Chapter 8-Environmental Management Plan

ESIA of LNG Terminal, Jetty & Extraction Facility - Pakistan Gasport Limited
8 ENVIRONMENTAL MANAGEMENT PLAN

8.1- Introduction Environment Health and Safety (EHS) laws,
regulations and internal EHS standards. In this
Environmental protection planning is an regard a sketch of environmental policy is being
important component of overall planning and given here which may be a part of PGPL's
implementation of mega-projects. Industrial corporate level policy once management of PGPL
activities, including those associated with the approves it.
construction of the PGPL's LNG terminal, are
reviewed and approved by Government agencies n The management and staff of PGPL are
through a variety of approvals, authorisations and committed to preserving and protecting the
permits addressing issues ranging from human quality of port area's environment. A clean
health and sanitation to fisheries and wildlife environment is important for the success of
habitat avoidance or protection. The our business and for that future generations
Environmental Management Plan (EMP) is an can also enjoy these precious resources.
important integration document between the In support of this commitment, we strive to
various approvals, authorisations and permits conduct clean material and goods export/import
issued for specific components and/ or activities of practices at Port area and educate our staff,
the undertaking. customers and guests on sound practices. Our
This EMP outlines the contents of construction overall goal is to create awareness among the
and operational phases both. It constitutes a PGPL staff and protect the environment due to
contract document for use in the field by the LNG Jetty and Pipeline operations. We will
contractor(s) and their personnel during achieve this goal by using a team oriented
construction as well as by the personnel of PGPL management approach to help ensure responsible
during operations. use of our air, land, and water resources.
PGPL and its construction contractor, through its To achieve this goal as a PGPL's management and
engineering and environmental consulting team, staff will put their all practicable efforts to meet or
is responsible for implementing the EMP and go beyond compliance with all applicable federal,
ensuring that all personnel are informed about local and international environmental rules and
the EMP and the requirement to implement the regulations.
procedures it contains. The EMP is intended as a We endeavour to continually improve our
quick reference for Project personnel and environmental performance and to prevent
regulators to monitor compliance, and is pollution before it is produced. All our employees
structured to allow updates and revisions as work are expected to support our environmental goals
continues. while providing clean and environment friendly
means of working practices and minimum
8.1.1- PGPL's Commitment to incident rate".
Environment, Health and Safety
PGPL is a sister organisation of Associated Group
PGPL is committed to manage and operate its which has a structured environmental program
assets in a manner consistent with its core values that involves environmental assessment,
to protect the health and safety of people and the monitoring, protection and rehabilitation of its
environment and to comply with applicable different projects. This EMP will strive for
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Environmental Management Consultants Ref: Y8LGOEIAPD
Chapter 8
continual improvement in the LNG jetty activities 8.1.3- Scope of the EMP
and its operations to maintain a healthy port
environment. The initial focus of the EMP is the protection of
aquatic habitat and traffic management due to
8.1.2- Purpose of the EMP increase in visiting people as well as those
activities under the direct control of PGPL
The primary purpose of this EMP is to establish management where activities may give rise to
the Environmental Protection Procedures to be significant environmental impacts, the EMP
implemented by PGPL staff, consultants and includes a number of priority strategies and
contractors. PGPL has committed to developing actions relating to these locations. The EMP also
and implementing a comprehensive EMP to help supports collaboration and joint actions with
ensure a high level of environmental protection
affiliated organisations, tenants and contractors
throughout this undertaking. This EMP provides
within the PGPL's sphere of influence.
the protection procedures associated with both
planned activities anticipated for the construction In line with the Environment Policy, the
and operations of the terminal as well as for following criteria will be used to determine
accidental events. priorities for attention:
The purpose of the EMP is to: n Impact on the physical and biological
environment;
n outline environmental protection measures to
be followed during construction of jetty / n Contribution to innovation and definition of
pipeline and operations of the facilities best environmental practice;
owned by PGPL such as the storage vessel,
n Compliance with statutory requirements and
pipeline, jetty, etc;
other environmental commitments;
n ensure that commitments to minimise
n Availability of resources.
environmental effects are met;
The EMP acknowledges the social and cultural
n document environmental concerns and dimensions of responsible environmental
appropriate protection measures; management alongside the biological and
n provide concise and clear instructions to physical, reflecting a holistic view of the PGPL as
Project personnel such as PGPL staff and a "human ecosystem".
contractors regarding procedures for The scope of the EMP includes the following
protecting the environment and minimising functional areas:
environmental impact;
n Management systems: Those systems
n provide a reference document for personnel employed in the management of the PGPL's
when planning and/or conducting specific operational activities. It will include financial
activities; systems; engagement and supervision of
n provide contingency plans for accidental contractors; purchasing policies, etc.
events; n Knowledge systems: Those processes which
n communicate changes in the program build knowledge and capacity on
through the revision process; and environmental issues, principles and
sustainable behaviours. It will include
n Provide a reference to applicable legislative training; communications; campaigns; links
requirements. with operational departments, etc.
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n Energy management: The energy-related laterals);

aspects of the planning, design, construction,
n Access roads; and
operation and maintenance of the PGPL's
facilities. n Supporting facilities and infrastructure.
n Water management: Aspects of supply,

8.1.4- Organisation of the EMP
usage and disposal of water pertinent to the
planning, design, construction, operation and The EMP will provide the procedures, organization
maintenance of the PGPL's facilities. and instruction to ensure Project personnel
understand and implement Environmental Protection
n Materials management: Those services and
Procedures for routine activities associated with the
activities which support the avoidance,
construction and commissioning of marine and land
resource recovery (e.g. reuse and recycling)
based facilities. The organization, style and format of
and environmentally responsible disposal of
the EMP is intended to enhance its use by Project
solid and liquid waste materials.
personnel in the field and to provide an important
n Planning, design and development: The support document between overall environmental
planning, design and development of the management of the Project and various permits and
PGPL's built form and associated authorizations issued for specific construction and
infrastructure. commissioning related Project components and
activities.
n Pollution prevention: Those aspects of
planning and management which support
minimisation of air and water pollution and
8.1.5- Maintenance of the EMP
contamination of land resulting from daily This section will outline the responsibilities and
routine activities. activities associated with the maintenance of the
EMP. The responsibilities of the Environmental
n Transport: Programs, projects, systems and
Monitor will be detailed and procedures for
procedures which promote and support
requesting EMP revisions will be outlined. EMP
walking, cycling and public transport for
revision procedures will include requirements for
trip-to-work, accommodation and other
related travel. notification of the appropriate government agencies
and First Nations.
n Biodiversity and open space: Those aspects
of management and maintenance which 8.2- Health & safety
support conservation and enhancement of
biodiversity and environmentally sustainable
8.2.1- Environmental health and
use of open space across PGPL and other
properties.
safety management system
The proposed scope of the Project subject to the This section will outline an Environmental Health
EMP includes all the main components of the and Safety Management System which will outline
Project mitigative measures and best management
practices. This management is recommended to
n Marine facilities and tanker approach lane carry out a complete assessment, evaluate,
out to existing shipping channel; monitor, identify and control all potential hazards
n LNG terminal and storage facilities; and risks arise during the construction, operation
and dissertation phases of the proposed project.
n Pipeline lateral and directly associated
The management needs to ensure that the Health
facilities (natural gas and natural gas liquid
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and Safety Plan (HSP) along with the Plant Health n Health and Safety implications about all
and Safety Rules is established and enforced. The hazards.
Plan will outline roles, responsibilities and
n Description about management techniques
expected outcomes with respect to the
including inspections, maintenance follow-
environmental health and safety management of
up, reports, personnel protective gears and
the construction phase of the Project. These medical monitoring.
measures should be implemented to ensure that no
significant adverse environmental health and n Outline of emergency response procedures
safety impacts are created by activities associated including organisational structure of key
with the construction of the Project. trained personnel to act as emergency
responders action steps for entering and
Protection of the public and workforce health and working within zone of hazards, evacuation
safety during both construction and operations is procedures, protective gear requirements,
paramount to PGPL. Utilising expert personnel decontamination procedures, lines of
and the (PGPL) Environment, Health and Safety communication, emergency call centres'
Management System (EHSMS), the potential telephone numbers, map of nearest medical
health and safety hazards and risks will be centres' route, etc.
identified and assessed, then the subject of
substantial planning, organisation and 8.2.2- Worker health and safety
procedural/facility development. plan
The LNG facility will be designed to include spill
This section will outline a Worker Health and
containment systems, fire protection systems, Safety Management System which will outline
multiple gas, flame, smoke and low- and high- mitigative measures and best management
temperature detectors and alarms, and automatic practices. Roles, responsibilities and expected
and manual shut-down systems. The efficiency outcomes will be defined. The Plan should be
and stability of operations will be maximised by implemented to ensure that no significant adverse
the use of a high level of automation, regular worker's health and safety issues arise from
preventative maintenance, and safeguards such as activities associated with the construction of the
back-up systems and the provision for safe Project. The Plan will apply to all PGPL personnel,
emergency shut-downs. Prior to project employees and contractors.
commissioning, all personnel will be required to
n Provide adequate worker training.
undertake an extensive training program to ensure
safe operating practices. The training program and n Use proper personnel protective equipment.
subsequent regular refresher programs will
n Follow fire protection measures.
involve issues covering operations, hazards, safety
and emergency procedures and environmental n Arrange availability of appropriate
management. emergency response, rescue, and first-aid
personnel and services.
The Plant Health and Safety Rules should include
provisions for, impediment of and response to
8.2.3- Emergency response plan
noxious chemicals and gases. It is also the
responsibility of the management to provide the Emergency may be defined as a sudden event
following basic information: causing or has the potential to cause serious human
injury and /or environmental degradation of large
n Description of all potential hazards/ risks. magnitude. The best "cure'' for an emergency is, of
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course, "prevention". When the Emergency Response Plan is put into

effect, Terminal Personnel will assume designated
The probable emergency situation can be:
positions, each with specific duties as depicted in
n Serious fire or explosion the following chart.
n Release of LNG in large quantities

A- Objectives
n Spillage of large quantity of acid/solvent or
The main objective of this plan is to establish the
major gas leakage.
general guidelines for actions to be taken in the
n Natural calamity such as heavy rain, event of fires, explosion, emergencies, accidents or
flooding, dust storm or earthquake, tsunami, hydrocarbon spills/leaks and spills of process
cyclone, etc. chemicals, natural disasters and sabotage, aimed at
minimizing their effects and consequences, in
n Bomb threat or any sabotage / terrorist
activity order to protect:
The physical integrity or the lives of own or third-
n Any other incident involving all or large part
party personnel present in the company's
of the premises and its workers.
facilities.
A Project-specific Emergency Response Plan will be
developed which primarily relates to the different n The physical integrity or the lives of the
construction activities of the Project as well as risks residents of the Company's Housing on
and hazards identified in QRA. It supports the EMP board FSRU.
and addresses actions and required responses all
n The physical integrity or the lives of the
PGPL personnel, employees and contractors.
residents of the geographical areas near the
Emergency response management will be provided project's area of influence.
by a small team of senior managers (the control
n The physical integrity of the Company's
committee) who in turn will direct all response
properties or assets.
activities through the Emergency response unit,
plant security, communications, public relations, n The physical integrity or the lives of the
safety and environmental affairs and material ecological systems located in the
procurement departments. Each of these surroundings of the company's facilities.
departments will have specific responsibilities to The Contingency Plan will be applied in the
perform in the event of an emergency. process area, the natural gas receiving area, LNG
Figure 8.1: Emergency Organization
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storage and dispatch, industrial services and D- Natural Risks

administration in view that they are not located in
Natural risks that may affect the facilities and
the area of influence.
their resulting damage to property and the
A complementary objective is to establish the personnel.
Notification Procedure to be followed between
Company personnel and with Government n Strong earthquake
Entities. n Tsunamis (floods)
B- Risk Situations E- External risks

Due to the characteristics of the project, the Risks arising from delinquent actions, terrorism
contingencies that could arise are the following: or vandalism.
Once received, the gas will undergo the following
processes: compression, LNG storage, re- F- Personnel Transportation Risks
gasification and dispatch for exportation through
All personnel of the Plant must be instructed that
submerged pipeline on board the FSRU vessel
in the event of automobile accidents while the
permanently stationed along the jetty.
personnel is being transported to/from the Plant,
Due to the characteristics of the project, the using own or third-party transportation contracted
contingencies that could arise are the following: by the company, they must immediately notify
the Environment, Health and Safety Environment
C- Internal Risks Department (EHS) so that it will provide the
necessary assistance for the injured, and proceed to
Risks arising from operational conditions or
issue notices not only to the health care centres but
human error that could result in personal
accidents, spills or fires, such as: also to external support institutions (National
Civil Defence, Police, Fire Fighters, etc).
n Uncontrolled gas leak (RLNG, liquefied
natural gas, and propane) into the G- Risk management
atmosphere.
The management of contingencies at the
n Fire / explosions.
natural gas re-gasification LNG import
n Hydrocarbon or by-product spills (gasoline, terminal plant is based on:
diesel).
n Early detection (alarms, detectors, setting
n Chemical product spills off of safety elements);
n Occupational accidents (serious or fatal), due n Immediate automatic reaction (feed shut-
to product contamination, failure to comply off valves, either of the fluid, electric
with operating rules and procedures, process or other).
negligence of the personnel, falls, internal
traffic accidents, burns, acts of God, bad use of n Confinement of emergency area.
equipment and personal protection items.
n Application of the adequate response
n Environmental Contamination (due to gas procedure
leaks into the environment, product spills on
n Follow-up and monitoring
land and in the sea).
n Schedule maintenance
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H- Evacuation Plan Phone No. ____________________________
The following alarm signal(s) will be used to Bay Area Air Quality Management District
begin evacuation of the facility (check all Phone No. ____________________________
which applies):
Regional Water Quality Control Board
n Bells
Phone No. ____________________________
n Horns/Sirens
* These telephone numbers are provided as a
n Verbal (i.e. shouting)
general aid to emergency notification. Be advised
n Other (specify) that additional agencies may be required to be
n Evacuation map is prominently displayed notified.
throughout the facility.
Note: A properly completed Site Plan satisfies iii- Emergency Resources:
contingency plan map requirements. This
Poison Control Centre
drawing (or any other drawing that shows
Phone No. ____________________________
primary and alternate evacuation routes,
emergency exits, and primary and alternate Nearest Hospital: Name: _______________
staging areas) must be prominently posted
Phone No. ____________________________
throughout the facility in locations where it
will be visible to employees and visitors. Address: _____________________________
City: ________________________________
i- Emergency Contacts*:
iv- Arrangements with Emergency
Fire/Police/Ambulance
Responders:
Phone No. ____________________________
If you have made special (i.e. contractual)
State Office of Emergency Services arrangements with any police department, fire
Phone No. ____________________________ department, hospital, contractor, or State or
local emergency response team to coordinate
National Response Centre
emergency services, describe those
Phone No. ____________________________
arrangements on the lines below:
ii- Post-Incident Contacts*:

