REPORT

Preliminary Environmental, Health, and Safety

Review (PEHSR)

Caustic Soda Plant ICAD 1

Prepared for:

Al Ghaith Industries

Prepared by:

URS Corporation Abu Dhabi

44130065
August 2011

Project Title:

Caustic Soda Plant ICAD 1

Report Title:

Preliminary Environmental, Health, and Safety Review (PEHSR)

Project No:

44130065

Report Ref:

44130065-REP-001

Status:

Initial Issue

Client Contact Name:

Almamoon Al-Baadani

Client Company Name:

Al Ghaith Industries
URS Corporation Abu Dhabi

Issued By:

Document Production / Approval Record

Issue No:

Name

Signature

Date

Position

Prepared
by

David Monaghan

Air Quality Scientist

Checked
and
approved
by

Andrew J Wilson

Principal Consultant

Document Revision Record

Issue No

Date

Details of Revisions

?? August 2011

Draft PEHSR Issued

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page i

LIMITATION
URS has prepared this Report for the sole use of in accordance with the Agreement under which our
services were performed. No other warranty, expressed or implied, is made as to the professional
advice included in this Report or any other services provided by us. This Report may not be relied
upon by any other party without the prior and express written agreement of URS. Unless otherwise
stated in this Report, the assessments made assume that the sites and facilities will continue to be
used for their current purpose without significant change. The conclusions and recommendations
contained in this Report are based upon information provided by others and upon the assumption that
all relevant information has been provided by those parties from whom it has been requested.
Information obtained from third parties has not been independently verified by URS, unless otherwise
stated in the Report.

COPYRIGHT
This Report is the copyright of URS Corporation Limited. Any unauthorised reproduction or usage
by any person other than the addressee is strictly prohibited.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page ii

CONTENTS
Section
1.
INTRODUCTION

Page No
18

1.1.
1.2.
1.3.
1.4.

Summary
Error! Bookmark not defined.
Need for Project
18
Policy and Standards 23
Scope 24

2.

PROJECT DESCRIPTION

2.1.
2.1.1.
2.1.2.
2.1.3.
2.1.4.
2.1.5.
2.1.6.
2.1.7.
2.1.8.
2.1.9.
2.1.10.
2.1.11.
2.1.12.
2.1.13.
2.1.14.
2.1.15.
2.1.16.
2.1.17.
2.1.18.
2.1.19.
2.1.20.
2.1.21.
2.1.22.

Overview
27
Unloading and Storage of Salt 39
Brine Purification Process
40
Electrolysis Process
44
Brine Dechlorination
46
Hydrogen Gas Processing
47
Chlorine Gas Cooling 47
Caustic Concentration & Flaking Plant 47
Sodium Hypochlorite Plant
49
Hydrochloric Acid Plant 51
Demineralized water system 52
Cooling water unit
52
Chilled water system 53
Compressed air system
53
Steam supply system 53
Control and instrumentation system
53
Bagging Unit 54
Transportation System 54
Facility Construction
54
Air Emissions Control 55
Wastewater Treatment and Management
58
Solid Waste Treatment and Management
59
Fire and Toxic Gas Release Prevention and Control

3.

ENVIRONMENTAL BASELINE CONDITIONS 62

3.1.1.
3.1.2.
3.1.3.
3.1.4.
3.1.5.
3.1.6.
3.1.7.
3.1.8.
3.1.9.
3.1.10.

General Environmental Setting 62

Seismicity
62
Regional Meteorology 63
Air Quality
63
Terrestrial Ecology
68
Marine Ecology68
Soil and Groundwater Baseline Assessments 68
Socio-economic Environment 69
Noise Quality 73
Archaeological, Paleontological and Cultural Heritage Baseline Conditions
73

4.

IDENTIFICATION OF POTENTIAL ENVIRONMENT, HEALTH, AND SAFETY

HAZARDS AND IMPACTS
74

4.1.

Air Emissions 74

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

27

60

Project Number 44130065

Page i

CONTENTS
Section

Page No

Appendix A Figures
Photographs

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page ii

1.

EXECUTIVE SUMMARY
TBC

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 1

2.

INTRODUCTION
2.1.

Project Title and Project Proponent

The title of the proposed Project is the Development of a Chlor-Alkali Plant at ICAD-1
termed throughout this document as Chlor-Alkali Project. The Project is being
developed by Al Ghaith Industries (Al Ghaith). As the nominated proponents for this
project, the name, address, telephone number, and fax number of Al Ghaith is shown
below.
Al Ghaith Industries - Abu Dhabi
Almamoon Al-Baadani
General Manager
Al Ghaith Industries
PVD Salt
P.O.Box : 35119
1D1, Industrial City of Abu Dhabi (ICAD)
Musaffah, ,Abu Dhabi, U.A.E.
Tel : + 971 2 5502500
Fax : + 971 2 5502728
Email: [email protected]

2.2.

