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Saudi Aramco PMT
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Project No: SA222501
Document No.: SAPMT-MYPD-2018-Q4-REP-001
Al Fanar Tower, Custodian of the Two Holy Mosques Road
Prince Humud Street
P.O. Box 981
www.jacobs.com
© Copyright 2018 Jacobs, Zamel and Turbag Consulting Engineers Company (Jacobs ZATE), a Saudi Arabian professional services partnership, is an affiliate of Jacobs Engineering Group Inc.. The concepts and information contained in this document are the property of JacobsZate. Use or copying of this document in whole or in part without the written permission of JacobsZate constitutes an infringement of copyright.
Limitation: This document has been prepared on behalf of, and for the exclusive use of JacobsZate’ client, and is subject to, and issued in accordance with, the provisions of the contract between JacobsZate and the client. JacobsZate accepts no liability or responsibility whatsoever for, or in respect of, any use of, or reliance upon, this document by any third party.
Document history and status
0 01 November 2018 Issued for Review MH EB EB
Maritime Yard Project Environmental Compliance Monitoring
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1.3 Inspection Schedule............................................................................................................................ 2
1.5 Environmental Compliance Monitoring Dashboard ............................................................................ 2
2. Environmental Compliance Monitoring ........................................................................................... 6
Appendix A. Environmental Compliance Monitoring Photos
1
Coordinator
Campbell
Environmental
Compliance
Monitoring:
Saudi Aramco PMT offices and compound, Maritime Yard Project Dept. (MYPD) construction
areas (platform, island, tuxedo area, finger jetty), SARCO vehicle inspection area, SARCO
steel and store yards, contractors’ offices and camps (i.e. HUTA/ARCHIRODON consortium)
were visited during the inspection.
The inspection covers the onshore project activities and facilities only. No offshore
inspection has been undertaken.
The objective of the Environmental Compliance monitoring is to evaluate the compliance of
the Project during the execution phase against the following Environmental requirements:
Land Use Permit (LUP) Conditions, Environmental Impact Assessment (EIA) Conditions,
Environmental Design Requirements, Construction Environmental Management Plan (CEMP),
Saudi Aramco Policies, Standards and Procedures, as well as Saudi Government
Environmental Regulations, Environmental Management System - EMS ISO 14001:2015 (as
applicable).
The concrete batching plant does not strictly fall under the contractual jurisdiction of
SAPMT, but it is known that primary contractors are utilizing this batching plant for the
project. For the purposes of reporting, the batching plant has been considered
independently and is reported separately in Section 2.
1.2 Environmental Compliance Critical Observations
Table 1 below describes the Major Non-Conformities for the project and the required Corrective Actions.
Note that the recommended Corrective Actions should be systematically implemented across the entire
project to achieve compliance.
The outstanding major non-conformity for the September visit (i.e. item 157) has been closed. No new major
non-conformities where recorded during Visit-1 of Quarter 4 (Q4.1).
Table 1: Major Non-Conformities for Maritime Yard Project and Required Corrective Actions
Ref Compliance Risk Required Action Reference Target Date Status
157 Unpermitted
discharge of
2
Site Inspections: 24th October 07:00 – 09:30 (MYPD construction areas), 09:30 – 10:00 (contractors’
offices and camps (i.e. HUTA/ARCHIRODON consortium)), 10:00 – 10:30 (SARCO
vehicle inspection area), 10:30 – 11:30 (SARCO steel and store yards) and 14:00 –
14:30 (SAMPT Camp)
October) and Tamimi EC (24th October)
Close-out Meeting: 24th October 14:30
1.4 Environmental Compliance Criteria
The environmental compliance of the Project is defined using the criteria outlined in Table 2 Environmental
compliance is determined through; visual inspection, discussion and interviews with site representatives’ and
review of documentation associated with the Project.
Table 2: Compliance metrics, descriptions and associated risks
Colour
Major Non-
reputational damage. Immediate
project schedule and cost due to
major non-conformity. Action to be
taken within 30 days.
procedures or standards. Legal
non-compliance with potential for
schedule and project cost due to
minor non-conformity. Action to be
taken within 60 days.