I- Emergency Procedures:
Fire Department Hazardous Materials Program
i- Emergency Coordinator esponsibilities:
Phone No. ___________________________
(a) Whenever there is an imminent or actual
EPA Department of Toxic Substances Control emergency situation such as an explosion, fire, or
release, the emergency coordinator (or his/her
Phone No. ____________________________
designee when the emergency coordinator is on
Cal-OSHA Division of Occupational Safety and call) shall:
Health n Identify the character, exact source, amount,
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and areal extent of any released hazardous for use.

materials.
n Notify the PQA Fire Department that the
n Assess possible hazards to human health or facility is in compliance with requirements b-
the environment that may result from the i and b-ii, above.
explosion, fire, or release. This assessment
ii- Post-Incident Reporting/Recording:
must consider both direct and indirect effects
(e.g. the effects of any toxic, irritating, or The time, date, and details of any hazardous
asphyxiating gases that are generated, the effects materials incident that requires implementation
of any hazardous surface water run-off from of this plan shall be noted in the facility's
water or chemical agents used to control fire, etc.). operating record.
Within 15 days of any hazardous materials
n Activate internal facility alarms or
emergency incident or threatened hazardous
communications systems, where applicable,
materials emergency incident which triggers
to notify all facility personnel.
implementation of this plan, a written Emergency
n Notify National Disaster Management & Incident Report, including, but not limited to a
Rescue Operations Authority as well as the description of the incident and the facility's response
Environment Protection Agency (EPA) Sindh. to the incident, must be submitted to the Sindh
Environmental Protection Agency's Department of
n Notify the City as well as PQA Fire
Toxic Substances Control, Fire Department
Brigade/Emergency Services
Hazardous Materials Division.
n Monitor for leaks, pressure build-up, gas
The report shall include:
generation, or ruptures in valves, pipes, or
other equipment shut down in response to n Name, address, and telephone number of the
the incident. facility's owner/operator;
n Take all reasonable measures necessary to n Name, address, and telephone number of the
ensure that fires, explosions, and releases do not facility;
occur, recur, or spread to other hazardous
n Date, time, and type of incident (e.g. fire,
materials at the facility.
explosion, etc.);
(b) Before facility operations are resumed in areas
of the facility affected by the incident, the n Name and quantity of material(s) involved;
emergency coordinator shall: n The extent of injuries, if any;
n Provide for proper storage and disposal of n An assessment of actual or potential hazards
recovered waste, contaminated soil or surface to human health or the environment, where
water, or any other material that results from this is applicable;
an explosion, fire, or release at the facility.
n Estimated quantity and disposition of
n Ensure that no material that is incompatible recovered material that resulted from the
with the released material is transferred, stored, incident;
or disposed of in areas of the facility affected by
the incident until cleanup procedures are n Cause (s) of the incident;
completed. n Actions taken in response to the incident;
n Ensure that all emergency equipment is n Administrative or engineering controls
cleaned, fit for its intended use, and available designed to prevent such incidents in the
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future. Chemical Handling Training Procedures
iii- Emergency Equipment: Safe method for handling and storage of

hazardous materials
The Hazardous Materials Storage Ordinance
Location(s) and proper use of fire and spill
requires that emergency equipment at the facility be
control equipment
listed. Completion of the Emergency Equipment
Spill procedures/emergency procedures
Inventory tabel (Table-7.1) meets this requirement.
Proper use of personnel protective equipment
Specific hazard(s) of each chemical to which they
J- Training:
may be exposed, including route of exposure(i.e.
Check all boxes which apply. inhalation, ingestion, absorption)
Hazardous waste Handlers/Managers are trained
i- Personnel in all aspects of hazardous waste management
specific to their job duties (e.g. container time
General workers will be trained as per following
requirements, manifesting requirements, etc.)
procedures:
Emergency Response Training Procedures

ii- Chemical Handlers
Personnel rescue procedures
Chemical Handlers will be annually trained in the
Shutdown of operations
following manner:
Use, maintenance, and replacement of
emergency response equipment
iii- Emergency Response Team
Refresher training which is provided annually
Members are capable of and engaged in the Emergency response drills which are conducted
following: at least quarterly
L- Response levels
K- Emergency response training
Two levels of response must be contemplated:
Develop and practice a spill clean-up procedure
including where to find emergency equipment and n With own personnel
how to use it. Make sure all people on site are
n With external government cooperation, such
aware of emergency telephone numbers to call in
as Civil Defence, Fire Fighters, National
the case of a large spill. Spill kit equipment on site
Police, High Ranking Assistance Centres and
should include: booms to contain liquids, material
the Government Attorney General's Office.
to prevent spills into drains, and material to absorb
spills. Keep this absorbent material in a clearly M- Response Strategy
labeled and easily accessible place.
Upon the occurrence of the emergency, the Plan
will be developed under the following conditions:
Personnel Training Procedures
n First Stage: Notification
Internal alarm/notification
Evacuation/ re-entry procedures & assembly n Second Stage: Initial assistance/rescue
point locations
n Third Stage: Response operations
Emergency incident reporting
External emergency response organization n Fourth Stage: Evaluation of the Plan and
notification damages
Location(s) and contents of Emergency
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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)
i- First Stage: Notification frequencies will be established for the

command post, alternative posts and for the
Internal Communication personnel that forms part of the response Brigade.
Radio communication systems, channels and Furthermore, message forms will be established
to record at least the following information:
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Name of informant, location and place of the emergency must be evacuated to a safe place
emergency, number of people affected and, if where there must be communication equipment
possible, an estimate of the type of injuries available to count the number and condition of
and/or damages, among others. the personnel.
In the event of fire, the execution or fighting
External Communication phase will be implemented immediately.
In the event of spills, leaks or discharges into the
iii- Third stage: Response Operations
sea or the beach, the Harbour Master's Office of
the area of influence must be informed through Response Operations refer to:
the fastest means: telephone and fax; and also
n Fire fighting using extinguishers or pressure
using the forms of the General Harbour Master's
water network or foam.
and Coast Guard Bureau.
n Spill control (of lubricants or fuel using
n Local Authorities will be advised by
absorbing material) or confinement.
telephone.
n Dispersion of gas clouds. Access control to
n In the case of serious or fatal accidents, the
affected area.
Government Attorney General's Office and
the National Police will be notified in n Medical assistance and evacuation of injured
coordination with the Legal Counsel. personnel.
n The relatives of the injured person, as soon as n Evacuation of all personnel if their lives are in
he is evacuated to a hospital. danger (in the event of earthquakes, tsunamis
or other factors).
n To the extent possible, the press will be
notified after the accident has been n Application of a monitoring program and a
investigated and by the person designated by mitigation plan.
Management. a) Response guide. In the future, the
n In the case of an accident that has affected the Contingency/Emergency Plan will apply the
facilities; the Insurance Company will be specific response procedure for each emergency,
notified in Coordination with the which procedure will be described in detail and
Administration and Finance Management. in a language that is easy to understand. It will
form part of the documents to be delivered
ii- Second Stage: initial assistance/ rescue during the induction process and there will be at
A joint evaluation will be made of the status of the least 2 drills per year in order to keep the
event, the conditions of the site, the personnel trained.
environmental characteristics that warrant a safe The communication chain with information on
development of rescue actions, first aid and contacts and notifications must be established
transportation of the injured to a medical unit. and maintained.
Strategies will be adopted to determine own Furthermore, the logistic chain to replace
material and human resources to be required, equipment and consumables must be established,
the deployment of the resources to the emergency determining a minimum stock at the Plant, which
location, as well as the estimated response time. for the case of fire must be in line with the risk
Trained emergency teams must be prepared to act study and the list of suppliers containing the
as required, and a reserve team must be available. contact name, address and telephones available
All personnel who are not essential to fight the on a 24-hour basis the 365 days of the year.
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iv- Fourth Stage: Evaluation of the Plan and occur at the Terminal include:
of damages
n LNG spills that are contained within the LNG
Once response operations have concluded, the spill containment system and do not result in
development and results of the Plan must be fire;
evaluated in order to issue recommendations that
n LNG spills that are contained within the LNG
allow correcting deficiencies for the purpose of
spill containment system and result in a fire
improving response operations. These
within the containment system;
recommendations will then form part of revision
and subsequent annual approval of the Contingency n Overpressure of gas or liquid process piping;
and Risk Prevention Manual.
n Collapse of buildings or systems and
A record of damages will be prepared as part of equipment that does not result in or does not
the final emergency report. The resources used, have the potential to result in the loss of
lost and recovered will be detailed in said containment of LNG or flammable gases;
register.
n Building fires that do not involve flammable
gases;
N- Emergency Response Manuals
n Electrical fires that do not involve flammable
Including the proponent's commitment to
gases;
prepare written emergency plans for the pipeline,
plant and marine terminal to cover emergency n Loss of electrical power;
situations that could occur, based on the results of
n Emergency LNG carrier departure –
a Quantitative Hazard and Risk Assessment. It
unexpected LNG carrier disconnect;
was agreed that Emergency Response Manuals
will be developed for: n Vehicle accidents;
n LNG Plant Accident Response; n Severe weather conditions; and
n Loading Facility and LNG Carrier Accident n Breaches of site security that do not result in
Response; or have the potential to result in substantial
damage to the Terminal.
n Pipeline Rupture Contingency Plan; and
Uncontrollable Emergency: An Uncontrollable
n Platform Emergency Response.
Emergency involves situations that have the
potential to result in exposure of personnel or
O‑ Responses to Emergencies within
property to natural gas in a liquid, cold vapor, or
the Terminal gaseous state or may result in fire or explosion.
Examples of Uncontrollable Emergencies that
i‑ Emergency Classification may occur at the Terminal include:
Determination
n LNG spills that are not contained by the LNG
Controllable Emergency: This is an emergency in spill containment system and do not result in
which the Terminal Operations Personnel can fire;
prevent harm to personnel or equipment by n LNG spills that are not contained by the LNG
taking reasonable and prudent actions such as spill containment system and result in an
valve manipulations, shutting down equipment, unconfined fire;
or initiating the Emergency Shutdown System.
Examples of Controllable Emergencies that may n Flammable gas leaks from significant failure
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of a pipeline or equipment; Emergency: This is an Uncontrollable Emergency

that threatens the public with exposure to natural
n Building or equipment fires that contain or
gas (liquid, cold vapor, or gaseous state) or
have the potential to contain flammable gases
involves a fire or explosion of a magnitude that
n Structural failure of an LNG storage tank; affects persons or property off-site. At the
instruction of the Terminal Emergency Director,
n Major fire aboard an LNG Carrier;
emergency help will be requested by the Public
n Bomb threats; and Information Contact from off-site emergency
organizations during a General Emergency.
n Severe weather conditions that cause wide-
scale damage to equipment and systems that Additionally, the Terminal Emergency Director
result in or have the potential to result in a may recommend an evacuation of the local
loss of containment of LNG or flammable community in accordance with Section 3.3.2 of
gases. this Emergency Response Plan.
n In addition, a Security Breach that results in a

ii‑ Emergency Classification Summary
high probability of substantial damage to the
Terminal that may create an Uncontrollable In summary, there are ultimately three types of
Emergency will be considered an emergencies:
Uncontrollable Emergency, even if no
damage has yet occurred. n Controllable Emergency;
Examples of this situation include: n Uncontrollable Emergency resulting in a