PER Consultants
URS Corporation Abu Dhabi (URS) has prepared this Preliminary Environment, Health
and Safety Review (PEHSR) on behalf of the Project proponents, Al Ghaith. The PEHSR
has been produced in accordance with the Environment Agency Abu Dhabi (EAD)
Technical Guidance Document for Preliminary Environmental Review (PER), and
Zonescorp Code of Practise on Environmental Health & Safety Impact Assessment
(EHS04). URS is an EAD-registered Class-A Environmental consultant. The name,
address, telephone number, and fax number of URS are detailed below:
URS Corporation Abu Dhabi
Mr Peter Mueller
Country Manager - UAE
102 Al Dhafra Tower
Istiqlal Street,
PO Box 43855, Abu Dhabi,
United Arab Emirates
Tel: +971 2 634 3365
Fax: +971 2 634 3374
Email: [email protected]
www.urscorp.eu

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 2

This PEHSR was prepared by Mr. David Monaghan (Air Quality Scientist) and reviewed
by Mr. Andrew J Wilson (Principal Consultant). In addition to the above-mentioned project
team, URS have drawn upon other professional and technical staff in our Abu Dhabi office
including: Dominic Adams (Senior Geologist), and Angela Nicholson (Environmental
Scientist). We can provide additional resources, including US-based environmental and
engineering professionals as requested. The primary contact within URS for the ChloroAlkali Project is:
Mr. David Monaghan, Project Manager
Email: [email protected]
URS has extensive experience in undertaking large-scale, complex environment, health
and safety impact assessments across a wide range of sectors and has a long history of
providing innovative, cost-effective solutions to our clients engineering and environmental
needs. URS has strong capabilities in the areas of:

Air Quality Management;

Environmental compliance;

Soil and groundwater site assessments;

Soil and groundwater remediation;

Human health risk assessments;

Decontamination and decommissioning;

Geosciences and risk management;

Environmental Impact Assessment;

Health, Safety and Environmental Impact Assessment (HSEIA);

Hazardous waste management;

Noise and acoustic services; and

Regulatory and permitting affairs.

The project staff has extensive experience in providing Environmental Consulting

services. Below are the individual team members fields of expertise.
Mr. David Monaghan
David Monaghan has six years experience as an Environmental Scientist specialising in
Air Quality, Environmental Impact, and Quantitative Risk Assessment. David joined URS
Corporation Abu Dhabi in June 2011, after spending five years as an Environmental
Scientist in the UK. David has expertise in characterising the air pollution impacts using

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 3

dispersion modelling packages (such as AERMOD/ ADMS) in support of EIA/HSEIA work

in the oil and gas, land development and heavy industry sectors. He is an experienced
project manager and has lead various environmental assessments across a broad range
of industrial activities for private and government organisations focusing on air quality
monitoring/ modelling, environmental permitting and due diligence.
Mr. Andrew J Wilson
Andrew Wilson PhD PE - Dr. Wilson is a Senior Principal in the URS Abu Dhabi Office
and has over 30 years of experience in the oil and gas, heat transfer, power, and
pharmaceuticals from both industrial and academic perspectives. He has managed or
directed a number of EIA activities encompassing Oil and Gas, Power, and Water projects
in the UAE, Qatar, Azerbaijan, and Saudi Arabia. He has performed engineering studies
and designs for fired heaters, water and wastewater treatment systems, and industrial
hazardous and NORM waste treatment and disposal. He previously worked for Black &
Veatch Consulting Engineers in the Power Division Chemical Engineering Department,
responsible for the design of power plant water and wastewater treatment systems. He is
very knowledgeable in the field of oil and gas facility and power plant design. Likewise, he
is knowledgeable in the areas of project management, process engineering and
modelling, design and operation of heat transfer equipment, industrial water/wastewater
treatment and Carbon Capture and Storage (CCS). He has managed large EIA projects
within the region and he is very familiar with the environmental licensing processes within
the region.
Mr. Dominic Adams
Dominic Adams is a Senior Geologist in the URS Abu Dhabi office with over ten years
experience as a consultant. During his career Dominic has gained extensive project
management experience for a wide range of projects including environmental impact
assessments (EIAs), geotechnical studies and contaminated land assessments for
commercial and industrial developments in the UK, Italy, Qatar and the UAE. His
responsibilities include project planning, design and coordination of field studies, and the
preparation and review of EIA reports.
Ms. Angela Nicholson
Angela Nicholson is an Environmental Scientist in URS Abu Dhabi office. Angela has an
interdisciplinary background in environmental sciences and has worked on a broad range
of projects across UAE, wider Middle East, and the UK. During her career Angela has
proven experience as a highly effective and organised project manager and coordinator
for numerous projects as well as being responsible for preparing environmental and
social impact assessment reports, managing field studies, and providing technical advice
to clients in sectors including oil and gas sector, power generation, industrial, coastal
defence, and port developments.
Angela has previously worked on a diverse range of projects, including EIA, Appropriate
Assessment, niche modelling, research and development, information dissemination, and
social inclusion projects. During her career, Angela has fulfilled a number of roles