No action required.
practice recommendations.
although improvement recommended
within 90 days.
prioritized for the next compliance
monitoring visit.
following further compliance
1.5 Environmental Compliance Monitoring Dashboard
Figure 1 below provides the monthly overview of environmental compliance for the Maritime Yard Project
Department. The ring on the left indicates the status of all environmental items which are monitored and the
3
percentage (%) which have been inspected during Visit-1 of Quarter 4 (Q4.1). The ring on the right indicates
the % of compliance across the environmental items that were inspected (i.e. 91%), excluding items with
observations (i.e. compliant items (green) / compliant + minor non-conformities + major non-conformities
(green, amber, red) *100). Observations are excluded from this calculation as these are considered compliant
with room for improvement in best practice terms only or there is currently insufficient evidence to determine
compliance.
Figure 1: Current project compliance
A further breakdown of environmental compliance is provided across the twelve main environmental categories
in Figure 2 below. This breakdown assists with indicating where non-conforming conditions were observed and
shows where improvements or, in some cases, recent failures in compliance were recorded. Consequently, this
highlights the areas where further improvements are required.
5
Figure 2: Further breakdown of environmental compliance by category for Q4.1 (October 2018)
0
5
10
15
20
25
30
35
Waste Management
Minor non-conformity Observation Compliant
6
(Q4.1)
1
Has a suitably qualified full-time Environmental Coordinator and backup been appointed for the project. This includes a suitably qualified SA PMT EC.
MYPD EIA (Section 9.4); MYPD EIA Section (Section 9.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8.1.9); MYDP EMS Manual (Section 6), EMS Manual
Minor non-
Environmental Coordinator
project. This individual would
environmental aspects of the
Have EMPs been prepared and held on site?
MYPD EIA (Section 9.4); MYPD EIA (Section 9.5); Saudi Archirodon / Huta Hegerfeld; MYPD Environmental Management Plan (Section 1.3)
Compliant EMPs are held on site. None required. Compliant
3
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 19.1), LUP Attachment Letter
Compliant
been prepared based on
7
(Q4.1)
4
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)
Compliant
representatives were noted in
multiple locations visited across
Is there a clear hierarchy for environmental management on site?
MYDP EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)
Compliant
contractors inspected to date.
Systems and Awareness
Is there an environmental policy and is this clearly communicated to staff and contractors (e.g. notice boards)?
MYPD EIA (Section 9.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 1.2); MYPD Environmental Management Plan (Section 15)
Compliant
Environmental
None required. Compliant
Have all staff attended HSE Induction training and a register maintained?
MYPD EIA (Section 10); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 1.3); MYPD EMS Manual (Section 7, 15)
Compliant
representatives arriving on-site.
8
(Q4.1)
8
Are Environmental Tool Box Talks (TBT) being held regularly and documented?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8.1.4); MYPD EMS Manual (Section 7, 15)
Compliant
observed.
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 19.1); MYPD EIA (Section 10); MYPD EMS Manual (Section 7, 15)
Compliant
Compliant
Environmental/directional
signage for waste segregation
noted to be missing, ignored or
misplaced in a number of areas.
HUTA/SARCO: Workers
9
(Q4.1)
11
Is there an Emergency Response Plan and does this refer to environment?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13); MYPD Environment Management Plan (Section 8.1.9); MYPD EMS Manual (Section 11)
Observation
provided and included
environmental procedures, such
Is there a register to record environmental incidents (e.g. spills)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EMS Manual (Section 6); MYPD EMS Manual (Section 15)
Compliant Environmental incident
13
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 14.1)
Observation
10
(Q4.1)
14
Has the project implemented procedures to manage the displacement of graziers from the site?
MYPD EIA (Section 9.4); MYPD EIA (Section 9.5); MYPD EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)
Compliant
considered of low agricultural
of camels from the peripheries
of the site boundary.
11
(Q4.1)
15 Air Quality Has an Air Quality Management Plan been prepared?
MYPD EMS Manual (Section 5,6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8) MYPD EIA (Section 9.4); MYPD EIA (Section 9.5) (Note: EIA Does not describe specifically about Air Quality Management Plan)
Compliant No change. None required. Compliant
16 Air Quality Has a Dust Control Plan prepared?
MYPD EMS Manual (Section 5,6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EIA (Section 9.4); MYPD EIA (Section 9.5); RC Volume I Section 2.3.7 and 2.3.8
12
(Q4.1)
Are fugitive emissions monitored (i.e. dust)?
MYPD EMS Manual (Section 12); MYPD EIA (Section 10.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.4.1); SAES-A-102
18 Air Quality
Are air quality monitoring reports submitted to Saudi Aramco PMT?
SAES-A-102 Compliant
to SA PMT will be reviewed for
air quality discussion during
MYPD EIA (Section 9.8.1); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3,23), SAES-A-102
20 Air Quality
Are vehicle wheels being cleaned when entering or exiting the construction site?