Terminal Site Emergency; or
n Discovery of an explosive device in close
proximity to an LNG tank or major LNG n Uncontrollable Emergency resulting in a
pipeline or natural gas pipeline; and General Emergency.
n An act of sabotage that may result in iii‑ Terminal Alarm System, Hazard
structural failure of an LNG storage tank or Detection and Mitigation System and
rupture of an LNG tank or major LNG
Shutdown System
pipeline or natural gas pipeline.
n An Uncontrollable Emergency is then further The following describes the hazard detection and
classified as a Site Emergency or a General mitigation system that is installed on board and
Emergency. which will be used to alert to and mitigate the
impact from the Controllable Emergency and
Uncontrollable Emergency – Terminal Uncontrollable Emergency situations.
Emergency: This is an Uncontrollable Emergency
that threatens personnel or equipment with Hazard Detection Systems: A Hazard Detection
exposure to natural gas (liquid, cold vapor, or and Mitigation System (HDMS) are installed to
gaseous state) or involves a fire or explosion of a prevent the occurrence of physical situations that
magnitude that involves a large portion of the have the potential to result in injury to personnel
facility. and/or damage to property and the environment.
The HDMS accomplishes this by detecting and
A Security Breach that results in a high alerting operating personnel to the presence of
probability of substantial damage to the Terminal fire and flammable gas leak hazards.
is considered a Terminal Emergency.
The hazard detection system consists of a
Uncontrollable Emergency – General combination of heat detectors, flame detectors,
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smoke detectors, high and low temperature B- HSE Manager

detectors and flammable gas leak detectors.
The role of HSE manager is vital. The success of
Emergency Shutdown Systems: An Emergency an EMP always depends on Proper and effective
Shutdown System (ESD) is installed to initiate management provided by HSE manager.
closure of valves and the shutdown of process Following are some of the roles and
drivers during emergency situations. All other responsibilities given should be provided by HSE
shutdowns that are not ESD are designated as manager:
process related trips.
n To identify issues and where possible
LNG Carriers that arrive at the Terminal have propose solutions for inclusion in the
their own ESD system, which will be connected to management plan review process.
the Terminal ESD system through an umbilical
n To ensure that the points of view of staff,
link, which will be established prior to unloading
LNG. contractor and HSE officers are considered and
placed in the EMP accordingly.
8.3- Responsibilities, training n To improve coordination and exchange of
and communication information between top management,
employees, contractors etc.
8.3.1- Responsibilities n To contribute towards the actions to deliver
The roles and responsibilities of PGPL's Project the management plan and ensure its
Manager, the Engineer, the environmental continual development.
inspection/quality assurance team, the
n To review EMP every year under the
contractors, all EMP holders and all personnel
supervision of top management, taking issues
will be defined in this section. An organizational
and change EMP accordingly with the
chart of the LNG Terminal Project Environmental
solutions and suggestions.
Management Roles and Responsibilities will be
included in this section. n To monitor the progress, development and
implementation of this management plan.
A- General Manager (Operations)
C- HSE Officer
Environmental management plan will be
regulated by the General Manager (Operations) of The role of HSE manager will be empowered by
PGPL. Some of the key role and responsibilities HSE manager. The superficial responsibilities
are described below: which an HSE officer will have to perform
include:
n To consider and react to issues and solutions
proposed by the HSE department. n To integrate, as far as possible, the aims and
objectives of different users within an agreed
n To cooperate and consult with relevant plan.
environmental agency in order to perform in
better way. n To maintain balanced, holistic approach to
the solution of concerned issues in
n To approve any change in decision making accordance with the compliance to the
and authorities in consultation with Manager legislative requirements.
HSE, if appropriate.
n To provide professional guidance on
questions relating to the environmental
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Chapter 8
management and issues raised by activities are scheduled in all requiring

contractors/relevant personals. monitors.
n To progress the EMP process through n The EI will play a significant role suggesting
development towards implementation. methods to bring construction activity into
compliance and/or to temporarily halt
D- Construction Contractor certain activities that may cause damage to
sensitive environmental resources.
On behalf of chief construction contractor, the main
responsibilities for all matters pertaining to n In addition to these responsibilities, the
environment will be looked after by field environmental inspector contributes to the
Construction Contractor and he will be responsible Environmental Management Team by
to report directly to HSE Manager. Major roles to be developing swift and innovative solutions to
performed by construction contractor are given unanticipated environmental issues which
below: develop during construction.
n To carry out construction activates in
F- Site (Operation) Manager
environmentally sound manner.
n To coordination with the HSE officer to n The site manager is responsible and
resolve issues arise during construction accountable for the site's HSE performance.
phase. n Establishes, implements, and maintains a
n To manage construction crew and reduce the formal written plant-HSE program that
environmental impacts. encompasses applicable areas of loss
prevention and is consistent with corporate
n To appoint a dedicated environment officers policy.
that will understand and tackle
environmental issues more easily. n Establishes controls to assure uniform
department performance to the HSE
n To discuss weekly progress report with HSE management system. The establishment of
Manager and issues concerned to controls should include corrective action and
environmental management. follow-up. Develops, by action and example, a
positive HSE culture and a clear understanding
E- Environmental Inspector
of specific responsibilities for direct reports.
n An Environmental Inspector (EI) is n Approves and adopts local HSE policies,
responsible to supervise the environmental rules and procedures.
compliance and inspection process.
n Chairs the Executive HSE Committee (or its
n Environmental inspector is also responsible equivalent).
to communicate with Environmental
manager and the chief constructions officers. n Personally investigates fatalities, serious Lost
Workday cases, environmental incidents or
n Environmental inspector provide key liaison major property losses.
role in coordinating attendees and facilitating
agreements in the field, as appropriate, with n Assigns management members to serve on
agency representatives. various HSE committees.
n Coordinate daily with construction n Reviews monthly HSE activity report and
inspectors, the contractor, when construction performance statistics.
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n Reviews Lost Workday Injury/Illness once per month; submits written report with
Investigation Reports. assignments and deadlines for correction.
n Reviews loss-control reports submitted by n Authorizes purchases of tools and equipment

outside agencies. to comply with plant specifications and
governmental regulations as required.
n Makes plant-HSE audits on a regular basis in
order to appraise program effectiveness and n Develops an indoctrination plan, which
to correct and reinforce behavior. includes specific job instruction, for new or
transferred employees; issues protective
n Reviews annually the program effectiveness
equipment and follow-up checks by
and makes adjustments where necessary.
supervisor/foreman/lead persons.
n Evaluates the functional performance of the
n Reviews the HSE performance of his area of
HSE staff and provides guidance training
responsibility.
where necessary.
n Personally investigates all "Lost Workday"
n Personally reviews, signs, and approves of
cases and significant losses and reports to
corrective action planned for Lost Workday
plant manager. Follows-up on corrective
cases.
action.
G- Department Manager (Department Head; n Adopts standards for assigning protective

Area Superintendent) equipment to employees; insists upon strict
enforcement; and makes spot field checks to
n Contacts each supervisor/foreman/lead determine compliance. Also reinforces safe
person frequently (daily) on HSE. behavior.
n Includes HSE as a meeting topic in staff n Evaluates supervisor/foreman/lead persons'
meetings. HSE performance.
n Makes daily observations of n Develops strong HSE culture and a clear-cut
supervisor/foreman/lead person's HSE understanding of specific duties and
activities. responsibilities in each member of
management.
n Reviews and approves all job procedures
growing out of Job Safety Analysis; installs
H- Supervisor/Foreman/Lead Person
approved procedures; requires direct reports
to check on use of procedures. n Makes daily safety observations of the work
n Approves all departmental HSE rules and area and corrects unsafe behavior and
regulations and reviews annually; maintains reinforces safe behavior.
strict enforcement; and develops plan to n Arranges for development of job safety
ensure employee instruction and re- analysis; reviews all job safety analysis; and
instruction. submits to department manager for approval.
n Establishes acceptable housekeeping n Develops a workable housekeeping program,
standards, defining areas of responsibility; defining areas assigned to work teams; makes
assigns areas to supervisor/foreman/lead daily spot checks of an assigned work area;
persons; makes daily spot check of some area; makes periodic housekeeping inspections,
holds formal inspection with reporting results of inspection to department
supervisor/foreman/lead persons at least
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manager and indicating condition and employee's apparent physical limitations to

corrective action. department manager.
n Ensures the indoctrination of new or n Enforces wearing of protective equipment;

transferred employees. makes spot checks to determine that
protective apparel is being used; and makes
n Develops protective apparel requirements,
periodic checks to appraise condition of
according to occupation; and makes spot
equipment.
fields checks to determine compliance.
n Sees to it, in case of serious injury, that injured
n Reports all injuries or illnesses of employees
employee receives prompt medical attention;
to department manager as soon as practical;
isolates area or shuts down equipment, as
reviews Accident Report with employees
necessary; and immediately reports to the
and, in case of injury, submits reports to
department manager the facts regarding
department manager after taking corrective
employee's accident or illness and the action
action.
taken. In serious incident cases, the
n Makes thorough investigation of all accidents supervisor/foreman/lead person determines
and serious incidents occurring to employees cause, takes immediate steps to correct
in assigned work area; makes personal condition, and isolates area and/or shuts
inspection; and develops preliminary down equipment, as necessary.
information. Supervisor/foreman/lead person
immediately reports facts and action taken to
n Conducts scheduled and assigned HSE
the department manager.
training meetings.
n Checks changes in operating practices,
n Participates on HSE committees as specified
procedures and conditions at the start of each
by plant policy.
shift and before relieving the "on-duty"
n Reviews unsafe conditions and unsafe supervisor/foreman/lead person, noting
behavior and directs daily HSE activities to facts related to HSE which have occurred
correct these causes. since his last working period.
n Instructs employees in HSE rules and n Makes, at the start of each shift, an immediate
regulations; records instruction; and enforces check to determine absentees. If plant injury
all HSE rules and regulations at all times. is claimed, an immediate investigation is
instituted and department manager notified.
n Makes daily inspections of assigned work
area and takes immediate steps to correct n Makes daily spot checks and takes the
unsafe or unsatisfactory conditions; reports necessary corrective action regarding
to department manager those conditions housekeeping; spills and storage of hazardous
which cannot be immediately corrected; waste & materials; unsafe behavior or
instructs employees on housekeeping practices; unsafe conditions, tools, ladders,
standards. wire rope, chains, clevises, pins, spreaders,
etc.; job procedures, and adherence to HSE
n Instructs each new employee personally on
rules.
job HSE requirements in assigned work areas.
n Instructs personally or provides on-the-job
n Enforces the plant's medical department
instruction in HSE and efficient performance
recommendations with respect to an
of assigned jobs.
employee's physical limitations; reports an
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n Takes action on all employee HSE complaints n Consult with the Manufacturing Engineering
and suggestions. department on original plans; see that all plans
and specifications for new or proposed
n Maintains HSE signs and bulletin boards in a
changes in processes, equipment or methods
clean and legible condition, in assigned area.
are reviewed from compliance with HSE
standards before being accepted.
I- HSE Supervisor/Manager
n Function as liaison with insurance
n Provide overall coordination and guidance to companies, Corporate HSE, local fire and
the site HSE efforts. rescue organizations, etc.
n Develop programs that are designed to n Provides leadership to the site for the
reduce exposure to loss via personal injury or implementation of new technologies such as
illness, loss by fire, loss due to spill of behavioral-based safety management
hazardous materials or waste, and comply concepts.
with governmental regulations.
n Reinforces safe behavior and corrects unsafe
n Supervise and coordinate the efforts of the behavior.
HSE department staff.
J-HSE Coordinator
n Collaborate on a routine basis with the site
manager in appraising the performance of all n Assist the site manager in coordinating all
departments. HSE activities.
n Develop recommendations for improvement n Reinforces behavior and corrects unsafe

of procedures, practices and activities behavior.
directly or indirectly involved in effective
n Be constantly alert for unsafe conditions and
execution of HSE functions by site
bring such conditions to the attention of the
management.
supervisor and, if necessary, the site manager,
n Advise and/or represent site management in without delay.
all matters concerning compliance with
n Participates on the site's Executive HSE
federal and state HSE regulations.
Committee.
n Audit the site from a regulatory and
n Accompany outside inspectors representing
management system perspective and
insurance carriers of fire, casualty, and
recommend actions to address deficiencies.
workers' compensation insurance.
n Maintain membership in necessary outside
n See that HSE promotional and reference
HSE organizations.
literature, such as monthly handouts, are
n Participate in the review of all serious available.
incidents, fatalities, and major disasters.
n Be thoroughly familiar with company HSE
n Collaborate with the site manager in the standards and assist the site manager in
development and preparation of Executive implementing them.
HSE Committee Meeting agenda.
n Maintain injury and incident statistics.
n Serve as a member of site committees for
n Assist the site manager in analyzing incident
special HSE studies and program
records, develop supervisory and employee
development.
educational programs and stimulate a high
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GENERAL ORGANIZATION FOR ENVIRONMENTAL MANAGEMENT
level of interest in HSE through various be recognized as one of guidance not

employee-involvement activities. enforcement
n Understand current Federal and state HSE

K- Personnel Safety Supervisor
regulations.
Every supervisor has at least three responsibilities
n Serves as the liaison between Corporate HSE
with which Environmental Safety can provide
and the site.
assistance. These responsibilities are employee
n Provides leadership to the site for the training, provision of personal protective
implementation of new technologies such as equipment and accident & injury reporting.
behavioral-based safety management
concepts. i- Employee Training
Supervisors are responsible for ensuring that each
n Regardless of the position the HSE
new employee, whether temporary or permanent,
Coordinator holds in the plant organization,
receives appropriate safety training at the start of
his function as HSE Coordinator must be only
employment. Supervisors are responsible for
advisory. Any corrective actions must be taken
ensuring that their employees receive the
by the concerned line supervisor. It is most
necessary safety training based on the work that
important that the HSE Coordinator's position
their employees perform.
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ii- Personal Protective Equipment incident-free workplace by:
OSHA requires each supervisor assess the hazards n Considering the consequences of their acts on
of the work area to determine the type of their safety and that of fellow employees.
protective equipment needed and to provide
n Following all general and job related HSE
training on its use. This review must be
work procedures and practices.
documented. Completing the Hazard Assessment
Form meets this documentation requirement. The n Detecting, reporting and correcting unsafe
Personal Protective Equipment Plan includes work behavior or conditions.
detailed information to assist in selecting the
n Applying HSE work practices both on and off
proper protective equipment.
the job.
iii- Accident and Injury Reporting n Making or suggesting enhancement to the
It is the supervisor's responsibility to report all jobs at hand to reduce or eliminate the risk or
accidents or injuries that occur to their employees stresses associated with job performance.
while at work. Each supervisor must ensure that any
n Reinforcing safe behavior.
employee who is injured while at work completes and
signs the Employee's Report of Work-Related Injury n Working safely and with regard for the
Form. Additionally, the supervisor must receive the environment is a condition of employment
employee form, Accident Witness Statement Form (if and no employee should ever consciously
the accident was witnessed by another person), and fill perform an unsafe act.
out a corresponding Supervisor's Report of Work-
Related Injury Form.
8.3.2- Training
L- Public Relation (PR) Manager It's an important step for the implementation of
the EMP. All the employees will require to be
The Public Relations (PR) Manager will have trained to work appropriately on EMP. Training
responsibility for managing client's corporate coordinator will organize trainings in
public relations efforts, reporting to the Vice consultation with HSE Officer. It will make sure
President of Corporate Communications. The that employees understand the issues associated
Public Manager will develop and execute an with the proposed activities. Trainings should be
integrated public relations plan based on arranged on regular basis with notification that it
marketing strategy and reflecting the individual should be attended all respective employees.
divisional (service line) public relations objectives.
The role requires careful cross company HSE Officer will determine the training
collaboration and will necessitate both strategic requirements during both construction and
leadership and practical execution. This is a operation phases. Induction will be the basis of all
corporate role with broad responsibility for training courses for contractor and subcontractor
managing both corporate and product PR during construction phase.
programs, also responsible for collaborating with
Trainings identified in EMP are given below:
and advising international public relation Public
Relation PR teams/agencies. n Site induction course
n Training for emergency response and