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 4

including ecological surveyor, technical advisor, lead author, and project manager. She
has worked with a variety of stakeholders and clients including government agencies,
private companies, and non-governmental organizations in a variety of sectors, and also
has a strong background in environmental and technical reporting and analysis.

2.3.

Project Description and Rationale

URS is pleased to provide this PEHSR study for development of a Chlor-Alkali Plant
(hereafter referred to as the Project) proposed to be established by Al Ghaith within the
ICAD-1 area, Musaffah.
The plant will produce Caustic Soda / Liquid (32% concentration), by-products-Chlorine
gas and Hydrogen gas, Caustic Concentrate (50% NaOH), Caustic Flakes, Hydrochloric
acid and Sodium Hypochlorite. Chlorine gas shall be processed through cooling. Sodium
Hypochlorite shall be produced as a by product under Waste Air Dechlorination
(environmental control measures).
The main products and the planned production capacity of the proposed plant are as
follows:

Product

Capacity per
day

Capacity per year

HCl - 32% w/w solution

179 MT / Day

59,000 MT/Year

Caustic Soda -100%

70 MT/ Day

23,100 MT/Year

Sodium Hypochlorite 12%

70 MT/ Dat

23,100 MT/Year

This PEHSR study will focus on construction, commissioning and operation of the
Project, and will culminate in the submission of this report to Zonescorp and EAD for
review and approval.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 5

2.4.

Justification and Chronology for the Development of a PER

By completing this PEHSR URS and Al Ghaith have been able to effectively assess the
associated risks and provide a definite solution to all environmental, health and safety
risks that are present in constructing and operating the Chlor-Alkali Plant. As such, a
more detailed costly EIA is not necessary.
The objectives of the PEHSR are specified in the relevant legislation and guidance
outlined in Section 3. The PEHSR report demonstrates that in relation to the subject
Project facility, site or activities:
a. That all EHS hazards have been systematically identified in the Hazards & Effects
Register (HER), inclusive of relevant risk classification (e.g. High, Medium and Low)
or in accordance with principles that are compatible with those provided in Zonescorp
CoP on EHS Risk Management (CoP EHS03).
b. That all environmental impacts have been identified, suitably analysed and assessed
for significance. It must be demonstrated that relevant control, mitigation and
recovery measures are proposed (for projects), are implemented (for existing facilities
or operations) or an implementation plan exists for implementation.
c.

That all accident hazards have been identified and suitable control, mitigation and
recovery measures are proposed (for projects) or are implemented (for existing
facilities or operations). It must be demonstrated that operation can be achieved
within the Zonescorp quantitative criteria for risk tolerability and compliance with As
Low As Reasonabliy Practicable (ALARP) must be demonstrated in accordance with
principles that are compatible with those provided in Zonescorp CoP on EHS Risk
Management (CoP EHS03).

d. That all Occupational Health Risks have been systematically identified and suitable
action to mitigate these risks and to protect employees from these risks have been or
will be taken in accordance with Zonescorp CoP on EHS Risk Management (CoP
EHS03).
e. How all HSE risk - including that resulting from moderate and low risk hazards - will be
managed and controlled by Al Ghaith or project/site/operations specific EHS
Management Systems. Refer to Zonescorp CoP on EHS Management Systems (CoP
EHS02).
f.

That Emergency Response Plans (on-site and off-site where necessary) in relation to
Major Accident Hazards have or will be prepared based on credible emergency
scenarios, with the necessary stakeholder consultation. Refer to Zonescorp CoP on
Crisis Management Plan (CoP FE05).

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 6

In order to complete this PEHSR the following schedule has been followed. A project
Gantt Chart is shown in Table 2- 1 -1.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Kick Off Meeting July 2011;

HAZID/ENVID July 2011;

Development of Hazard Effects Register August 2011;

Completion of PEHSR and submission to Al Ghaith August 2011;

Submission of PEHSR to Zonescorp August 2011; and

Submission of PEHSR to EAD September 2011.