MYPD EIA (Section 9.8.1); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3) SAES-A-102
13
(Q4.1)
21 Air Quality
Are trucks carrying dry spoil and other waste covered during transportation?
MYPD EIA (Section 9.8.1); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); GERRI 2001 General Environmental Regulations (Article 2)
Compliant
However, large quantities of
spoil, primarily sand, were
observed uncovered within the
site. Additional spilling from
large gaps in the rear of the
truck bed, was noted.
22 Air Quality Are unpaved roads watered on daily basis?
MYPD EIA (Section 9.2); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant
14
(Q4.1)
23 Air Quality
Is a Vehicle Emissions Control Plan provided (e.g. prevention of vehicle idling)?
GAMEP Mobile Source Emissions (Article III) / EIA
24 Air Quality
Do vehicle and equipment performance tests meet vendor specifications prior to commencement of construction activities?
As above; and GAMEP Mobile Source Emissions (Article III)
Observation
the device is planned before
the end of October.
15
(Q4.1)
Is there emission rating/performanc e criteria for equipment utilized on-site?
GAMEP Mobile Source Emissions (Article III)
Observation
GAMEP standards.
26 Air Quality Black smoke emitted for plant or machinery?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3)
Observation
stages black smoke was being
emitted from the small set of
heavy plant on-site.
observed.
16
(Q4.1)
27 Air Quality
Are all stationery combustion engine exhaust emissions monitored for NOx, PM10 and SOx?
MYPD EMS Manual (Section 12); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8), GAMEP Mobile Source Emissions (Article III)
Observation
28 Air Quality
Are all mobile equipment maintained at the highest possible standard, and tested annually for emissions?
MYPD Environmental Management Plan (Section 8); SAES- A-102; GAMEP Mobile Source Emissions (Article III)
Compliant
29 Air Quality
Do Emissions from dredgers comply with standards for NOx and SOx prescribed in International Maritime Organization (IMO)?
MYPD EIA (Section 9.8.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3)
Compliant
17
(Q4.1)
30 Air Quality
Are material storage and loading / unloading areas located away from sensitive receptors
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); EMS Manual (Section 6); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant Confirmed in the areas
inspected. None required. Compliant
18
(Q4.1)
31 Noise Has a Noise Management Plan been prepared?
MYPD EMS Manual (Section 5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EIA (Section 9.4, 9.5) (Note: EIA Does not describe specifically about Noise Management Plan);SAES-A-105
Compliant
prepared and forms part of the
MYPD EMP.
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.5.1); MYPD EIA (Section 10.1);
Compliant Records previously inspected. None required. Compliant
33 Noise
Are all equipment, machinery and vehicles maintained in a good working condition?
MYPD EIA (Table 9.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13.2)
Compliant
emissions above.
19
(Q4.1)
GAMEP Environmental Noise (Article VII)
Observation
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EMS Manual (Section 6)
inspected. Continue to monitor. Compliant
36 Noise
Do all high noise plant and equipment have acoustic barriers fitted?
37 Noise Are acoustic barrier doors closed at all times?
20
(Q4.1)
Are noise barriers erected between noise sources and sensitive receptors?
MYPD EIA (Section 9.8.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3, 23)
39 Noise
MYPD EIA (Section 9.8.6); ); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3)
40 Noise
Are suitable staff resting areas available away from noise generating activities?
Compliant
locations inspected. However,
the pre-cast x-block area.
41 Noise
Is there a requirement to adhere to time restrictions for noisy activities?
SAES-A-105; Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EMS Manual (Section 6)
Compliant Records previously inspected. None required. Compliant
21
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13.2);
Compliant Not observed in the areas
MYPD EIA (Section 9.8.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3);
44 Noise Is plant turned off when not in use?
Are there any ecological sensitive receptors in proximity to site?
SAEP-396 (Section 2)
to 'save' two trees from the
main construction area and
Camp.
22
(Q4.1)
Ecology
Is there a requirement to prepare a Terrestrial Biodiversity Management Plan?