M- Individual Employees
preparedness
n Employees must assume a high level of n Training for familiarization with site
responsibility to work safely and strive for an environmental controls
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n Specific environmental training for relevant n Unloading operations must be immediately

employees e.g. installing erosion and halted in coordination with the Ship.
sedimentation controls, daily checks to
n Every possible ignition source in the area
maintain controls, cleaning up pills, waste
must be eliminated.
minimization.
n If a spill occurs on the wharf, the plan
The Plant and Terminal will have (i) Distributed
must be always activated because there is a
Control System to monitor and control the plant
possibility that the product might spill into
process and operation, (ii) Fire and gas
the water, or there may be other situations
detection and alarm system, and (iii) an that could jeopardize other facilities within
emergency shut off system. Each of these the Terminal.
systems will be separated from each other, to
n Containment equipment must be readily
provide data and communication transmission.
available to contain as much as possible the spill
A permanent fire fighting system will be of the product onto the wharf or adjacent areas.
installed, which shall include fire fighting
water, foam generators and CO2 extinguishers. b) Procedure to respond to a spill on the
The personnel will be trained in the use and ground
operation of said systems.
n The area must be isolated and unauthorized
Equipment such as fire trucks, fire fighting
people should not be allowed to enter the
equipment, medical hospital equipment,
spill site.
ambulances and environmental protection and
spill control equipment will also be provided so n Every possible effort should be made to stop
that they will be available in the event of an the spill, if at all possible, without running
emergency. any major risks.
The aim is to instruct all personnel on the n Every possible effort should be made to
operation of this equipment and on the procedure contain the spill and thus prevent the spill
to be followed in the event of spills, fire or from spreading on the ground. In this case,
explosions. makeshift dams will be constructed or
containment booms will be installed, if
A- Personnel training possible.
Both the personnel in charge of unloading n For large spills, every possible effort should
operations at the LNG jetty terminal and on shore be made to contain the spill with makeshift
LPG terminal, as well as the Terminal personnel, dams or fences, or with absorbent material or
are conveniently trained to carry out their work containment booms, in order to then be
and respond to any emergency. collected.
i- Identification of training requirements n Flammable substances that could explode or

catch fire, located in areas surrounding the
a) Procedure to respond to a spill in the spill, should be taken out of the area.
wharf n Basic fire-fighting procedures.
n Any spill that takes place in the wharf area, n Three basic procedures should be borne in
originating from a Ship or from connection hoses, mind in fighting a fire.
will be immediately reported to the Safety Area.
n Fuel should stop being supplied (valves
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should be closed, transfers should stop, etc.). (methane).

n Air should not come into contact with the To respond to a seepage involving a flammable
fuel; therefore, the fire area should be covered product, the following steps should be taken:
with foam.
n Isolate the area.
n The heat produced by the evaporation of the
product should be eliminated, because n Eliminate every source of ignition in the area.
vapour is combustible, and water is the most n Use duly grounded armoured equipment in
effective agent for this purpose. the Hot Area.
n To control any fire at the Terminal, the first n Try to seal the seepage, if it is possible to do
step will be to isolate and evacuate the area, it in a safe manner.
besides taking the following precautions:
n Try to contain the product to prevent it from
n Remove all containers from the area exposed
filtering into drainage networks or other
to fire and heat, if it is possible to do it in a
places.
safe manner.
n Monitor flammability indices in the risk area
n Cool the sides of the containers that are
to analyze the need to isolate a broader area.
exposed to the flames or heat, using water.
n Remove the product with absorbent
n If the fire is intense in the loading areas,
material or other mechanical means in order
support-mounted hoses operated at a distance
for wastes to be properly disposed of.
or monitor guns should be used.
c) Procedures to respond to a fire on the e) Procedures for toxic substances

ship In situations involving the seepage of liquid
substances classified as toxic, the most important
n If a fire breaks out on a ship, then, besides the
thing to do is to wear appropriate breathing
basic fire fighting procedures, the following
equipment.
steps will be taken:
If there is any doubt regarding the concentration
n If the fire breaks out next to the mooring
of the substance in the environment, breathing
wharf, loading operations must be
equipment that affords the highest possible
interrupted immediately and the ship must
protection will be worn, that is, self-contained
get ready to weigh anchor.
compressed-air breathing masks and appropriate
n If the fire breaks out aboard the ship, then the clothing.
captain and the crewmembers should give
In addition, the following steps will be taken:
immediate notice thereof to the technical
personnel working at the Terminal for the n Isolate and evacuate the area that poses a
latter to halt all operations. danger immediately.
n Crewmembers must identify the type of fire n Try to seal the seepage, if it is possible to do
in order for the personnel working at the it in a safe manner.
Terminal to mobilize the appropriate internal
n Try to contain the product to prevent it from
or external resources required to promptly
filtering into drainage networks or other
respond to the incident.
places.
d) Procedures for flammable substances n Permanently monitor the concentration of
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vapors in the risk area to analyze the need to shutdowns.

isolate a broader area.
n All intake and discharge valves in the sea
n Remove the product with absorbent material should be closed.
or other mechanical means in order for
n Blind flanges should be connected to all
wastes to be properly disposed of
valves that are not going to be used.
Decontaminate all clothing, equipment,
materials and areas reached by the product. n High-capacity drip trays should be placed
In addition to the above training, workers below pipe connections.
should be aware of the following:
n Flexible pipes and loading arms should be in
ii- Operations involving oily substances a good condition, properly connected, and
correctly supported.
a) Person in charge
n There should be sufficient and readily
The person in charge of the plant will personally available absorbent material in place.
supervise all operations involving oily
n The valve in the tank where the product is to
substances. Said person will closely cooperate
be loaded should be open and duly aligned.
with and remain in close contact with the person
in charge of the loading of oily substances in the b) While loading Hydrocarbons
vessel and with the wharf personnel.
n There should be no leaks in flexible pipes or
b) During loading operations pipe connections.
Loading will begin at the minimum pumping rate, n The reduction in the pumping rate during the
in order to be able to quickly stop the supply if last phase of loading operations should be
there is any problem. The pressure of supply pipes reported well in advance.
will be checked to make sure that the maximum
n Proper notice should also be given when
working pressure is not being exceeded. The
loading operations are intended to be
hydrocarbon supply tank will be frequently
brought to a full halt.
measured.
n Sufficient room should be left in the tanks in
Upon completion of loading operations upon
order to be able to drain flexible pipes and the
completion of loading operations, and once all
entire pipeline system used in the respective
flexible pipes have been drained, a drip tray will be
loading operations.
left below the flexible pipe connections, when
loading hydrocarbons. Flanges will then be c) Upon completion of loading operations,
disconnected and a blind flange will be installed check whether:
on one end of the hose.
n Distribution valves have been closed.
iii- Check list
n Flexible pipes and loading arms have been
a) Before loading Hydrocarbons drained before being disconnected.
n Blind flanges have been installed in the

n There should be a clear signalling system in
aforesaid pipes.
place to report the commencement of loading
operations, reduction in the loading rate, the n The valves in the loading system have been
end of loading operations, and emergency closed, including intakes in the hydrocarbon
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Chapter 8
supply tank. issues that require attention of higher

management of PGPL will be communicated to
iv- Training schedule
them for action. The HSE officer and the
As part of its policy, emergency drills will be contractor will also prepare a weekly
carried out at least twice a year, which will allow environmental report. Duplicates of the report
the personnel to carry out and learn the actions will be provided to the higher managements of
they must take and the attitude they must have in PGPL and of the contractor. Communication
the face of real emergency situation will play a vital role in good management
During training, consideration of following areas practices. Steps given below will assist in
of knowledge and experience are essential: effective communication and documentation.
n Appreciation of properties of hazardous substances A- Kick-off Meeting

e.g., toxic, flammable, reactive etc, as well as, levels
at which they pose a considerable menace requiring The aim of organising the kick-off meeting is to
protective measures. define the environmental responsibilities,
awareness to EMP to the managing staff and to
n Knowledge of early-warning indicators, streamline the work plan according to the EMP.
hazard/risk identification and ability to recognise This meeting will be arranged prior to
potentially hazardous situations. commencement of activities.
n Acquaintance with engineering control to evade the
incidence of hazardous situations. B- Quarterly Meetings
n Familiarity with capability and restraints of facility Initially quarterly meetings will be held after kick-off
to respond the hazardous emergencies, ventilating meeting however if situation demands for monthly
systems, plumbing systems, shut off systems, meetings, it will be rearranged accordingly. Aim of
containment strategies and emergency response this meeting is to review the progress of activities
measures. performed, explore ideas and problems, and discuss
about the progress in acquisition and analysis of
n Awareness of use, repair/ maintenance of
information. Dead lines are re-evaluated in it and if
emergency response equipments as well as
necessary, the project program is revised in these
routine equipments to health and safety
meetings.
monitoring and protection.
n Awareness of methods and trials for C- Peer Review

decontamination personnel equipments and facility
following potential chemical contaminations. The aim of this review is to predict and modify the
conclusions and interpretation of assessment phases
8.3.3- Communications in the light of other professional opinions that
mainly not involved in the proposed project, but
For effective monitoring, management and just for the provision of a critical appraisal of the
documentation of the environmental style and expression of documentation produced.
performance during the operation, the Health,
Safety and Environmental (HSE) matters will be D- Minutes of Meetings
discussed during daily meetings held on site.
Environmental concerns raised during the In the end of quarterly meetings, minutes will be
meetings will be mitigated after discussions issued which comprises of the discussion made in the
between the HSE officer and the contractor. Any meeting, issues discussed and decisions taken with the
time frame for their implementation. Main points of
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Chapter 8
minutes for general employees may be incorporated in required periodic reporting of the monitoring results in
the record register. These meeting minutes will also be form of report submitted to the Environmental
provided to the higher authorities of PGPL and the Protection Agency. During the construction phase, it
contractor for their own record. will be on bimonthly basis and during the operation
phase it will be done on quarterly basis.
8.4-Regulatory requirements It is also understood that monitoring shall be done by
an independent consultant/ organisation. It would be
8.4.1- Approvals, authorisations further required to make the annual environmental
and permits report public as laid under the Equator Principles.
The list of potential approvals, authorizations and Equator Principles (EP) requirements were taken care
permits required for the Project from various off in this EIA report and it is one of the mandatory
agencies including, federal, provincial, municipal requirement of EP to report all the stakeholders and
are given below: announces their EHS performance publically atleast
once a year.
n Sindh Environment Protection Agency, for
which this document would be submitted for
grant of permission and approval of the
8.5- Standard Operating
project.
Procedures
n Port Qasim Authority 8.5.1- Barge and supply ship
n Maritime Security Agency operations
n Sanction of utilities from concern department
A- Purpose
such as KESC, SSGC, KW&SB, PTCL and other
civic agencies including City District Government n To achieve the desired productivity.
of Karachi, etc.
n To delineate the method for handling of cargo
8.4.2- Environmental quality from and to vessel efficiently, effectively and
objectives safely.
This section will outline criteria for management's B- Scope

quality objectives related to generation of solid
waste and wastewater quality, air and noise This procedure applies to all vessels calling the
quality. The management of PGPL shall make terminal.
Environmental Objectives every year and try to
complete them in the stipulated time frame. C- Definitions
This will also include any applicable treatment A barge is a flat-bottomed boat, built mainly for river
criteria meeting the National Environmental and canal transport of heavy goods. Most barges are
Quality Standards (NEQS) as per Pakistan not self-propelled and need to be moved by tugboats
Environment Protection Act 1997. towing or towboats pushing them.
8.4.3- Compliance monitoring D- Procedure
It would be required by the management of PGPL to i- Information Required

comply with the Environmental Monitoring Plan laid
in the subsequent section. The compliance shall also Shipping efficiency is highly dependent upon the
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quality and timing of information made available worked. These planned ship-working programs
to the Terminal Planning Section. This section is will have taken into account:
responsible for, amongst other activities,
n Vessel stability requirements
preparing quay crane utilization plans and
container discharge and load sequences. n Disposition of cargo to be discharged from
Information sources are: the vessel
a- Shipping Line: responsible for providing n The yard stacking disposition of cargo to be
inward bay plan information, container status loaded to the vessel
lists, reefer container information, dangerous n Resource availability by way of cargo
cargo declarations and any particular information handling equipment and manpower
which may be useful in ensuring smooth
operations. For planning purposes this n Conditions of contract with the client.
information should be available to the terminal at
iii- Ship Working Systems
least 24 hrs prior to vessels arrival with updates
from the last port of call at least 12 hours prior to Ship working systems at a terminal may feature a
vessel arrival. Communications should be number of methodologies. The two most
through fax or emails. commonly used are shown below:
b- Shipping Line Agents: responsible for An ECH system whereby containers are moved
providing details of containers to be received for between the quay gantry cranes and container
export. For planning purposes initial indicative yard stack using internal transfer vehicles. ECH
information should be made available to the terminal are used for yard stacking.
seven days prior to vessel arrival with general
indications of containers to be handled by size, port of 8.5.2- Watercourse crossings
discharge, weight classification, commodity
classification, reefers, dangerous cargo etc. The initial A-Purpose
information is to be regularly updated as more specific
The main purpose of watercourse crossing is not
information becomes available. Communications with
to disturb the sea water flow in the nearby
the terminal may be either using fax or emails.
channels. Care must be taken to ensure that jetty
n The Operations Superintendent: is responsible for construction, laying of pipeline and LPG
ensuring the best information is available extraction area do not cause erosion or have a
concerning availability of cargo handling negative effect on aquatic habitat. Fish passage
equipment and manpower availability (by driver should not be obstructed as a result of
skills); and watercourse crossing installations.
n The Terminal Yard Planner: is responsible for

B- Scope
managing and providing and monitoring yard
area allocations for the optimum utilization of the The scope of watercourse crossing is to construct
cargo space at time of receiving at the terminal. watercourse crossing and to ensure minimization
of harmful effects of watercourse crossings on the
ii- Planning for Operations
aquatic environment.
In all cases the start position for operations occurs
when, through the Vessel Planner, the SPARCS C- Definitions
system generates off-loading working programs
It is natural or artificial channel through which
and sequence sheets for storage facility to be
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water flows. n Sustainable management of water
n Water is a vital component of the