Project Number 44130065

Page 7

Table 2-1-1 Project Schedule

The following provides a proposed project schedule with best estimates provided for Al Ghaith, Zonescorp, and EAD review periods
based on previous experience.
Task

Sub-Task
1

Kick Off Meeting (1 day)

HAZID/ENVID Workshop (2
days)
HAZID/ ENVID Register

PEHSR Study Report

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Draft Spreadsheet to Al Ghaith

Al Ghaith Review and Comment
Draft Report
Al Ghaith Review and Comment
Final Draft Report
ZonesCorp Review and Comment
Final Report
EAD Review and Comment
Final Report (Issue 2 if
necessary)
EAD Approval

Project Number 44130065

Page 8

10

11

Week
12 13

14

15

16

17

18

19

20

21

22

3.

LEGAL FRAMEWORK AND STANDARDS

This section outlines the key environmental regulations in the UAE that will be considered
both in terms of the scope and nature of the PEHSR, and in the overall construction and
operation of the proposed Project.

3.1.

Specific Environmental Standards and Guidelines relevant to the

Chloro-Alkali Project
The Al Ghaith PEHSR will assess relevant factors against applicable EAD and Zonescorp
guidance. In the absence of specific UAE criteria levels, applicable International
Standards shall be applied.
The following regulations and standards were followed whilst carrying out this study.

3.2.

Zonescorp CoP on EHS Management Framework (EHS 01);

Zonescorp CoP on EHS Management Systems (EHS 02);

Zonescorp CoP on EHS Risk Management (EHS 03);

Zonescorp CoP on EHS Impact Assessment (EHS 04);

Zonescorp CoP on Practise on Crisis Management Plan (FE 05);

EAD Technical Guidance Document for Preliminary Environmental Review (PER)

(April 2010);

Abu Dhabi Emirate EHS Management System Manual;

Abu Dhabi Emirate Environmental Protection Policies (EEPPs); and

EAD Standard Operating Procedures for Permitting of New Projects and Activities
in Abu Dhabi.

National Laws, Standards, and Guidelines

The Ministry of Environment and Water (MOEW) is the Competent Authority responsible
for implementing federal law in the UAE. The MOEW, formally the Federal Environmental
Agency (FEA) established in 1993, is the principal environmental institution in the UAE.
The MOEW develops environmental policies that are implemented and enforced as a
minimum level of environmental due diligence by the various member Emirates within

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 9

their area of jurisdiction. In Abu Dhabi, the competent environmental authority is

Environmental Authority Abu Dhabi (EAD).
Principal federal environmental and social laws that are relevant to this Project include:

Ministry of Labour and Social Affairs Federal Law No. (8) of 1980;

Ministry of Labour and Social Affairs Ministerial Order No. (32) of 1982;

Federal Law No. (7) of 1993 concerning the establishment of the FEA;

Federal Law No. (23) of 1999 Concerning exploitation, conservation, and

development of living aquatic resources in the United Arab Emirates and its
Executive Order issued by Ministerial Decree No. (302) of 2001.

Federal Law No. (24) of 1999 for the Protection and Development of the
Environment and subsequent Decree No. (37) for 2001 Executive Guidelines for
Federal Law No 24 of 1999, concerning Environmental Protection &
Development prescribing regulations pertaining to the following systems:
o

Impact Assessment of Projects;

Protection of the Marine Environment;

Handling of Hazardous Substances, Hazardous Wastes and Medical

Wastes;

Protection of Air from Pollution.

Agricultural Pesticides, Agricultural Conditioners and Fertilizers; and

Protected Areas.

Federal Law No. (21) of 2005 for Waste Management in the Emirate of Abu Dhabi;

Federal Law No. (16) of 2005 concerning the reorganization of the Abu Dhabi
Environment Agency, replacing Federal Law No. (4) of 1996 as amended by Law
No. (1) for 1997, specifying EAD as the competent body for implementing federal
environmental law; and

Federal Law No. (12) of 2006 for Air Pollution Protection.

Of these Federal Law No. (24) for 1999 provides the overarching framework for
environmental considerations in the UAE. This law aims to achieve the following goals:

Protection and conservation of the quality and natural balance of the environment.

Control of all forms of pollution and avoidance of any immediate or long-term

harmful effects resulting from development.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 10

Development of natural resources and conservation of biological diversity in the

region and the exploitation of such resources with consideration of present and
future generations (i.e. the principle of Inter-generational Equity).

Protection of society, human health and the health of other living creatures from
activities and acts that are environmentally harmful or impede authorized use of
the environmental setting.

Protection of the UAE environment from the harmful effects of activities undertaken
outside the region of the UAE.

Compliance with international and regional conventions ratified or approved by the

UAE regarding environmental protection, control of pollution and conservation of
natural resources.

In addition to the requirements of Federal Law 24, a number of Executive Regulations

deal with specific environmental areas, including:

Regulation for the Environmental Effects of Installations. This regulation requires an

EIA to be carried out for certain projects before an Environmental License to
develop and operate the project is issued by the Competent Authority.