MYPD EIA (Section 9.8.4) (Note: EIA does not specifically state the requirement for a Terrestrial Biodiversity Management Plan\)
Compliant Previously inspected. No issues
noted during site visit. None required. Compliant
47 Terrestrial
MYPD EIA (Section 9.8.4)
48 Terrestrial
MYPD EIA (Section 9.8.4)
Archaeology and Cultural Heritage
49 Archaeology and Cultural
Heritage
Are there any archaeological / cultural heritage receptors in proximity to site
n/a Not
Not
applicable
23
(Q4.1)
Heritage
Is there a requirement to prepare a Cultural Heritage Management Plan
n/a Not
Not
applicable
n/a Not
Not
applicable
n/a Not
Not
applicable
Is there a Waste Management Plan (WMP) for the project?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); MYPD EMS Manual (Section 5)
Compliant WMP is in place and has been
provided. None required. Compliant
Management
Are waste management mitigation measures addressed in the EIA reflected in the WMP?
MYPD EIA (Section 7.4)
24
(Q4.1)
Management
Are copies of relevant Saudi Aramco Chemical Hazard Bulletins or Materials Safety Data Sheets provided?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.13); GI.150.100
Observation Confirmed in the areas
25
Management
As a waste generator are Waste Tracking Forms issued (Waste Manifest)?
MYPD EIA (Section 7.4, 7.3.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.7) Attachment VI; GAMEP Waste Regulatory Control and Compliance (Article III). GCC Unified Healthcare Waste Management Law.
Minor non-
jurisdiction. Bee'ah certificate
approval to dispose of medical
waste.
of transportation/disposal raise
for transportation/disposal of
boundary.
HUTA/SARCO:
discussed with the EC.
will be reviewed on
26
(Q4.1)
Are Waste Tracking Forms held on record for 5 years?
MYPD EMS Manual (Section 15); GAMEP Waste Regulatory Control and Compliance (Article III)
Compliant
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.7); RCER-2015- Volume-I (Section 5.8) GAMEP Waste Handling and Storage (Article IV)
Observation
therefore RC approval is
transportation/disposal of
boundary.
27
(Q4.1)
Is an approved waste receiving facility used?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.7); RCER-2015- Volume-I (Section 5.1.6); If RC approval for disposal outside of RC Industrial City: GAMEP Landfill Design and Operation
Compliant No change.
and confirmation that
they have an
operator’s licence
Management
Are waste materials transported outside the boundary of Industrial City for storage, treatment or disposal?
RCER-2015- Volume-I (Section 5.3.1)
primarily due to
transportation/disposal of
boundary.
28
(Q4.1)
Does waste generator record types, quantities and classification of wastes?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.12); RCER-2015- Volume-I (Section 5.2.5, 8); If RC approval for disposal outside of RC Industrial City: GAMEP Waste Regulatory Control and Compliance (Article II); GAMEP Waste Acceptance Criteria (Article II and Article III)
Minor non-
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); RCER-2015- Volume-I (Section 5.1.11)
Minor non-
mixed in multiple locations
block pre-cast yard, SARCO
jetty.
waste observed to be mixed in
an additional skip situated
storage area, near to the new
chemical storage area.
staff to promote the
correct use of waste
29
(Q4.1)
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); RCER-2015- Volume-I (Section 5.1.11); GAMEP Waste Handling and Storage (Article III)
Compliant
areas inspected.
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); RCER-2015- Volume-I (Section 5.1.11); RCER- 2015-Volume-I (Section 4.3.3, 5.1.10); GAMEP Waste Handling and Storage
30
(Q4.1)
Management
Is the hazardous waste storage area constructed on impervious surface such as concrete or asphalt?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6)
Management
Does the contractor demonstrate clear understanding of SAP EH&S Module requirements for manifesting of hazardous waste and recordkeeping?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management System (Section 10.11.1); MYPD EMS Manual (Section 15); GI 430.001
Compliant Previously discussed, no
change. None required. Compliant
Management
Are storage areas clearly marked and signed with regard to the quantity and hazardous characteristics of the wastes stored therein
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.11); RCER-2015- Volume-I (Section 4.3.16)
Minor non-
vehicle servicing area. In
addition these were without
31
(Q4.1)
Are storage areas well maintained and subject to good housekeeping?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment V)
Compliant
majority of skips were noted to
be full or overflowing.
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (10.10, Attachment V; RCER-2015- Volume-I (Section 4.3.26, 4.4.4, 4.4.5, 5.3.5, 5.3.9)
inspected.