D- Procedure
environment.
i- Construction of Watercourse Crossings n Water plays an essential role in a prosperous

The location of all watercourse crossings is to be economy and balanced economic
inspected and approved prior to construction. development.
The chosen location of the watercourse crossing n Water must be managed using an integrated
should: approach with other natural resources.
n Cross watercourses at right angles; n Water must be managed in consultation with

the public.
n Select crossing points which:
n Water must be managed and conserved in a
n Are immediately downstream of straight and
fair and efficient manner.
stable watercourse sections;
The Code of Practice establishes the objectives,
n Have easy high bank access; standards and conditions to be met when
n Do not require deep box cuts; undertaking the activity of constructing
watercourse crossing.
n Require minimum alteration or disturbance
to the high bank;
8.5.3- Wastewater/ storm water
n Have stable beds. management
A series of monitoring studies were undertaken
to evaluate the effectiveness of the applied A- Purpose of Wastewater/storm water
crossing techniques, to limit sediment release Management
into the watercourse and subsequent changes to
The purpose of the adopted procedure is to
habitat conditions during, and after in-stream
provide guidelines and simplify the process of
construction.
categorizing, quantifying, managing, and
disposing of wastewater wherever and whenever
E- Watercourse Crossings Management
arising during the project's construction and
Options operation phase. Wastewater management is a
Full compliance to all legislation protecting aquatic critical component of company's operating
habitat is ensured. All necessary permits and policies. Wastewater management includes the
proper disposal / recycling and reuse of the
approvals will be obtained before any in-stream
wastewater generated during construction and
work is initiated.
operation phase. The procedure is designed to
The potential harmful effects of watercourse assist in a company's wide effort to provide
crossings activity within a water body can be protection for the environment and to comply with
eliminated or minimized by identifying the company's corporate requirement, environmental
objectives that are to be met when such an activity laws and regulations regarding proper wastewater
is undertaken. Objectives set out in the Code of management.
Practice are based on the principles of sustainable
water management. B- Scope
These principles are: Wastewater as part of drilling and construction,
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production shall be managed as per this (iii) Non-hazardous Waste:

procedure. An integrated wastewater
The wastes are categorized as non-hazardous
management system for the LNG jetty and
wastes, if they do not possess any of the
storage terminal is essential to reduce
hazardous contaminant mainly comprising of
wastewater.
consumed water arising from washing area and
Substitute techniques must be investigated, sanitary wastewater.
including source reduction, recycling and reuse
wherever possible with a view towards D- Procedure
maximizing the benefits and minimizing the cost
Main concern to manage the wastewater is listed
of each method of wastewater management.
below:
Guidelines for proper handling, categorization,
recording, minimization, and disposal of all types n Eliminate wastewater production wherever
of wastewater associated with company possible.
operations and projects are part of this procedure
n Minimize wastewater production.
that need to be documented.
n Recycle or Reuse
This procedure shall be followed at all construction
sites by all company personnel and contractors n Wastewater disposal in an environmentally
working for this proposed project. safe manner through adequately designed
facility
C- Definitions i- Wastewater Minimization
(i) Wastewater Generation of wastewater will be minimized
through the following steps taken by working
Any water arising after use/ consumption shall
personnel at the facility:
be including of liquid waste discharged by
domestic residences, commercial properties, n Through efficient use of raw water
industry, and/or agriculture and can encompass (minimizing the wastewater).
a wide range of potential contaminants and
n Extensive management schemes will be
concentrations. In the most general terms, it
formulated for both phases during
refers to the municipal wastewater that contains
construction and operations (water
a wider range of pollutants arising due to the
management).
mixing of wastewaters from different sources.
n It is expected that segregated and /or treated
(ii) Hazardous Wastewater wastewater will be made available for
Plant wastewater comes in the category of subsequent use during operations phase
(recycling and reuse).
hazardous wastewater. If it has one or more
of the following properties: ii- Storage and Handling
n Oily water Wastewater shall be stored / retained in lined
ponds or storage tanks till proper onsite
n Toxicity (may cause risk of injury to health of
treatment or remote disposal.
organisms or the environment)
n Concentration of contaminants too high

iii- Recycling
above safe acceptable limits Reuse of wastewater is a best way to reduce the
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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 Wastewater
Description 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.
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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 rock plugging with gel slugs to block off water
production in completions where there is a separation of
the oil and water zones
n Dually complete the oil zone and water zone to allow
water to be produced simultaneously but separately from
oil and allow control of water coning
n Carefully plan completions of bored well
n Re-perforate / re-inject wells to reduce water
production
n Drill wells to minimize water production
n Optimize production rate to minimize influx of water
Disposal Options n Inject produced water into disposal or injection wells
n Reuse produced water whenever possible
n Use produced water for hydro-testing pipelines,
equipment, tanks, well killing and or drilling mud
preparation
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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 rock plugging with gel slugs to block off water
production in completions where there is a separation of
the oil and water zones
n Dually complete the oil zone and water zone to allow
water to be produced simultaneously but separately from
oil and allow control of water coning
n Carefully plan completions of bored well
n Re-perforate / re-inject wells to reduce water
production
n Drill wells to minimize water production
n Optimize production rate to minimize influx of water
Disposal Options n Inject produced water into disposal or injection wells
n Reuse produced water whenever possible
n Use produced water for hydro-testing pipelines,
equipment, tanks, well killing and or drilling mud
preparation
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quantity of the wastewater that requires n Direct discharge will only be considered as a
subsequent treatment and disposal. contingency option.
iv- Treatment n During preparation of the final EMP, PGPL

will undertake an evaluation of the proposed
n Biological treatment of wastewater through release of hydro-test water during construction
retention in septic tanks prior to disposal of the storage tanks for LNG and condensate
on-site. This will include an analysis of the
n Sludge produced as a by-product of biological
additives which will be present, their fate and
treatment be disposed off properly through
anticipated environmental effects
burial pits
n Some of the wastewater will be reused for F- Recording & Reporting

cleaning or washing purpose. The treated
Visually acquired wastewater management-related
water should comply with National
monitoring data will be recorded in field logbooks.
Environmental Quality Standards (NEQS).
These logbooks will be maintained as part of the
v- Disposal Construction Spread Wastewater Management
Records at each designated area or facility within a
Proper disposal should be done following the
spread, wherever the stated wastewater
treatment through discharge into water bodies or
management activities occur.
sewerage system where available.
These monitoring data will include as applicable.
E- Waste Management Options
n Time, date and identify of individual
n All storm water run-off and pump-out from performing the monitoring activity.
facility construction-sites will be inspected and
n Description of the process or activity being
directed to sedimentation basins to remove
monitored.
suspended solids (e.g., silt);
n Findings or results of the monitoring activity.
n Sewage will be collected and temporarily
stored in tank(s) until it is transported to a n Description of activities to address deficiencies
designated wastewater treatment facility; or problems; and
n Standard mobile sewage tankers should be n Problems / Deficiencies, Remedial Measures.

engaged to collect and transport sewage from
n It is responsibility of the management to
portable latrines and temporary storage tanks
identify and implement appropriate remedial
n Oil spills in port waters could result from a measures based on identified problems /
variety of sources including on-shore industries; deficiencies and to properly record and verify
unsupervised bilge pump-outs; collisions and all EMP compliance initiatives.
sinking of vessels; illegal discharges from
vessels; accidents when transferring waste oil to 8.5.4- Hydrostatic testing
storage facilities on shore and accidents when
refueling vessels. A- Purpose of Hydrostatic Testing
n To reduce the risk of oil spills occurring from a The objective of performing hydrostatic testing of
vessel, Maritime Safety Regulations ensure the a pipeline is to check and eliminate any defect
safety of navigation, including the provision of that might be potential threat for leaks and
navigation aids is maintained. bursting of pipeline when sustaining maximum
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operating pressures or sometimes accidental rise n The water inside the pipeline is pumped up to
in pressure above normal. The key word is a pressure much higher than the normal
pressure which is regulated and when hydrostatic operating procedure of the pipeline (i.e.
testing is performed through raising the pressure transporting petroleum while in full operation).
level above the operating pressure to check for This high pressure is typically held for at least 8
any defects in the joining and failure of material hours.
due to excessive pressures above the normal
n During this test, which will likely occur
operating pressures. If failure occurs then defects
during the late evening and early morning
are eliminated or in case of no failure a safe
hours,
margin of pressure above the operating pressure
is demonstrated. Defects adversely affect the n In the event of sudden leak of water from the
pressure-carrying capacity because excessive pipeline, the pressure will be reduced rapidly
stress in the material leads to failure. and the green water should be raised to the
surface quickly.
B- Scope n In the event of small leak of water from the
Primary focus during any pipeline activity, pipeline; the pressure will be reduced slowly
including hydrostatic testing, is public safety and and the green water may not immediately
protecting the environment. Also it ensures that reach the surface. To locate the leak, excavate
the material or substance being transferred from the pipeline at determined locations for
one point to another location is conserved and further investigation and testing.
does not occur as waste from the system. n In the event that defect in the pipeline is
identified, repair will be made as soon as
C- Definitions possible and the testing will continue until
Hydrostatic Leak Testing is used to test the pressure remains intact for at least 8
components for leaks by pressurizing them inside hours.
with a liquid. This testing method can be used on n The pipeline will be refilled with the gas
piping, tanks, valves and containers with welded products and the distribution service to the
or fitted sections. area will be resumed.
n PGPL is committed to the continued safe

D- Procedure
operation of its pipelines and ensuring the
Hydrostatic testing of pipelines is one method to efficient and reliable transportation of
identify defects or damage in pipelines that could petroleum product.
potentially cause a pipeline leak.
A hydrostatic test is a routine test to ensure the E- Management Options of Hydrostatic
integrity of pipelines and distribution network. testing
The information below outlined the hydrostatic Management of Hydrostatic testing consists of;
testing process.
n Description of the pipeline to be tested.
n The gas inside the pipeline is removed and Include information such as the location,
replaced with water. This water contains an dimensions, and materials of construction,
environmentally safe green dye to aid in intended use.
determining the location of a defect, in the
event of leak. n Identify the source of the water to be used for
the test. (Should be a good quality water
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source such as a municipal water supply, B‑ Scope

drinking water well, irrigation well, clean
Scope of work include
source of surface water, etc.) Note: The use of
surface waters may require a temporary n Evaluation of present ambient air quality and
water use permit from the Pakistan noise level at existing area.
environmental protection agency.
n Evaluation of impact of impact of traffic
n Description of any chemicals to be added to movement at the proposed site and noise
the test water, the purpose for using the level.
chemicals, and the concentrations used.
Provide product literature and material n Evaluation of impacts on roads and in the
safety data sheets. adjacent area due to construction and
operation.
n Estimate total volume of test water to be
discharged in gallons and discharge rate. n Recommendations for mitigation techniques
to redress the expected impacts both for
n Description of how the test water will be design phase and operational phase.
settled, filtered, or otherwise treated to
prevent erosion and remove suspended C- Definitions
solids, oil and grease, and other pollutants.
In common use the word noise means unwanted
n A description of how dissolved oxygen will sound or noise pollution. Excessive noise
be restored to the test water if it is going to permanently damages hearing, but a continuous
reach any surface water body. low-level sound can be dangerous too.
n No hydrostatic test water may be discharged
within near drinking water supply intake. D- Procedure
n The operator's representative responsible for Air emissions (continuous or non-continuous)

ensuring that the hydrostatic test water is from LNG facilities include combustion sources for
disposed of properly. power and heat generation (e.g. for dehydration
and liquefaction activities at LNG liquefaction
8.5.5- Noise and air emissions terminals, and regasification activities at LNG
receiving terminals), in addition to the use of
compressors, pumps, and reciprocating engines
A- Purpose
(e.g. boilers, turbines, and other engines).
The purpose of this guideline is;
Emissions resulting from flaring and venting, as
n To monitor contents of polluting substances well as from fugitive sources, Principal gases from
in the atmospheric air; these sources typically include nitrogen oxides
(NOX), carbon monoxide (CO), carbon dioxide
n To control observance of approved limiting (CO2), and, in case of sour gases, sulfur dioxide
permissible emissions at man-made sources; (SO2). For LNG plants with important combustion
n To monitor natural sources and a number of sources, air quality impacts should be estimated by
man-made sources of emission at work sites the use of baseline air quality assessments and
at the construction phase; atmospheric dispersion models to establish
potential ground level ambient air concentrations
n To monitor noise emissions; during facility design and operations planning.
n Sources of noise emissions; These studies should ensure that no adverse
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impacts to human health and the environment n Environmental Management System (EMS)
result. development
Emissions of green house gases together with n Air permitting such as Prevention of
NOx and SOx are expected from power Significant Deterioration (PSD), New Source
generation plants. All reasonable attempts should Review (NSR),and state construction permits
be made to maximize energy efficiency and
n Air quality modeling and monitoring of air
design facilities to minimize energy use. The
and noise emissions.
overall objective should be to reduce air
emissions and evaluate cost-effective options for n Risk Management Plans
reducing emissions that are technically feasible.
n Emission release inventories (Toxic Release
The main noise emission sources in LNG facilities Inventories, Global Warming and Green
include pumps, compressors, generators and House Gas Inventories)
drivers, compressor suction/ discharge, recycle
n Leak Detection and Repair
piping, air dryers, heaters, air coolers at
liquefaction facilities, vaporizers used during n Pollution control technology assessment,
regasification, and general loading / unloading
n emission inventory development,
operations of LNG carriers / vessels.
Atmospheric conditions that may affect noise n capture efficiency,
levels include humidity, wind direction, and n control equipment performance and
wind speed. Vegetation, such as trees, and walls equipment specifications and warrantees,
can reduce noise levels. Installation of acoustic
insulating barriers can be implemented, where n compliance assessment,
necessary. n non-compliance resolution,
E- Noise and air emissions Management n negotiation of commercial terms for air
Options pollution and control equipment and control
systems, and
Noise and air emissions monitoring includes:
n Development of parametric monitoring,
n Strategic environmental planning (e.g., plant periodic monitoring, and compliance
sitting and fatal flaw analyses) assurance monitoring.
n Pollution control device feasibility,