Regulation for the Protection of the Maritime Environment. This is concerned with
the prevention of pollution of the marine environment from vessels, land based
sources and offshore platforms.

Furthermore the Executive Guidelines for Federal Law No. (24) for 1999, Concerning
Environmental Protection and Development, Decree No. (37) for 2001, states the
requirement to have a permit for new projects through EAD, and also states that
when analyzing the expected environmental reactions, the following elements must
be taken into consideration when conducting and EIA:
A) Any environmental impact on the ecological system that might get affected by the
project / activity.
B) Any impact on an Area/Place/or building that has an archaeological, amusement,
architectural, cultural, historical, scientific, or social values, or has other environmental
characterizes that form a value for the existing or future generations.

3.3.

Abu Dhabi Emirate and Local Laws, Standards and Guidelines

EAD is the nominated authority for implementing Federal Environmental Law in Abu
Dhabi in accordance with:

Federal Law No. (24) (Article 4)

Abu Dhabi Local Law No. (4) for 1996 (as amended)

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 11

Executive Council Decision No. (37)

As such, EAD is the nominated authority for implementing laws including Federal Law No.
(24) for 1999 and Decision No. 42 of 2009 Concerning the Environment, Health and
Safety Management System in Abu Dhabi Emirate (EHSMS Law)
The Competent Authority for this project, EAD, is responsible for the evaluation of the
environmental impacts of the project and the issue of associated permits and licenses.
EAD standards and guidelines of relevance to the Project which will be adhered to
include:

EAD Technical Guidance Document for Preliminary Environmental Review (PER)

(April 2010).

Standard Operating Procedures for Permitting of New Projects and Activities in Abu
Dhabi (SOP PNPS-01, 2002).

EAD Guidelines for Submission of Baseline Environmental Data (November 2003).

Technical Guidance Document (TG-0003R). Standards and Limits for Pollution to

Air and Marine Environments (July 2003).

EAD Guidelines Format for the Submission of Environmental Impact Assessment

Reports (December 2002).

EAD Geographic Information System Data Management System (July 2001).

EAD Guidance on Permitting of New Projects through Environmental Impact

Assessment.

It should be noted that EAD has since issued updated standards and guidance The PEHSR will,
however, be produced in line with the new guidelines in so far as is possible. The new guidelines
include:

3.4.

Standard Operating Procedures for Permitting of Industrial Projects in Abu Dhabi

(April 2010).

Technical Guidance Document for Environmental Impact Assessment (April 2010).

Abu Dhabi Environment, Health and Safety Management System (EHSMS) and
associated Codes of Practice (CoP).

International Conventions, Treaties, and Protocols

The UAE has signed and ratified (that is, placed into federal law) the following
international protocols and agreements relevant to the S3 Project:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Convention on Biological diversity, 1992 (Biodiversity Protocol);

Project Number 44130065

Page 12

United Nation Framework Convention on Climate Change for the year 1992;

Kyoto Protocol, 1997;

Vienna Convention for the Protection of the Ozone Layer of 1985;

Montreal Protocol on Ozone Depleting Substances of 1987 and Montreal

Amendments (London 1990, Copenhagen 1982, Montreal 1987, Beijing 1999);

United Nations Convention to Combat Desertification 1994;

Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other

Matter (London Convention), 1972;

International Convention for the Prevention of Pollution of the Sea by Oil, 1954 and
its amendments;

Convention on International Trade in Endangered Species of Wild Fauna and Flora

(CITES), 1973;

Basel Convention on the Control of Transboundary Movements of Hazardous

Wastes and Their Disposal, 2002;

Convention on Persistent Organic Pollutants (POPs) 2001;

International convention on Civil Liability for Oil Pollution Damage (CLC) 1969;

International convention on the Establishment of an International Fund for

Compensation for Oil Pollution Damage 1971; and

Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides
in International Trade (PIC Convention) 1998.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 13

4.

PROJECT DESCRIPTION
4.1.

Statement of Need
Chlorine is essential to chemical industry; more than 85% of all pharmaceuticals and
more than half the products marketed by the chemical industries are derivatives of
Chlorine chemistry. Almost 1,500 of these products are used in different industrial and
economic sectors such as health, agro-food, building, textiles, transport, leisure activities,
cosmetics etc.
With every tonne of Chlorine that is produced 1.1 tonnes of Caustic Soda are also made.
More than half of the Caustic Soda manufactured is used in the chemical industry and the
rest goes into products such as soap and textiles, or is used in water treatment,
aluminium production and oil refining.
The UAE government has established heavy industry in order to increase diversification
of the economy. Foreign firms have been employed to provide expertise in planning,
construction, management and marketing in return for minority shares in the companies.
Oil revenues have funded the construction of plants and the development of
infrastructure; natural gas has been used as a source of power and as feedstock.
Petroleum and natural gas industries and their related manufacturing are the basis of the
national economy in the UAE.
A limited local production of Caustic Soda exists in Abu Dhabi, hence the requirement to
develop a local manufacturing plant that will provide additional supply to the required
industries.