32
(Q4.1)
Compliant Confirmed. None required. Compliant
71 Waste
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12.6); MYPD EMS Manual (Section 6); RCER- 2015-Volume-I (Section 4.3.20); GAMEP Waste Handling and Storage (Article XIV)
Compliant
33
(Q4.1)
Are spill kits available in waste storage areas?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6); MYPD EIA (Table 9.6); RCER-2015- Volume-I (Section 4.3.3, 4.3.19); GAMEP Waste Handling and Storage (Article XIV)
Management
Are hazardous wastes removed off-site within 180 days? The 180 days shall include the storage period of wastes at the premises of generating facility and the disposal facility
MYPD EIA (Section 7.4)(EIA States 90 days) GAMEP Waste Handling and Storage (Article VI);
Compliant Confirmed. None required Compliant
74 Waste
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23); SAEHC-S-03 (Section 5.1)
Observation
Uncovered skips were being
used for food waste.
34
(Q4.1)
Management
Is recycling and reuse addressed and implemented for specific waste streams that can be recycled?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.4); RCER-2015- Volume-I (Section 5.3.2)
Observation
materials could be added to the
weekly project dashboard
reviewed.
Management
Are waste generators (within the construction site) trained on implementing the WMP?
MYPD EIA (Section 10.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 14.1, Table 14.1); MYPD EMS Manual (Section 7)
35
(Q4.1)
Management
Does the hazardous waste storage area have a secondary containment system to control any leaks or spills?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6); RCER Volume I (Section 4.3.7); GAMEP Waste Handling and Storage (Article IX)
Management
Are non- compatible hazardous wastes stored in the same area or separately?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Table 14.1); RCER-2015- Volume-I (Section 4.3.6); GAMEP Waste Handling and Storage (Article III)
Compliant Confirmed is the areas
36
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment V); MYPD EMS Manual (Section 6); RCER- 2015-Volume-I (Section 5.6.2) SAES-S-007 (5.3.3)
Compliant No burning of waste observed. None required. Compliant
80 Waste
Do above-ground hazardous waste storage tanks have secondary containment systems?
MYPD EIA (Section 7.4); MYPD EMS Manual 6.5.6; RCER-2015- Volume-I (Section 4.3.7); GAMEP Waste Handling and Storage (Article IX)
Do underground hazardous storage tanks have secondary containment systems?
MYPD EIA (Section 7.4); MYPD EMS Manual 6.5.6; RCER-2015- Volume-I (Section 4.5.1); GAMEP Waste Handling and Storage (Article IX)
Observation
37
(Q4.1)
Wastewater
82 Wastewater
Has a Wastewater Management Plan (WWMP) been prepared for the project?
MYPD EIA (Section 7.3.2,7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8), MYPD EMS Manual (Section 6)
Compliant Included in WMP. None required. Compliant
83 Wastewater
Are the types, sources and quantities of generated wastewater provided?
MYPD EIA (Table 7.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Plan (Section 20.1, 10.10); RCER-2015- Volume-I (Section 3.4.15, 3.8.6); GAMEP Waste Regulatory Control and Compliance (Article III); GAMEP Waste Acceptance Criteria (Article II)
Minor non-
Camp
84 Wastewater
If raw sewage is disposed off-site is an EPD waiver in place?
SAES-A-104 (Section 5.1.1.2 f); SAEHC-02 (Section 3.1.2)
Minor non-
38
(Q4.1)
85 Wastewater
Is there a procedure to report overflowing holding tanks to Saudi Aramco EPD?
MYPD EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); SAEHC-02 (Section 3.3.4.3)
Observation
occur consider implementing
Are Waste Manifest Forms held for disposal of sanitary wastewater?
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment VI); RCER-2015- Volume-I (Section 5.2.1, 5.2.5); GAMEP Waste Regulatory Control and Compliance (Article III); SAEHC-02 (Section 3.3.4.4);
Minor non-
STP signing/stamping for the
signatures/stamps for
wastewater
transporter.
39
(Q4.1)
87 Wastewater
Is a Water Disposal Plan and Water Disposal Request Form required (Water Disposal Approval Form been submitted to EPD 60 days prior to disposal of hydro-test wastewater)?
the project. None required
89 Wastewater
Is wastewater discharged to an evaporation pond and does the pond(s) meet Saudi Aramco design requirements?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment VII); SAES-A-104 (Section 15)
Compliant
construction areas.
advice directly from
40
(Q4.1)
90 Wastewater
Is wastewater reused on site and is this approved by Saudi Aramco EPD?
MYPD EIA Section (9.8.3); SAES-A- 104 (Section 14); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 20.1); SAEHC-02 (Table 1 and Table 16); GERRI 2001 General Environmental Regulations (Article 2)
Not
Not
applicable
91 Wastewater
Is there any discharge of wastewater to marine waters? Discharges approved by EPD?