8.5.6- Erosion protection
troubleshooting, and cost evaluations
requirements
n Innovative solutions and flexible permitting.
n Regulatory tracking and rulemaking A- Purpose Erosion Protection

negotiation on behalf of corporations and Erosion control projects protect public and
trade associations including New Source private land value and can help reduce sediment
Review (NSR) Reform, Maximum Available pollution by minimizing the degrading effects of
Control Technology (MACT) standard erosion. Erosion control projects utilizing natural
development materials also conserve plant, fish, and wildlife
n Enforcement assistance, economic habitat, as well as wildlife access to the land.
evaluations, expert testimony. Erosion control is necessary at the project sites
which are interfacing with land and shore.
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B- Scope that meets the soil loss tolerance. Soil loss

tolerances denote the maximum level of soil
Soil erosion by water and wind affects the natural
erosion that allows high levels of sustainable
environment. Soil loss, and its associated impacts,
economic crop productivity.
is one of the most important, yet probably the
least well-known, of today's environmental n Wherever possible, non-structural erosion
problems. The scope of this activity is to control control measures, such as marsh creation,
the erosion through practice of preventing or should be used to stabilize eroding
controlling wind or water erosion. shoreline.
n Where no significant erosion is occurring,

C- Definitions
structural shore erosion control measures
The natural process by which the surface of the should not be encouraged.
land is worn away by the action of water, wind, or
n Structural erosion control measures should
chemical action is termed as Erosion.
only be used in areas designated for this
Shore erosion protection works are structures or activity and when non-structural measures
measures constructed or installed to prevent or are impractical or ineffective.
minimize erosion of the shoreline in the critical
n A conservation plan includes best
area i.e. is most likely to be the area influenced by
management practices to address erosion and
the project.
sedimentation control and protection of the
soil resource. In the absence of a complete
D- Procedure
conservation plan, an erosion and
The best erosion control methods involve the sedimentation control plan consisting of
restoration of natural environments along the appropriate numbers and locations of
shoreline. Replanting bay grasses and shrubs and sediment removal best management practices,
utilizing biodegradable materials as well as must be developed, installed and maintained.
offshore breakwaters can stabilize soil while
enhancing habitats at the same time. Structural 8.5.7- Cleanup and re-vegetation
barriers, such as bulkheads, compact soil, alter the
composition of the land, and often undermine A- Purpose
natural ecology.
This involves removal of excess excavated material
Mulching - Applying plant residues or other (not used as backfill), restoring the site surface to final
suitable materials, not produced on the site, to the contours, and stabilization of slopes. After cleanup,
surface of the soil. This application will help disturbed areas are stabilized, smoothed, mulched,
conserve moisture; prevent surface compaction or reseeded, and fertilized as required. After
crusting; reduce runoff and erosion; control construction is complete and cleanup is in progress,
weeds; and help establish plant cover. temporary erosion controls may be removed and
permanent landscaping and erosion control
E- Management Options measures installed where required as part of final
facility reinstatement. It also involves the
Adequate management and/or structural best
conservation of mangroves which will be taken away
management practices to minimize accelerated
during construction activity.
erosion prevent sediment pollution to the waters
of the coastal area and maintain the resource base.
B- Scope
Generally this will require a conservation plan
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Topsoil is segregated from subsoils during this applicable environmental requirements and
operation. Top soil is stored in temporary topsoil specifications.
stockpile areas for later use in re-vegetation
programs. Regular visual inspection is conducted ii- Instructions
to monitor the growth of vegetation and to ensure The site environmental coordinator (SEC) will
that no erosion occurs on slope areas while the verify that the layout at the facility work area
trees and other vegetation get established to and temporary use areas conform to project.
protect the slope surfaces. The re-vegetation
programs will be continued by the Project. n The SEC will verify that clearing and re-
vegetation is performed in accordance with
Mangroves re-plantation will be conducted with a
construction Specifications, which include
ratio of 1:5 i.e. for each mangrove removal five (5)
requirements for timber removal, slash
mangroves will be planted.
disposal, and dust control.
C- Procedure n The SEC will verify that any debris

resulting from clearing activities that may
To determine the number of protected species if
block stream flow, contribute to flood
any in or around the construction zone in order to
damage, or result in streambed scour or
assess damage inflicted on the natural
erosion is immediately removed from the
environment through the loss of these species and
stream area.
the damage to their ecotopes in the course of
clearing construction sites: n The SEC will verify that all necessary
measures are taken to minimise erosion and
n To determine number of rare species
growing within the determined populations transport of sediment and silt from graded
in the clearance zone. and disturbed work areas. Erosion control
specifications and site specific erosion
n To determine proximity of the rest of the
species population to the pipeline route in control plans will be followed to ensure
order to assess the constructions possible that disturbed areas are stabilised and
impact on the whole of the population. erosion is minimised to the greatest extent
n To assess the condition of rare species in the practicable.
impact zone prior to and in the course of the
n Environmental inspection will be conducted
construction, as well as during
commissioning of the facilities. during clearing and grading activities and in
coordination with Construction
n To determine number of mangrove species/
total area over which mangrove area spread. Superintendent.
n To identify area for re-plantation of n IUCN and regulatory authority will be in

mangroves with consultation IUCN and close contact by PGPL while managing/
regulatory authority. replanting mangroves and their suggestions
will be considered accordingly.
D- Management of Cleanup and re-
vegetation E- Recording & Reporting
The site environmental coordinator (SEC) will
i- Responsibilities
document on a Daily Environmental Inspection
The site environmental coordinator (SEC) is Reports (DIR) the progress of clearing and re-
responsible for verifying that clearing and re- vegetation activities and status of compliance.
vegetation is performed in compliance with
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8.5.8- Waste management plan semi solid or liquid. Additionally, abandoned

materials and materials intended to be recycled
are considered wastes. It is very important to
A- Purpose of Waste Management
understand this concept, because even though
The purpose of this procedure is to provide something is going to be recycled, it must be
guidelines and simplify the process of managed as a waste until it is actually recycled.
categorizing, quantifying, managing, and
disposing of solid wastes. Waste management is a ii- Hazardous Waste
critical component of company's operating Waste is categorized as a hazardous waste if it
policies. Waste management includes the proper has one or more of the following properties:
handling, collection, storage, manifesting,
transportation, and disposal/recycling of the n Ignitability (flash point less than 60 0 C);
solid waste generated. The procedure is designed
n Corrosivity (pH less than or equal to 2.0, or
to assist in a company wide effort to provide
greater than or equal to 12.5);
protection to the environment and to comply with
company's corporate requirement, environmental n Reactivity (inherently unstable under
laws and regulations regarding proper waste ordinary conditions or when exposed to
management. water);
n Irritability (when in contact with body

B- Scope causes inflammation)
The waste management plan has been developed
n Toxicity (may cause risk of injury to health
by the pipeline / jetty construction contractors to
of organisms or the environment.)
ensure that the Management of solid waste
generated as a result of the construction of the iii- Non-hazardous Waste:
pipeline and associated activities is consistent,
The wastes are categorized as non-hazardous
efficient, and in conformance with the laws and
wastes, if they do not possess any of the
regulations.
hazardous characteristics as defined above.
With respect to monitoring, the waste However, non-hazardous waste may still
management sets out the following objective: present hazards to employees who handle them.
All recommended safety and handling practices
n To monitor and inspect waste management- must be followed.
related facilities and activities directly
resulting from executing the scope of the
D- Procedure
contract in order to ensure compliance with
the WMP. Guidelines for proper handling, Priorities to manage the waste are listed below:
categorization, recording, minimization,
n Eliminate waste production whenever and
recycling and disposal of all types of waste
wherever possible. Use the material only for
associated with company operations and
its intended purpose on site
projects are part of this procedure.
n Minimize waste production
C- Definitions
n Reuse
i-Waste n Recycle waste on site.
Any material, for which no further use is n Dispose of waste through properly designed
intended, is considered a waste. It can be solid,
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waste disposal facility. are very high, so it is extremely important to

identify wastes and keep them segregated.
i- Waste Minimization
The scheme of segregation is as follow:
To minimize waste, the following steps shall be
taken by all personnel working on n All hazardous waste shall be segregated
COMPANY sites: from other types of hazardous wastes as well
as non-hazardous wastes at the point of
n Only the needed amount of materials shall be
generation of waste.
ordered. Before purchasing hazardous
material, all alternatives for non-hazardous n At all facilities, following types of
material should be explored. containers, with colour coding for easy
identification, shall be kept to collect and
n Prior consideration shall be given to the sizes
segregate common wastes:
of containers available when ordering
products that could potentially generate n Food waste shall be collected in separate
waste. The intent is to avoid unused products containers.
and / or their containers from becoming
n All containers must be properly and clearly
wastes that require special handling.
labeled. The label must clearly mention the
ii- Waste Categorization name or type of waste. Also, if the waste is
hazardous, it should be clearly labeled on
All wastes generated at COMPANY facilities shall
the container along with its hazardous
be categorized in two major categories (i.e.
characteristics (e.g. flammable, toxic,
Hazardous wastes and Non-hazardous wastes) as
radioactive, etc.). This is important to
per the definitions in section 3.0. Each category
workers and to emergency response teams,
has different types of requirement for handling,
who need to know what they are dealing
storage and disposal.
with. Missing or unreadable labels must be
iii- Labeling replaced.
v- Storage and Handling

n Name of the waste (e.g., waste oil, solvents).
n Waste category (e.g., toxic, ignitable). n Waste that will be sent for recycling or off-site
disposal shall be temporarily stored at waste
n Facility name and address (disposal site, etc.). storage facilities available at different sites
n Date of waste accumulation: (date when such as Junkyard, Scrap yard, pits, etc.
waste was placed in drum). n The oily sludge, contaminated soil and
n Wastes are segregated and located in other hazardous liquid waste (e.g. rinsate,
designated areas to optimize control; storage chemicals, etc.) shall be stored in lined pits
with HDPE liner. Liner shall be of sufficient
areas.
thickness (at least 20mil) and adequate
iv- Segregation strength to withstand tears and punctures.
Waste management becomes very complicated if n All other wastes awaiting disposal shall be
different types of waste are mixed together. A kept in closed containers separately. Care
small amount of hazardous waste, mixed with a must be taken to prevent wastes giving rise to
non-hazardous waste or recyclable material, can secondary environmental problems, such as
make the whole mixture a hazardous waste. odors or soil and groundwater pollution
Disposal costs and liabilities for hazardous waste through rainwater leaching.
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n All stored wastes must be clearly labeled with Disposal becomes the only available alternatives, if
type of waste and warning signs. reuse and recycling options are exhausted. A
material should be classified as a waste for disposal
n Daily estimates of hazardous and no
only if no other useful purpose can be identified and
hazardous waste and volumes generated on
if the material cannot be beneficially reused or
site.
recycled. The choice of a suitable disposal option for
n Waste segregation, waste storage containers, any waste depends on both environmental and
general housekeeping and the provision of economic considerations. The final disposal can be
adequate resources will be monitored. either at on-site disposal facilities or at off-site
disposal facilities.
n All workers handling wastes shall use proper
PPE.
(a) On-site Disposal Facilities
vi- Recycling
Recycling and reuse minimizes the quantity of waste Burial Pits
requiring disposal. Some of the wastes can be reused Only segregated food waste shall be buried in
within the facilities while others can only be recycled burial pits. Buried waste should be covered with
a thick layer of soil as 'daily cover' to reduce the
Coding system for different type of waste
environmental problems, such as odour from
Waste material (Colour or code) decaying / degrading waste, spreading of waste
Glass (blue); n into other areas due to wind, vermin and disease
Metals (green); n vector, flies, mosquitoes, etc.
Plastic (white); n
Reserve pits
Oily rags (black); n
These pits are used to temporarily store drilling
Used oil (red); n waste, chemical waste, oily sludge and
Rubbish / trash (yellow) n contaminated soil. The pits should be properly
designed and lined to avoid soil, groundwater and
at off-site recycling centers. For example, recycling of surface water contamination.
used oil is possible in some of the Lube Oil Recycling
companies; batteries may be sent back to Incineration
manufacturer or distributor for recycling. Waste Incinerator will also be used for disposal of waste
shall not be sold to the unauthorized but before burning the trash, plastics, metal, glass
contractors/companies, who may not have proper and any other items that are not to be burned,
recycling facilities, to avoid misuse and to reduce should be segregated first. Ash of the incinerator
associated liabilities. The possibilities of recycling of shall be buried in the lined landfill as it may
each waste are discussed in relevant documents. contain heavy metals.
vii- Treatment Evaporation Ponds

Some of the wastes, such as wastewater from camps, The evaporation ponds are used to dispose of
oily wastewater from process, etc., require proper produced water at some facilities by evaporation.
treatment before disposal. The treated water should All evaporation ponds should be lined.
comply with National Environmental Quality
Standards (NEQS). Off-site Disposal Facilities:
In Pakistan, properly designed and well-operated
viii- Disposal
commercial waste disposal facilities are scarce. All
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such facilities are being explored and evaluated for n Noise;

possible future use.
n Wastewater discharge;
E- Waste Management Options n Public transport; and landscape and visual

impacts, if any.
Waste will be managed accordance with the
following requirements. n Wildlife protection requirement
n Garbage collection containers, which will be n Fisheries protection

located on the land site and on board FSRU.
F- Recording & Reporting
n Environmental inspectors/technicians will
document, in their daily report, the compliance PGPL has to record the information about source,
to measures outlined in this plan. composition, quantity, and final disposal of the
waste. This information is needed for regulatory
n Kitchen and food waste will be segregated compliance, risk assessment and setting reduction
from other waste materials; the main targets and objectives as well as corporate
collection container for these wastes will be statistics.
emptied at least twice a day in the interests of
health and hygiene. The Waste Tracking Form, as shown in Table-8.3
shall be used to record this information by all
n Other wastes such as tins, glass, packaging, PGPL teams, while waste is being dispatched
plastics, etc., will be placed in the outside facility or PGPL's controlled location. It is
appropriately designated collection the responsibility of the Team Leader to assign a
container; the main waste containers will be suitable person (such as Lead Operator at all
emptied at an approved waste storage site. manned fields) to sign off the Waste Tracking
n All wastes will be segregated upon receipt at Form, before the waste is dispatched outside.
the waste storage area.
8.5.9- Environmental monitor/
n Inert waste will be segregated and stored to
inspector
promote reuse; it will not be stored where it
can be easily moved into a wetland or water
A- Purpose Environmental Monitor /
body.
Inspector
n The main garbage collection container(s) will
be regularly collected and transported by a This procedure identifies environmental
waste collection firm who speciallise in waste responsibilities for the project offices and for the
disposal as per regulations. construction site. It also provides procedural
guidance for environmental training, inspection,
n The impact caused by handling (including monitoring functions during construction.
stockpiling, labeling, packaging & storage),
collection, transportation and disposal of B- Scope
wastes shall be addressed in detail and
appropriate mitigation measures shall be Primary scope of environmental
proposed. This assessment shall cover the inspector/monitor is to comply with the
following areas: environmental requirements of the project. PGPL
is also responsible for inspecting, documenting,
n Potential hazards; and ensuring that construction meets
n Air and odour emissions; environmental responsibilities through an
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integrated program of personnel orientation and contractor and agency field representative
training, and inspection of construction activities. and will coordinate regularly with the
In addition, the company will assist in various construction inspectors are apprised
implementing environmental management plans of the status of environmental issues in their
through its program of construction inspection. respective areas.
n The EI will be responsible for determining