4.2.

Project Location and Scale

The Chlor-Alkali Plant will be located in Abu Dhabi Emirate approximately 20km southeast of Abu Dhabi City. The project site is located to within the Industrial City Abu Dhabi 1
(ICAD-1), which is part of the overall Musaffah Industrial Area. The Chlor-Alkali Plant will
be located on a plot of 25000m2 of reclaimed industrial land.
The coordinates for geographic site boundaries are as:
North-West boundary:

Easting: 230522.306 Northing: 2649202.344

South-West boundary:

Easting: 230277.223 Northing: 2644508.749

North-East boundary:

Easting: 235215.915 Northing: 2648957.294

South-East boundary:

Easting: 234970.840 Northing: 2644263.659

Note: All coordinates are UTM Zone 40N, Datum WGS 84

The location of the proposed Chlor-Alkali Plant is shown in Error: Reference source not
found and Error: Reference source not found. The plot and surrounding area up-filled and
levelled, and includes minimal vegetation.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 14

Figure 4-1 Regional Location of ICAD-1

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 15

Figure 4-2 Site Location

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 16

4.3.

Project and Activity Description

The proposed Chlor-Alkali Plant will produce hydrochloric acid (HCl), sodium hydroxide
(caustic soda) and sodium hypochlorite (NaOCl) by electrolysis of brine/salt solution
(sodium chloride) utilizing membrane cell technology. This technology is a proven,
environmentally-safe electrolysis process.
The main products and planned production capacity of the proposed chlor-alkali project is
shown in Table 4 -2 below:
Table 4-2: Main Products and the Planned Production Capacity

Product

Capacity /Day

Capacity / Year

HCl - 32% w/w solution)

179 MT / Day

59,000 MT/Year

Caustic Soda -100%

70 MT/ Day

23,100 MT/Year

Sodium Hypochlorite 12%

70 MT/ Dat

23,100 MT/Year

Approximately, 2.588 Tons/hour of Chlorine gas and 0.0729 Tons/hour of Hydrogen gas
will also be produced as intermediate products during the electrolysis process. All
chlorine and hydrogen gas produced will be fed back into the production process and
converted to HCl and NaOCl, thus there will be no venting of chlorine or hydrogen during
normal operations.
The main raw material & chemicals consumed within the proposed project are presented
in the following Error: Reference source not found. All consumption figures are based on
per metric ton of caustic soda production (as 100%).
Acids and chemical precipitants will be used to remove impurities in salt/brine and in the
products. Chlorofluorocarbons (CFCs) or other ozone-depleting substances will not be utilized
at the Chlor-Alkali Plant.
The following ancillary materials will be used in various stages of the Chlor-Alkali industrial
process:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Sodium carbonate (Na2CO3) will be used for precipitation of calcium ions as

calcium carbonate (CaCO3);

Barium Carbonate will be used for precipitation of Sulphate ions as Barium

Sulphate( BaSO4);

HCl will be used for pH adjustment of cells and also used for dechlorination of
brine;

Project Number 44130065

Page 17

Sodium bisulfite (NaHSO3) will be used for dechlorination of brine and in the final
stage to eliminate chlorine; and

Sodium hydroxide (NaOH) will be used for removal of magnesium and heavy
metals.

The proposed project will comprise of a series of operations, as shown in Figure 4 -3.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 18

Figure 4-3 Flow Diagram of Chlor-Alkali Industrial Process

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 19

The following are the major processes/operations involved in the project, and are
described in the subsequent sections:
1. Unloading and Storage;
2. Brine Purification;
3. Electrolytic Process;
4. Brine Re-saturation and Dechlorination;
5. Chlorine Gas Processing - Cooling and Treatment;
6. Hydrogen Cooling;
7. Production of Hydrogen Chloride;
8. Production of Sodium Hypochlorite;
9. Caustic Solution Concentration (Flaking Unit); and
10. Caustic Solution Concentration (Flaking Unit).
Other utilities and secondary operations, as listed below, will also be involved in the
proposed Al Ghaith project plant.
1. Demineralized Water (DM) system;
2. Cooling Water System;
3. Chilled Water System;
4. Compressed Air System;
5. Steam Supply System (Boiler);
6. Control and Instrumentation System;
7. Bagging Unit; and
8. Transportation System.
Following are the control measures included at the proposed Al Ghaith project plant.
1. Air Emissions Control;
2. Wastewater Treatment and Management;
3. Waste Treatment and Management; and
4. Fire and Toxic Gas Release Prevention and Control.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 20

