informationwhich may be useful in ensuring smoothoperations. For planning purposes thisinformation should be available to the terminal atleast 24 hrs prior to vessels arrival with updatesfrom the last port of call at least 12 hours prior tovessel arrival. Communications should bethrough fax or emails.

b- Shipping Line Agents: responsible forproviding details of containers to be received forexport. For planning purposes initial indicativeinformation should be made available to the terminalseven days prior to vessel arrival with generalindications of containers to be handled by size, port ofdischarge, weight classification, commodityclassification, reefers, dangerous cargo etc. The initialinformation is to be regularly updated as more specificinformation becomes available. Communications withthe terminal may be either using fax or emails.

n The Operations Superintendent: is responsible forensuring the best information is availableconcerning availability of cargo handlingequipment and manpower availability (by driverskills); and

n The Terminal Yard Planner: is responsible formanaging and providing and monitoring yardarea allocations for the optimum utilization of thecargo space at time of receiving at the terminal.

ii- Planning for Operations

In all cases the start position for operations occurswhen, through the Vessel Planner, the SPARCSsystem generates off-loading working programsand sequence sheets for storage facility to be

worked. These planned ship-working programswill have taken into account:

n Vessel stability requirements

n Disposition of cargo to be discharged fromthe vessel

n The yard stacking disposition of cargo to beloaded to the vessel

n Resource availability by way of cargohandling equipment and manpower

n Conditions of contract with the client.

iii- Ship Working Systems

Ship working systems at a terminal may feature anumber of methodologies. The two mostcommonly used are shown below:

An ECH system whereby containers are movedbetween the quay gantry cranes and containeryard stack using internal transfer vehicles. ECHare used for yard stacking.

8.5.2- Watercourse crossings

A-Purpose

The main purpose of watercourse crossing is notto disturb the sea water flow in the nearbychannels. Care must be taken to ensure that jettyconstruction, laying of pipeline and LPGextraction area do not cause erosion or have anegative effect on aquatic habitat. Fish passageshould not be obstructed as a result ofwatercourse crossing installations.

B- Scope

The scope of watercourse crossing is to constructwatercourse crossing and to ensure minimizationof harmful effects of watercourse crossings on theaquatic environment.

C- Definitions

It is natural or artificial channel through which




water flows.

D- Procedure

i- Construction of Watercourse Crossings

The location of all watercourse crossings is to beinspected and approved prior to construction.The chosen location of the watercourse crossingshould:

n Cross watercourses at right angles;

n Select crossing points which:

n Are immediately downstream of straight andstable watercourse sections;

n Have easy high bank access;

n Do not require deep box cuts;

n Require minimum alteration or disturbanceto the high bank;

n Have stable beds.

A series of monitoring studies were undertakento evaluate the effectiveness of the appliedcrossing techniques, to limit sediment releaseinto the watercourse and subsequent changes tohabitat conditions during, and after in-streamconstruction.

E- Watercourse Crossings ManagementOptions

Full compliance to all legislation protecting aquatichabitat is ensured. All necessary permits andapprovals will be obtained before any in-streamwork is initiated.

The potential harmful effects of watercoursecrossings activity within a water body can beeliminated or minimized by identifying theobjectives that are to be met when such an activityis undertaken. Objectives set out in the Code ofPractice are based on the principles of sustainablewater management.

These principles are:

n Sustainable management of water

n Water is a vital component of theenvironment.

n Water plays an essential role in a prosperouseconomy and balanced economicdevelopment.

n Water must be managed using an integratedapproach with other natural resources.

n Water must be managed in consultation withthe public.

n Water must be managed and conserved in afair and efficient manner.

The Code of Practice establishes the objectives,standards and conditions to be met whenundertaking the activity of constructingwatercourse crossing.

8.5.3- Wastewater/ storm watermanagement

A- Purpose of Wastewater/storm waterManagement

The purpose of the adopted procedure is toprovide guidelines and simplify the process ofcategorizing, quantifying, managing, anddisposing of wastewater wherever and wheneverarising during the project's construction andoperation phase. Wastewater management is acritical component of company's operatingpolicies. Wastewater management includes theproper disposal / recycling and reuse of thewastewater generated during construction andoperation phase. The procedure is designed toassist in a company's wide effort to provideprotection for the environment and to comply withcompany's corporate requirement, environmentallaws and regulations regarding proper wastewatermanagement.