C- Definitions
noncompliance activities and anticipating
Consists of examining construction activities in the activities and situation that could result in
field to verify and document that activities are noncompliance to plan of Development,
carried out in compliance with construction and environmental permits, and project
environmental Permits, specifications relating to stipulations.
environmental protection, and mitigation plans
n The EI will play a significant role suggesting
approved for the LNG project.
methods to bring construction activity into
compliance and/or to temporarily halt
D- Procedure certain activities that may cause damage to
The company will establish a plan detailing the sensitive environmental resources.
procedures and documents required for
implementing environmental management plan E- Management Options
thereby complying to the environmental Functions and responsibilities that will be
legislations and regulations during the assigned to company's ES&H department
construction and operational phase of the project. include:
An environmental inspector will be assigned
n Orientation of LNG project personnel in
oversee the environmental compliance inspection
environmental requirements and procedures
process. In addition to performing duties, the
particularly in context to the sensitive
environmental inspector (IE) will;
resource issues at the construction site.
n Communicate with the Environmental n Environmental training particularly in
Manager and the Chief Construction officers environmental monitoring is to be imparted
on daily basis. to all project personnel.
n Provide key liaison role in coordinating n Inspection of facilities construction activities
attendees and facilitating agreements in the for compliance with environmental
field, as appropriate, with agency regulations,
representatives.
n Specifications, stipulations, drawings,
n Coordinate daily with construction mitigation plans, and procedures.
inspectors, the contractor, and biological
and culture monitors to ensure that n Documentation of all training, inspection,
required monitors are present when and monitoring activities should be
construction activities are scheduled in all exercised.
requiring monitors. n Coordinate with the owner's environmental
n The EI will be on a peer status with other representatives and management personnel
project construction inspection staff. on environmental issues.
n The EI will act as a liaison between the n Provide technical support to Owner for
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Table-8.3: Waste Tracking Form

Location of Generation:
Reporting Team:
Submitted by (Name):
Submitted on (Date):
Waste Approx. Quantity Unit Disposal Location
Aerosol Cans (Empty)
Asbestos
Batteries (Dry)
Batteries (Lead Acid)
Charcoal from Turk Amine Plant
Clinical Waste
Construction Waste
Crude Oil or Condensate Waste
Descaling Acids
Diethanolamine (DEA)
Drilling Fluids/Solids
Drums and Containers (Empty)
Filters
Fluorescent Light Tubes
Food Waste
Glycols
Laboratory Wastes
NORM Containing Waste
Oil Contaminated Soil
Oily Rags (Used)
Paint Waste
Pigging Wastes
Plant Wastewater
Produced Water
Rinsate
Sanitary Wastewater
Scale (Pipe and Equipment)
Sludge
Trash
(i) Glass
(ii) Metal
(iii) Plastic
(iv) General Trash
Used Engine Oil
Checked and Signed: dated:
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obtaining environmental permits or other includes:

Authorizations as needed or modified during
n Summary of inspection and monitoring
facilities construction.
efforts on the spread over the past week;
F- Recording & Reporting n Identification of any non-compliance and
Environmental compliance records will be steps taken to correct non-compliance;
completed daily (as applicable) on standard n Any other issues or problems encountered in
reporting forms. Other records may include daily carrying out inspection activities (e.g.,
logbooks, meeting notes, correspondence, or schedule
records of telephone conversations. Compliance
reports and other appropriate records will be n delays);
logged into the field ES&H office and copies n Government representatives on-site during
transmitted to the project office. the week;
Forms will be used to document field inspection n Inspection and monitoring plans and
activities. They become permanent documents schedules for the upcoming week.
when completed by the Site Environmental
Coordinator (SEC) /trainer and reviewed and n General site audit and completion of the
signed by the appropriate supervisor, as required. "Weekly Inspection Checklist".
Documentation that will be used by field The Owner will have a standing invitation to
environmental compliance personnel is accompany project personnel on this audit. The
summarized below. checklist will be modified over time to reflect
pertinent issues related to the phase of
i- Daily Environmental Inspection Checklist construction presently occurring.
The purpose of the checklist is to document the
results of the environmental inspection activities 8.6- Contingency planning-
conducted during the day with respect to accidents & malfunctions
compliance of observed construction activities
relative to applicable environmental 8.6.1- Fire Contingency Plan
requirements.
Because flammable / combustible materials are
The ES&H Manager reviews the report for
present at this site, fire is an ever-present hazard.
adequacy and accuracy and identifies potential
problem areas. Construction sign-off is required All personnel and subcontractors are not trained
only if there is a non-compliance requiring action professional fire-fighters. Therefore, if there is any
and/or acknowledgement by Construction. Copies doubt that a fire can not be quickly contained and
of all checklists are filed in the site ES&H files. extinguished, personnel will notify the Site
Superintendent by radio and vacate the area. The
The checklist is designed to be site specific and
Site Superintendent will immediately notify the
will remain dynamic through-out construction to
local Fire Department.
ensure it remains relevant to current activities.
The following procedures will be used to prevent
ii- Weekly Inspection Report the possibility of fires and resulting injuries:
A weekly inspection report is prepared by the
n Sources of ignition will be kept away from
SEC after completing a general inspection of site
where flammable materials are handled or
and submitted to the field ES&H Manger with stored.
copies to the Environmental Lead. The report
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n The air will be monitored for explosivity single long blast on the air horn).
before and during hot work and periodically
n No further entry of visitors, contractors, or
where flammable materials are present. Hot
trucks will be permitted. Vehicle traffic
work permits will be required for all such
within the site will cease in order to allow
work.
safe exit of personnel and movement of
n No Smoking" signs will be conspicuously emergency equipment.
posted in areas where flammable materials
n Shut off all machinery if safe to do so.
are present.
n All on-site personnel, visitors, and
n Fire extinguishers will be placed in all areas
contractors in the support zone will assemble
where a fire hazard may exist.
at the entrance to the site for a head count and
n Before workers begin operations in an area, await further instruction from the Site
the foreman will give instruction on egress Superintendent.
procedures and assembly points. Egress routes
n All persons in the exclusion zone and
will be posted in work areas and exit points
contamination reduction zone will be
clearly marked.
accounted for by their immediate crew
The following procedures will be implemented leaders (e.g., foremen). Crew leaders will
in the event of a fire: determine the safest exits for employees and
will choose an alternate exit if the first choice
n Anyone who sees a fire will notify their
is inaccessible.
supervisor who will then contact the Site
Superintendent and the Health and Safety n During exit, the crew leader will try to keep
Officer by radio. The Health and Safety the group together. Immediately upon exit,
Officer will activate the emergency air horns the crew leader will account for all employees
and contact the local Fire Department. in his crew.
n When the emergency siren sounds, workers n Upon completion of the head count, the crew
will disconnect electrical equipment in use (if leader will provide the information to the Site
possible) and proceed to the nearest fire exit. Superintendent.
n Work crews will be comprised of pairs of n Contract personnel and visitors will also be
workers (buddy system) who join each accounted for.
other immediately after hearing the fire
The names of emergency response team
alarm and remain together throughout the
members involved will be reported to the
emergency. Workers will assemble at a
Site Superintendent.
predetermined rally point for a head count.
n A final tally of persons will be made by the Site
n When a small fire has been extinguished by a
Superintendent or designee. No attempt to
worker, the Site Superintendent and the
find persons not accounted for will involve
Health and Safety Officer will be notified.
endangering lives of employees by re-entry
into emergency.
A- Evacuation Procedures
n In all questions of accountability, immediate
In the event on-site evacuation of remedial action
crew leaders will be held responsible for those
personnel is necessary, the following actions will
persons reporting to them. Visitors will be the
be taken:
responsibility of those employees they are
n The emergency signal will be activated (one seeing. Contractors and truck drivers are the
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responsibility of the Site Superintendent. The n Any injuries involved.

Health and Safety Officer will aid in accounting
n Fire and/or explosion or possibility of these
for visitors, contractors, and truckers by
events.
reference to sign-in sheets available from the
guard shack. n The area and materials involved and the
intensity of the fire or explosion.
n Personnel will be assigned by the Site
Superintendent to be available at the main This information will help the Site
gate to direct and brief emergency Superintendent to assess the magnitude and
responders. potential Seriousness of the spill or release.
n Re-entry into the Site will be made only after B- Procedure for Containing/Collecting
clearance is given by the Site Superintendent.
Spills
At his direction, a signal or other notification
will be given for re-entry into the Site. The initial response to any hazardous spill or
discharge will be to protect human health and
n Drills will be held periodically to practice all
safety, and then the environment. Identification,
of these procedures and will be treated with
the same seriousness as an actual emergency. containment, treatment, and disposal assessment
will be the secondary response.
8.6.2- Hazardous spill contingency If, for some reason, a chemical spill is not
plan contained within a dike or sump area, an area of
isolation will be established around the spill. The
In the event of an emergency involving
size of the area will generally depend on the size of
hazardous material spill or release, the following
the spill and the materials involved. If the spill is
general procedures will be used for rapid and safe
large (greater than 55 gallons) and involves a tank
response and control of the situation.
or a pipeline rupture, an initial isolation of at least
Emergency contacts in Table-8.4 provide a quick 100 feet in all directions will be used. Small spills
reference guide to follow in the event of a major (less than or equal to 55 gallons) or leaks from a
spill. Hazmat spill responses will be coordinated tank or pipe will require evacuation of at least 50
through the local Emergency Response Centre. feet in all directions to allow cleanup and repair
and to prevent exposure. When any spill occurs,
A- Notification Procedures only response personnel will be allowed within the
designated affected area. If possible, the area will
If an employee discovers a chemical spill or a vapour
be roped or otherwise blocked off.
or material release, he or she will immediately notify
the Site Superintendent. If the spill results in the formation and release of
a toxic vapour cloud, further evacuation will be
The Site Superintendent will obtain information
enforced. In general, an area at least 500 feet wide
pertaining to the following:
and 1,000 feet long will be evacuated downwind
n The material spilled or released. if volatile materials are spilled.
n Location of the release. If an incident may threaten the health or safety of the
surrounding community, settlement, etc., it will be
n An estimate of quantity released and the rate consulted and determine if the public will be
at which it is being released. informed and possibly evacuated from the area. The
n The direction in which the spill, vapour or Site Superintendent will inform the proper agencies
smoke caused by the release is heading. in the event of its being necessary (refer to Table-8.5).
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All petroleum product spills on the water will be material.

reported to the Environment Protection Agency
n Determine the major components in the waste
Sindh.
at the time of the spill and remove all
As called for in regulations developed under the surrounding materials that could be reactive
Comprehensive Environmental Response, with the spilled material.
designated Response personnel will take the
n If wastes reach a storm sewer; try to dam the
following measures:
outfall by using sand, earth, sand bags, etc. If
n Avoid breathing vapors of spilled material. this is done, pump this material out into a
temporary holding tank or drums as soon as
n If possible and safe to do so, turn off any
possible.
ignition source or gas emergency shutoff
valve. n If volatile emissions may occur, spray the
spill area with foam, if available.
n Make sure all unnecessary persons are
evacuated from the hazard area. n Apply appropriate spill control media to
absorb discharged liquids.
n Put on protective clothing and equipment.
n For large spills, establish diking around
n If a flammable material is involved, remove
leading edge of spill using booms, soil or other
all ignition sources, and use spark and
appropriate material. If possible, use a
explosion proof equipment for recovery of
Table-8.4: Emergency Telephone Number

Emergency Response Dept. Numbers
Local Fire Department
Local Police 15
Hospital Emergency Room
Site Superintendent
Site Safety Officer
Project Manager
Vice President, Health and Safety
Table-8.5: Contingency and Response Team

Team Member Title SES Title Individual Name
Health and Safety Officers Site Superintendent
Alternate Health and safety Officers Health and Safety Officer
Alternate No.2 Project Manager
Response Team Support Personnel Operation on-site
Public Relations Project Manager
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diaphragm pump to transfer discharged liquid n Personal protective equipment (PPE)

to drums or a holding tank. selection/use
n Written and approved permits for hot work,