MYPD EMS Manual (Section 13); SAES-A-104 (Section 15)
Compliant No change, previously
41
(Q4.1)
92 Wastewater
Is there any discharge to land and if so, permitted by Saudi Aramco EPD?
MYPD EMS Manual (Section 13); SAEHC-02; SAES-A- 104; GAMEP Industrial and Municipal Wastewater Discharges (Article II + IV)
Compliant
stopped as per previous
holding tanks for pre-cast
concrete wastewater are on
be used to store and treat
(coagulants) larger quantities of
general site activities, e.g. dust
suppression. This will vastly cut
down on the wastewater
HUTA/SARCO:
Are there procedures for monitoring effluent wastewater?
MYPD EIA (Table 10.2); MYPD EIA (Section 9.8.3); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9, Table 14.1); RCER-2015- Volume-I (Section 8.2.2); SAES-A-104 (Section 5.4); SAEHC-02 (Section 2)
Compliant
effluent to the marine
SAES-A-104 (Section 5.4)
42
(Q4.1)
MYPD EIA (Section 9.8.3); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.11); Saudi Aramco Water Conservation Policy INT-11
Observation
prepared.
could be matched to
the new inventory of
Compliant No change, not required at this
stage of the project. None required. Compliant
43
(Q4.1)
Groundwater
Has a Groundwater Protection Plan (GWPP) been prepared for the project?
MYPD EIA (Section 10, Table 10.2); MYPD EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); GERRI 2001 General Environmental Regulations (Article 2)
Compliant
contamination only.
Groundwater
Is groundwater used during construction, and if so, has a permit from Saudi Aramco EPD been approved
MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); RCER 2015; Saudi Aramco Water Conservation Policy INT-11
Compliant
Is a Drainage and Dewatering Plan required and in place?
SAES-A-114 Observation
land reclamation works.
44
(Q4.1)
Groundwater
Are quantities and quality of the water consumption monitored (e.g. site preparation, potable water)?
MYPD EIA (Table 10.2), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9); MYPD EMS Manual (Section 12); RCER-2015- Volume-I (Section 3.13.1)
Compliant Reported monthly to SA PMT. None required. Compliant
101 Soil &
Not
applicable
construction
45
(Q4.1)
Is quantity / quality of wastewater reinjection to groundwater aquifer monitored?
GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Not
Not
applicable
103 Fuels and Chemicals
Are all fuel and oil stored within a bund / secondary containment?
MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6); RCER-2015- Volume-I (Section 4.3)
Minor non-
vehicle servicing area and at
the finger jetty. Tamimi: Initial
works observed to install
MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 14.1, Table 14.1, 21.3); RCER-2015- Volume-I (Section 4.3)
46
(Q4.1)
Are there procedures for inspecting and testing the integrity of above- ground storage tanks?
MYPD EIA (Section 9.4, 9.5); MYPD EMS Manual (section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)
Compliant Previously inspected,
confirmed. None required. Compliant
Are there procedures for inspecting and testing the integrity of below ground storage tanks?
MYPD EIA (Section 9.4, 9.5)(Note: EIA does not specifically describe about procedure); MYPD EMS Manual (section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); RCER- 2015-Volume-I (Section 4.5.4)
Observation
contractor to check the
integrity of below ground
although no change from
Does refuelling take place in a sealed area with impermeable surface?
47
(Q4.1)
Are refuelling vehicles and equipment inspected and maintained to reduce the risk of leaks and spills?
MYPD EIA (Section 8); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section14); EMS Manual (Section 12)
Compliant
regular inspections.
Is fuel transfer equipment and methodology acceptable?
MYR EMS Manual (Section 6.0); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)
Are spill kits available at all fuel storage and refuelling points?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8, 21.3); MYPD EIA (Section 9.8.2); MYR EMS Manual (Section 2); RCER-2015- Volume-I (Section 4.3.19)
Observation
area next to one of the main
generators (Generator 2).
Corrective action was
48
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); MYPD EMS Manual (Section 13)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); MYPD EMS Manual (Section 13)
Compliant
area.
HUTA/SARCO:
Are spill kits carried on refuelling vehicles?
MYPD EMS Manual (Section 2,10, 13); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23);
Compliant
the greasing truck,
49
(Q4.1)
Is there a plan for inspecting completeness and availability of spill kits?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 14.5); MYPD EMS Manual Section 6.0); RCER-2015- Volume-I (Section 4.3.20)
Compliant
part. Tamimi held the checklist
in the office although this was
moved to be with the relevant
spill kit during the inspection.