4.3.1. Unloading and Storage of Salt

Main raw materials will be transported via road from XXX(where??) to the proposed
Chlor-Alkali Plant. The salt and other raw materials will be unloaded from trucks and will
be moved to a dedicated storage area utilizing front-end loaders. This storage area will
be provided with a concrete-lined pad and sheet-metal shading. It is expected that
approximately 120 tons of salt will be brought to the Chlor-Alkali Plant on a daily basis.
Details of the proposed storage facilities are provided in Table 4 -3 below.
Table 4-3 Proposed Storage Facilities

SL No

Storage

Proposed capacity

Remarks

materials

and description

Remarks

50,000 Tons Covered

The storage areas for liquid

chemical (caustic soda, HCl and
NaOCl) above-ground storage
tanks will have containment
dikes to contain 110 percent
capacity of its entire volume of
tanks within the containment.

Salt

shed with wind

protection
4 tanks x 300 m3

Caustic Soda
(50%)

7 m diameter x
8 m height
Mild steel
6 tanks x 150 m3

32% HCl

5.5 m diameter x
7 m height

4 tanks x 100 m3

The storage area will also be

provided with recovery/ drainage
system to transfer the liquid into
other storage tank immediately.

4.5 m diameter x
6 m height

ANSI standards will be followed

for construction of the storage
tanks.

Rubber-lined from
inside.

Sodium
Hypochlorite

FRP or derakane-lined

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

The storage area will be of full

reinforced concrete flooring with
epoxy coating to avoid any
ground contamination in case of
spillages.

Caustic soda

5,000 m3

Flakes

Covered Shed

Paint used on the storage tanks

will be epoxy paint with three
different layers of special
coating.
MSDSs will be located at the
storage facilities to guide
personnel in case of spills.

Project Number 44130065

Page 21

4.3.2. Brine Purification Process

Make-up brine for the process is prepared by dissolving crystal NaCl salt into the return
brine from the membrane cell electrolysers, and is treated with chemicals so as to
precipitate the impurities of raw salt.
Feed to the electrolysers requires highly purified brine free of any metallic impurities.
This is performed by pre coated filter and ion exchange resins under secondary brine
purification facilities. The plant will have a recycled NaCl brine stream as well as
depleted return brine stream as per process requirements.
4.3.2.1. Primary Brine Purification
The return brine is fed to the salt saturator. This will be saturated with make-up salt.
Makeup crystal salt is continuously supplied to the saturator by salt feeder (pay-loader).
Temperature of the return brine is controlled by return brine heater so as to maintain the
saturated brine temperature within 60-65 C.
The clear saturated raw brine overflows from the feed compartment of the saturator to the
clear brine compartment and fed to the reactor with the help of pumps. The density of
brine is controlled automatically. Chemicals, such as caustic soda, barium carbonate and
sodium carbonate shall be added to the saturated raw brine flow.
Dissolved impurities of raw brine (Ca, Mg and SO 4) are concentrated as CaCO3, Mg
(OH)2 & BaSO4 from the solution in the reactor. The excess OH - is maintained by help of
automatic pH measurement & control.
This suspension solution is sent to the center well of brine clarifier for sedimentation and
removal of the solid impurities.
Flocculent is also added to the stream of suspension solution. Clarified brine overflows
from brine clarifier to clarified brine tank. Slurry from clarifier slurry pit and filter slurry pit
is sent to sludge filter press to recover the brine in the slurry. Recovered brine is fed to
return brine tank. The barium sludge obtained during processing shall be dried and
stored in the impervious landfill inside the plant area. As such, the question of barium
sludge disposal does not arise.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 22

Figure 4-4 Brine Clarifier

The clarified brine from clarified brine tank is then filtered through primary brine filters
packed with anthracite coal as filter media. Membrane type electrolysers need high
quality brine free from metallic impurities for trouble free membrane cell electrolyser
operation. Further purification of brine from the primary brine section is carried out in the
secondary brine candle filtration and ion exchange resin adsorption system.