B- Scope

Wastewater as part of drilling and construction,




production shall be managed as per thisprocedure. An integrated wastewatermanagement system for the LNG jetty andstorage terminal is essential to reducewastewater.

Substitute techniques must be investigated,including source reduction, recycling and reusewherever possible with a view towardsmaximizing the benefits and minimizing the costof each method of wastewater management.

Guidelines for proper handling, categorization,recording, minimization, and disposal of all typesof wastewater associated with companyoperations and projects are part of this procedurethat need to be documented.

This procedure shall be followed at all constructionsites by all company personnel and contractorsworking for this proposed project.

C- Definitions

(i) Wastewater

Any water arising after use/ consumption shallbe including of liquid waste discharged bydomestic residences, commercial properties,industry, and/or agriculture and can encompassa wide range of potential contaminants andconcentrations. In the most general terms, itrefers to the municipal wastewater that containsa wider range of pollutants arising due to themixing of wastewaters from different sources.

(ii) Hazardous Wastewater

Plant wastewater comes in the category ofhazardous wastewater. If it has one or moreof the following properties:

n Oily water

n Toxicity (may cause risk of injury to health oforganisms or the environment)

n Concentration of contaminants too highabove safe acceptable limits

(iii) Non-hazardous Waste:

The wastes are categorized as non-hazardouswastes, if they do not possess any of thehazardous contaminant mainly comprising ofconsumed water arising from washing area andsanitary wastewater.

D- Procedure

Main concern to manage the wastewater is listedbelow:

n Eliminate wastewater production whereverpossible.

n Minimize wastewater production.

n Recycle or Reuse

n Wastewater disposal in an environmentallysafe manner through adequately designedfacility

i- Wastewater Minimization

Generation of wastewater will be minimizedthrough the following steps taken by workingpersonnel at the facility:

n Through efficient use of raw water(minimizing the wastewater).

n Extensive management schemes will beformulated for both phases duringconstruction and operations (watermanagement).

n It is expected that segregated and /or treatedwastewater will be made available forsubsequent use during operations phase(recycling and reuse).

ii- Storage and Handling

Wastewater shall be stored / retained in linedponds or storage tanks till proper onsitetreatment or remote disposal.

iii- Recycling

Reuse of wastewater is a best way to reduce the







Table-8.2: Wastewater Data Sheets Guidelines for Wastewater Management

Plant Wastewater

Description n General water from washings, etc.

Components n Water

n Total Dissolved Solids (TDS) and total suspended solids

n Oil

Waste Category Non-hazardous

Analysis Refer Monitoring procedure for analysis requirements

(PRO/ENV/02).

Ownership / Responsibility Production Team Leaders

Accumulation/ Storage Stored in lined ponds or storage tanks till proper disposal.

Waste Handling When handling plant wastewater, protect yourself from

direct contact by using appropriate personal protective equipment

Waste Reduction n Reduce water use

Disposal Options n Recycle free oil back into the production stream

n Dispose water into lined evaporation ponds or skim pits

n Oily water from yards should be treated in oil/water

separator

Sanitary WastewaterDescription Wastewater from camps.

Waste Category Non-hazardous


(PRO/ENV/02).

Ownership / Responsibility Camp Administrator / PTLs

Waste Handling When handling sanitary wastewater/ sludge, protect

yourself from direct contact by using appropriate personal

protective equipment.

Waste Reduction Reduce water use.

Disposal Options n Treat wastewater in Redfox or in septic tanks before

disposal

n Sludge removed from Redfox or septic tank during

cleaning should be buried in burial pits.




Water produced from ground sources

Description Water brought up from the hydrocarbon-bearing

strata during the extraction process.

Components n Formation water

n Injected water

n TDS

n Petroleum hydrocarbons.

n Naturally occurring metals.

n Additive chemicals.

Waste Category Non-hazardous may be fairly contaminated


(PRO/ENV/02).

Ownership / Responsibility Production Team Leaders / Subsurface Operation Team

Leader / Well Works Team Leader

Waste Reduction n Use ro

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