Are hazardous materials stored a min of 50m from drains / wells / water bodies?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6)
Are Saudi Aramco Chemical Hazard Bulletins / Material Safety Data Sheets available in chemical storage areas?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 10.14)
Observation
locations across the site.
However, MSDS sheets and
SARCO chemical storage area.
50
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environment Management Plan (Section 6.5.6), MYPD EMS Manual Section 6.0); RCER-2015- Volume-I (Section 4.3.15, 4.3.16)
Compliant
segregated.
Compliant
Saudi Archirodon / Huta Hegerfeld MYPD Environment Management Plan (Section 6.5.6), MYPD EMS Manual Section 2)
Saudi Archirodon / Huta Hegerfeld MYPD Environment Management Plan (Section 6.5.6), MYPD EMS Manual Section 2)
Not
inspected
inspected.
HUTA/SARCO:
51
(Q4.1)
Do storage areas have adequate space for vehicle manoeuvring to prevent accidental damage to storage vessels / containers?
MYPD EMS Manual (Section 5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12)
GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Not
inspected
container were open and at
least one of the AC units in the
container was not working.
Do all chemical containers (at point of use) have drip trays?
MYPD EMS Manual (Section 2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.15); GERRI 2001 General Environmental Regulations (Article 2)
Not
inspected
52
(Q4.1)
Do all chemical containers (at point of use) have spill kits?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8, 21.3); MYPD EIA (Section 9.8.2); MYR EMS Manual (Section 2)
Stationary diesel and petrol operated equipment have impervious drips trays?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8), MYPD EMS Manual (Section 8)
53
(Q4.1)
Compliant
the spill was as a result of
maintenance works earlier in
the day although no
Management
Is there a procedure for managing and reporting marine spills (e.g. chemical, oil etc)?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23), RCER Volume I 3.10
Not
inspected
MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant
block pre-cast area was
from cleaning/leakage or
site visit.
54
(Q4.1)
Is septic / holding tank overflow prevented?
MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); SAEHC-02 (Section 3.3.4.2)
MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SAES-A-104
Compliant
block pre-cast area was
from cleaning/leakage or
site visit.
55
(Q4.1)
Management
If plant washing is taking place is it on a hard standing with collection tank?
Not
applicable
on site. None required.
MYPD EIA (Section 9.8.2); Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant Confirmed at the SARCO
vehicle servicing area. None required. Compliant
135 Spill
MYPD EIA (Section 9.8.2); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
56
(Q4.1)
Are components containing refrigerants stored correctly to prevent damage and release?
MYPD EMS Manual (Section 6), MYPD Environmental Management Plan (Section 8)
Not
Not
applicable
MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.3, 23) GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
57
(Q4.1)
Does the project implement ‘Just on Time’ procurement and delivery?
Not
inspected
surrounding GCC countries and
timeframes on demand.
MYPD EMS Manual (Section 12), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.13,10.16,12.1, 13.2); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant Confirmed and monthly reports
are sent to SA PMT None required Compliant
58
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.10); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SA Water Conservation Policy INT-11
Compliant Confirmed and monthly reports
are sent to SA PMT None required Compliant
141 Resource
Is there a programme to promote water and energy conservation?
MYPD EIA (Section 9.8.3); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.11); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SA Water Conservation Policy INT-11
Observation
59
(Q4.1)
Is there a programme to promote material recycling and reuse?
MYPD EMS Manual (Section 5); MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.4)
Observation
materials could be added to the
weekly project dashboard
reviewed.
Management
Is there a programme to inspect water storage tanks and pipes to minimize leakage?
MYPD EMS Manual (Section 5) MYPD EIA (Section 9.8.5, Table 9.6); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SA Water Conservation Policy INT-11
Compliant
Are material / aggregate stockpiles suppressed to minimise dust emissions?
SAES-A-102 (5.17); MYPD EIA (Section Table 9.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3),
60
(Q4.1)
Black smoke emitted from plant or machinery?
MYPD EIA (Section 10.1, Table 10.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9); MYPD EMS Manual (Section 12)
Compliant No black smoke emissions
observed at the batching plant. None required. Compliant
146 Batching
MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan
Plant
As a waste generator are Waste Tracking Forms issued (Waste Manifest)?
MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6); RCER-2015- Volume-I (Section 4.3)
Compliant
ambiguity surrounding the
tracking systems in place.
Al Kifah: It was
61
(Q4.1)
Plant
Are all fuel and oil stored within a bund / secondary containment?
MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 14.1, Table 14.1, 21.3); RCER-2015- Volume-I (Section 4.3)
MYPD EIA (Section 9.8.7); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.10); GAMEP Waste Handling and Storage (Article IV)
Compliant
from designated storage areas
beneath the batching plant
and the drip trays provided
were overflowing.
designated and
Are storage areas well maintained and subject to good housekeeping?
SAEHC-S-03 (Section 5.1)
an example, boxes of fibrous
material required for the
batching process were stored
sunlight, against clear
keep covered and within
62
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Plant
Are spill kits available at all fuel storage and refuelling points?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
63
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 10.14);GI.150.100 (Section 4.1); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant
provided next to the additional
chemical storage area being
used beneath the batching
Plant
Are Saudi Aramco Chemical Hazard Bulletins / Material Safety Data Sheets available in chemical storage areas?
MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.13); GI.150.100
Compliant
batching plant building
stored beneath the batching
64
(Q4.1)
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant Confirmed None required Compliant
156 Batching
Are fuel / chemical spills and contaminated ground remediated?
MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); SAEHC-02 (Section 3.3.4.2); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
Compliant No fuel/chemical spills
65
(Q4.1)
Major non-
inspected.
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.2);GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5
66
(Q4.1)
Plant
Are construction materials stored and handled to minimize releases to ground?
SAES-A-102 (5.17); MYPD EIA (Section Table 9.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3),
Operations
Is there a requirement to prepare a Dredging and Reclamation Environmental Management Plan?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Annex I)
Compliant Yes, this has been inspected. None required. Compliant
161 Off-Shore
Has a silt screen been installed to prevent sediment dispersion?
MYPD EIA (Table 9.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 20); RCER-2015- Volume-I (Section 6.1.3)
Compliant
mitigate the dispersion of
67
(Q4.1)
Operations
Have controls and contingency measures been prepared for the following: Sediment characteristics; marine flora and fauna; water quality; waste management; spill response and emergency procedures; and air and noise?
Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan Annex I (Section 20); MYPD EMS Manual (Section 6)
Compliant
the dredging plan and the EMS
documentation
Operations
Is monitoring of turbidity in the areas outside the area of dredging recorded / retained?
MYPD EIA (Table 9.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9); MYPD EMS Manual (Section 12)
Compliant
levels exceed 4.5 NTU
Operations
Is a marine wildlife monitoring program adopted during dredging to monitor for their presence each day?
MYPD EIA (Section 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Table 14.1); RCER-2015- Volume-I (Section 6.1.2)
Compliant
68
(Q4.1)
Operations
Is marine equipment, including dredgers, inspected and maintained (e.g. prevent spills, leaks; emissions comply with standards)? NOTE: Emissions from dredgers shall comply with the standards for NOX and SOX prescribed by the International Maritime Organization (IMO)
Compliant
checklist. Records were
visit. No inspection for vehicles
or engines. The primary
monitoring (for vehicles,
Compliant Confirmed from on-shore
None required but to
Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12.5)
Not
inspected
Compliant
marine vessels.
69
(Q4.1)
Operations
Do incoming vessels have third party analysis of ballast water indicating the absence of the species as listed by International Maritime Organization (IMO)?
International Maritime Organization Ballast Water Management Convention 2004
Not
inspected
marine team.
Operations
Do vessels comply with MARPOL Annex I (Regulations for the Prevention of Pollution by Oil)?
The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex I)
Minor non-
used instead.
None required.
Operations
Do vessels comply with MARPOL IV (Prevention of Pollution by Sewage from Ships)?
The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex IV)
Compliant
which discharges to sea after
treatment. ALS Arabia collect
discharged to sea.
None required Compliant
Operations
Do vessels comply with MARPOL V (Prevention of Pollution by Garbage from Ships)?
The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex V)
Compliant
approved landfill. Waste
manifests are available.
None required Compliant
70
(Q4.1)
Operations
Do vessels comply with MARPOL VI (Prevention of Air Pollution from Ships)?
The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex VI)
Not
inspected
emissions testing equipment to
71
Ref Photographic Evidence: Notes:
72
67
hazardous waste storage areas at SARCO vehicle
servicing area.
yard.
73
SAPMT Camp.
149
74
site and replant it in front of SAPMT Camp