C- Emergency spill response cleanup
confined space
materials and equipment
n Air monitoring
The supply of appropriate emergency response
cleanup and personal protective equipment on n Following all standard operating procedures
hand will be inventoried and visually inspected
n Practice drills for fire, medical emergency, and
on a weekly basis.
hazardous substances spills.
The materials listed below will be kept on-site for
spill control depending on the types of hazardous 8.6.3- Housekeeping
materials present. The majority of this material will
be located in the support zone, in a supply trailer or In order to reduce the possibility of accidental
storage area. spills and safety hazards, good housekeeping
practices will be followed. They include prompt
n Activated charcoal (carbon) to adsorb removal of small spills, regular maintenance of
organic solvents (hydrocarbons) and to walking areas, regular removal of refuse, and
reduce flammable vapors. staging of similar materials together.
n Appropriate solvents, e.g. CITRIKLEEN, for
decontamination of structures or equipment.
8.6.4- Security
The following equipment will be kept on-site and All rules and regulations set up by landowner will
dedicated for spill cleanup: be followed by all personnel on site.
n Plastic shovels for recovering corrosive and 8.6.5- Training

flammable materials.
All site personnel are trained to operate the
n Sausage-shaped absorbent booms for diking
equipment that is present at the site.
liquid spills, drains, or sewers.
n Sorbent sheets (diapers) for absorbing liquid 8.6.6- Fire Detection and Warning
spills.
Portable Fire extinguishers will be used in
n Over pack drums for containerizing leaking buildings and as protection during "Hot Work"
drums. activities throughout the site. As construction
n 55-gallon open-top drums for progresses and systems are commissioned within
containerization of waste materials. specific buildings, personnel will be informed of
the differential of alarm sounds.
Once a hazard has been recognized, take
immediate action to prevent the hazard from n Large office accommodation will be protected
becoming an emergency. This may be by the use of hard-wired smoke detection
accomplished by the following: devices with battery backup.
n Daily safety meeting n A suitable means of raising the alarm in the

event of a fire or other emergency at the LNG
n Task-specific training prior to
terminal will be established. The alarm
commencement of activity
system will be appropriate to ensure all
n Lock-out/tag-out personnel can be notified immediately of any
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emergency situation and evacuation, or other 8.6.9- Materials storage

actions required. The alarm system will be
tested on a regular basis. n The Site ES&H Manager must be informed of
all flammable gases and liquids being
8.6.7- Site accommodation brought onto site.
Site accommodation (all temporary facilities) n Oxygen and fuel gas cylinders shall not be
shall be designed and laid out in such a manner stored together. The minimum distance
so as to reduce the risk of fire to the minimum. between cylinders is to be 3 meters. Singular
oxygen, acetylene carts will be acceptable as
n Good housekeeping shall be observed at all long as they are in use together.
times throughout buildings with desks cleared
at the end of each working day and sensitive n No flammable materials including solids,
documents locked away in flame proof gases or liquids shall be stored next to any
cabinets/ lockers. temporary facilities.
n All site accommodation shall have sufficient n Storage of flammable gases shall be a
multi purpose dry powder extinguishers minimum of 5 meters from any occupied
located at the access door with signs building suitably secured and with a
indicating their positions. prominent sign stating "DANGER HIGHLY
FLAMMABLE".
n Additional CO2 extinguishers shall be
provided to cover other electrical equipment. n Storage facilities for flammable gases will be
inspected by the Site ES&H Manager prior to
n All fire extinguishers are visually checked on a being used.
regular basis through weekly area inspections
and quarterly in accordance with equipment n Material storage within the warehouse
tagging process. facility will maintain an excellent standard of
housekeeping at all times. Flammable
8.6.8- Fire drills material packaging shall be removed to a safe
location as it becomes redundant. Sprinkler
n The Fire Safety Co-ordinator shall ensure that systems shall be investigated in warehousing
monthly drills are carried out that ensure all facilities, and were possible installed.
personnel are familiar with the evacuation
n Materials shall be stored in compliance with
procedure and their respective muster points.
OSHA and SEPA regulations.
n Simulated fires shall be carried out to ensure
the readiness and competency of the fire 8.6.10- Fire fighting equipment
brigade to fight a major fire. During the drill
equipment shall be tested and shall The following fire fighting equipment shall be
adequately work. In the event any piece of maintained in good order at the Project and
equipment should fail it shall be immediately Equipment will also be suitable for fighting bush
replaced. fires in and around the LNG Project:
n Review of brigade competency shall be n Fire Extinguishers of adequate size and

determined during the drills. Brigade number
members shall be retrained if any evidence of
n Fire hose and nozzles
in-competency exists.
n Bunker gear
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n Air packs confined space
n 1 pumper truck with internal tank n First aid
n 1 water tanker with pumping capabilities n High level rescue (if the site assigns this
responsibility to this group)
n Fire pumps of sufficient size to fill tanker
or pumper
8.7- Environmental
n Assorted accessories for connecting hoses compliance
and fighting fires (wrenches, hose clamps,
axes, etc. As confirmed in the Preliminary EMP, Proponent
will be responsible for regular audit and review of
n Rescue gear for high level rescue (if this is environment and safety management of the LNG
assigned to this group) facility. This will include both on-site auditing and
n Equipment shall be maintained and tested review of performance reports. Additional onsite
to ensure serviceability in the event of a inspections and investigations will be undertaken in
fire. the event of significant environmental incidents.
These will be undertaken in conjunction with the
n Tests shall be conducted monthly. relevant government agencies.
n A water fill station including a storage Plant management will participate in the audits
tank of adequate size to meet construction and inspections and investigations. Plant
fire requirements shall be installed to management will also be responsible for regular
facilitate the filling of the pumper truck review of the environmental performance of the
and tanker.
site and site personnel, and for the reporting on
n The plant fire suppression system shall be the implementation of commitments made in the
prioritised and serviceable as soon as EMP.
practical during construction.
There is also likely to be some compliance
auditing associated with the licensing of the LNG
8.6.11- Training Plant, for each government recommendation and
All employees shall receive general fire fighting proponent commitment, the following
training (i.e. fire extinguisher use). Employees information:
who are members of the fire brigade shall receive n The recommendation or proponent
at a minimum the following training: commitment being addressed;
n Use and limitations of the fire fighting n The issue to be addressed by the proponent;
equipment
n How the issue is to be addressed by the
n Fire fighting strategies and methods proponent;
n Use of respiratory equipment and its n Where the issue is addressed in the EMP;
limitations
n When the issue is to be addressed by; and
n Donning bunker gear and its care
n To whose satisfaction the issue is to be
n Care and maintenance of fire fighting addressed.
equipment and hoses
The finalisation of the EMP will see the
n Confined space entry and fire fighting in a completion of Compliance Audit Table, which
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will record dates of compliance by the proponent n Jetty and unloading arms
with recommendations and Commitments and a
n Process Area
reference to appropriate documentation from the
relevant approving authority. The Compliance n Low Pressure and High Pressure pumping
Table is meant to be a live document and will be systems
updated periodically throughout the life of the
n Vaporizers (Regasification Area)
project.
n Vent or flare systems (low pressure and high
8.7.1- Audits pressure)
In particular, there will be: n Maintenance Workshop
n Annual audit reports. n Administration Building
n A triennial review and improvement of the n Guard House

EMP. n Utility Area
Proponent recognises that periodic external n Control Room
compliance audits and inspections will be made
to monitor, assess and validate the level of n Gas Metering Station
Proponent performance and compliance pursuant
n Offshore Pipeline launching area
to the commitments made in the accepted
Environmental Management Plan. n Gas pipeline
n Gas Receiving Station

8.7.2- Site Internal Environmental
Audit
To enable site management to assess the day-to-
day environmental management of activities at
the site. Environmental activities include all
aspects of operations that result in emissions,
effluent or wastes.
8.7.3- Environmental Management

Systems Audit
To assess the implementation and operational
success of the EMS at the site. This is achieved by
assessing the objectives, organisational structure,
responsibilities,
Procedures, processes and resources available at

the site. The EMS Audit is a systems assessment,
rather than an audit of environmental
compliance, which is assessed through the Site
Internal Environmental Audit.
Potential areas of concern for audit during

construction of LNG plant mainly include:
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Table 8.6: Environmental Monitoring Plan
Stage Monitoring areas Parameters and techniques to monitor Monitoring frequency Reason to monitor parameter Responsibility
Dredging l Benthic Community Continuous l Dredging results in disturbance Health, Safety &
l Erosion and Sedimentation of benthic community. Environment Department.
l Vegetation l Causes soil erosion and
l Disposal of Dredge Material sedimentation.
Marine Ecology l Biodiversity Continuous Unmitigated operations may result Health, Safety &
in loss of biodiversity Environment Department
Air Emissions l CO l Before start of
l SOX Emissions from construction Health, Safety &
construction activity machinery and power production Environment Department
l NOX
Environmental Management Consultants

l Monthly monitoring
l PM10 and operation of FSRU may result
during construction and in deterioration of air quality
l PM2.5 operation
l SPM
Continuous Improper disposal may result in Health Safety &
Solid Waste Solid waste quality and quantity Environment Department
deterioration of marine ecology
Construction
Wastewater Primary Pollutants of NEQS Monthly Improper disposal may result in Health, Safety &
deterioration of marine ecology Environment Department
Noise Uncontrolled noise may cause Health, Safety &

Noise Intensity l Start of construction Environment Department
l Monthly nuisance
l Soil contamination Monthly Health, Safety &
Ref: Y8LGOEIAPD
Soil l Soil erosion Surface and sea water pollution
Environment Department
l Soil sedimentation
l Accidents Continuous Occupational safety and legal Health, Safety &
Occupational l PPEs
Safety obligations Environment Department
l Annoyance
Land reclamation l Soil Quality Continuous Legal obligations and structure Health, Safety &
protections. Prevention of soil Environment Department
erosion and sedimentation to the
port.
52 of 53
Chapter 8
Table 8.6: Environmental Monitoring Plan
Stage Monitoring areas Parameters and techniques to monitor Monitoring frequency Reason to monitor parameter Responsibility
End of Restoration of l Visual analysis End of construction Compliance of Environmental Health, Safety &
construction sites l Photographic records Approval Conditions Environment Department.
l Waste water minimisation Compliance of Environmental

Waste water Monthly Health, Safety &
l Storage and handling Approval Conditions
l Recycling and reuse Environment Department
l Treatment before disposal
l Primary Pollutants of NEQS
Monthly Compliance of Environmental Health, Safety &
Solid waste l Solid waste quality and quantity Approval Conditions
l Solid waste disposal Environment Department
Environmental Management Consultants

Fire & Safety l Fire Hazards & Compliance of Environmental
Continuous Health, Safety &
l Safety Protocols Approval Conditions
Air Emissions l CO
Monthly Compliance of Environmental Health, Safety &
l SOX
l NOX Approval Conditions Environment Department
l PM10
Operations
l PM2.5
l SPM
Noise Noise intensity measurement Monthly Compliance of Environmental Health, Safety &
Ref: Y8LGOEIAPD
Approval Conditions
l Spill on Land Compliance of Environmental
Hazardous spill Continuous Health, Safety &
l Spill on Water Approval Conditions Environment Department
Traffic Standard Operating Procedures Compliance of Environmental
Continuous Health, Safety &
management Approval Conditions Environment Department
Compliance l EIA Commitments Monthly l EIA Commitments Independent Monitoring

monitoring l Mitigation Measures l Mitigation Measures Consultant (IMC)
l Conditions of Environmental Approval l Conditions of Environmental
l SOPs Approval
l SOPs
53 of 53
Chapter 8

Chapter 8-Environmental Management Plan

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Chapter 8-Environmental Management Plan

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

8 ENVIRONMENTAL MANAGEMENT PLAN

n Energy management: The energy-related laterals);

n Water management: Aspects of supply,

course, "prevention". When the Emergency Response Plan is put into

n Release of LNG in large quantities

Figure 8.1: Emergency Organization

storage and dispatch, industrial services and D- Natural Risks

B- Risk Situations E- External risks

H- Evacuation Plan Phone No. ____________________________

ii- Post-Incident Contacts*:

Health n Identify the character, exact source, amount,

and areal extent of any released hazardous for use.

future. Chemical Handling Training Procedures

iii- Emergency Equipment: Safe method for handling and storage of

Emergency Response Training Procedures

Table 8.1: Emergency Equipment Inventory

i- First Stage: Notification frequencies will be established for the

n LNG Plant Accident Response; n Severe weather conditions; and

of a pipeline or equipment; Emergency: This is an Uncontrollable Emergency

n In addition, a Security Breach that results in a

Examples of this situation include: n Uncontrollable Emergency resulting in a

smoke detectors, high and low temperature B- HSE Manager

management and issues raised by activities are scheduled in all requiring

n Reviews loss-control reports submitted by n Authorizes purchases of tools and equipment

G- Department Manager (Department Head; n Adopts standards for assigning protective

manager and indicating condition and employee's apparent physical limitations to

n Ensures the indoctrination of new or n Enforces wearing of protective equipment;

n Develop recommendations for improvement n Reinforces behavior and corrects unsafe

GENERAL ORGANIZATION FOR ENVIRONMENTAL MANAGEMENT

level of interest in HSE through various be recognized as one of guidance not

n Understand current Federal and state HSE

ii- Personal Protective Equipment incident-free workplace by:

n Training for emergency response and

n Specific environmental training for relevant n Unloading operations must be immediately

i- Identification of training requirements n Flammable substances that could explode or

wharf n Basic fire-fighting procedures.

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

c) Procedures to respond to a fire on the e) Procedures for toxic substances

vapors in the risk area to analyze the need to shutdowns.

n Blind flanges have been installed in the

supply tank. issues that require attention of higher

n Appreciation of properties of hazardous substances A- Kick-off Meeting

n Awareness of methods and trials for C- Peer Review

This section will outline criteria for management's B- Scope

8.4.3- Compliance monitoring D- Procedure

It would be required by the management of PGPL to i- Information Required

n The Terminal Yard Planner: is responsible for

water flows. n Sustainable management of water

n Water is a vital component of the

i- Construction of Watercourse Crossings n Water plays an essential role in a prosperous

n Cross watercourses at right angles; n Water must be managed in consultation with

These principles are: Wastewater as part of drilling and construction,

production shall be managed as per this (iii) Non-hazardous Waste:

n Concentration of contaminants too high

Table-8.2: Wastewater Data Sheets Guidelines for Wastewater Management

n Total Dissolved Solids (TDS) and total suspended solids

Waste Category Non-hazardous

Analysis Refer Monitoring procedure for analysis requirements

Ownership / Responsibility Production Team Leaders

Waste Handling When handling plant wastewater, protect yourself from

direct contact by using appropriate personal protective equipment

Waste Reduction n Reduce water use

n Dispose water into lined evaporation ponds or skim pits