Figure 4-5 Anthracite Filters

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 23

4.3.2.2. Secondary Brine Purification System

Candle filtration
In the membrane cell based caustic / chlorine plant, the content of suspended solid in the
filtered brine must be kept very-very low because suspended solids above a certain level
will plug the ion exchange resin. Care is taken while designing a brine filtration system
for smooth operation of the electrolyser. The system employed by Al Ghaith will have a
carbon candles filtration system with automatic change over valves and sequence
controller. The operating process of a candle filter consists of four stages:
1 Preparation of Pre-coat
The required quantity of the filtrate brine is filled into the filter. This step is performed
immediately after the completion of washing step except the initial start. Alphacellulose
of the required quantity is dosed into a pre-coat tank. When the pre-coat tank dosage
completion button has been pushed and the required time has passed, filtered brine is
filled into the pre-coat tank and agitation begins.
2 Filtration
When saturated brine passes through pre-coat layers formed on surface of filter elements
from upstream to downstream, the fine impurities are trapped and removed. Body feed is
automatically performed during recirculation and filtration process.
3 Washing
The impurities attached and alpha-cellulose on the surface of filter elements are removed
and washed by flushing the clean brine through filter elements from inside to outside. By
washing filter elements are restored back to original state before reuse. Immediately after
completion of washing process (except initial start up) filtered brine of required quantity is
filled into the brine filter. Alpha-cellulose of the required quantity is dosed into the precoat tank. After dosing of alpha-cellulose filtered brine is filled into the pre-coat tank and
agitation is started.
4 Pre-coat:
Filtered brine mixed with alpha-cellulose is sent into the filter. Alpha-cellulose powder is
attached evenly on the surface of filter elements and the pre-coat layers with alphacellulose are formed. The layers contribute to achieve a fine filtration quality by
preventing filter elements from blinding, which gives higher washing efficiency of filter
elements.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 24

Ion Exchange System

Any traces of calcium and magnesium ion or other multivalent cations still present in the
brine are harmful to the electrolyzer membrane. These are removed after chemical
treatment and sedimentation in primary brine purification and further are removed by ionexchange resin as a secondary purification step. Al Ghaith plan to implement a 3-tower
absorber merry-go-round type ion-exchange system. Ion exchange resin is filled into all
the columns.
Two columns are normally on line in series and while the third undergoes regeneration.
After 16 hours the primary column is switched off-line for resin regeneration and the
second column is elevated to primary position, while the regenerated column is switched
into the position of secondary column. The resin in the off-line column, in which a large
amount of multivalent cations have been absorbed, is regenerated by hydrochloric acid
and caustic soda. As per cycle each column is regenerated after every 32 hours. As all
the columns are connected through automatically operated valves, switching takes place
automatically through the programmable logic controller.

Figure 4-6 Ion Exchange Resin Columns

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 25

Flow indication and control valves are installed in all the liquid lines connected to the ion
exchange system in order to automatically control the flow rates.
The resin regeneration process involves the following steps.

Washing with water (brine displacement)

Backwash with water

HCl regeneration

Washing with water

Caustic regeneration

Washing with water

Replacement of water with brine

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 26

4.3.3. Electrolysis Process

The electrolysis section comprises of the membrane electrolyser and associated
equipment.
4.3.3.1. Membrane Electrolyser
The electrolyser assembly consists of a number of bi-polar type cell frames with a metal
anode and the activated cathode, the ion-exchange membrane, filter press type units for
mounting cell frames, sub-headers for feeding purified brine and catholyte, sub-headers
for discharging electrolysis products, and hoses for connecting cell frames with subheaders.
A highly purified brine solution will be fed to each electrolyser manifold and then
distributed to each anode chamber where it then decomposes into chlorine and sodium
ions. The brine flow rate to each electrolyser circuit will be monitored by a flow controller
equipped with individual feed brine branch pipe.

Figure 4-7 Electrolyzer cell in operational reference plants (INEOS & AKCC)
A two-phase process stream of depleted brine and wet chlorine gas overflows from each
anode chamber and is separated at the collection manifold. The depleted brine will flow
by gravity through the branch pipe and common header into the depleted brine tank,
while the chlorine gas will be sent to chlorine gas processing section.
Depleted brine will be pumped to depleted brine dechlorination system by level controller.
Two hydrochloric acid additions have been considered for the brine recycling system in
order to maintain a low oxygen concentration in the chlorine gas. One will be located at

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 27

the inlet of the depleted brine tank, while the other will be situated at the cell feed brine
line.
Two types of chlorine gas seal pots will be installed to protect the electrolysers from
excessive pressure surging in process upset conditions: one for positive pressure relief
and another for negative pressure. Chlorine gas header pressure in the cell room will be
maintained by the pressure control of chlorine at cooler inlet. Recycled caustic will be fed
to electrolyser manifold through a caustic heat exchanger and then distributed to each
cathode chamber. The recycle caustic flow rate will be controlled by the flow controller
installed in the caustic feed line.

Figure 4-8 Catholyte System

A two-phase stream of caustic solution and wet hydrogen gas overflows from each
cathode chamber and is separated at the collection manifold equipped with electrolyser.
The caustic solution flows through the common header into the caustic recycle tank by
gravity.
Gas Processing Section
The hydrogen gas pressure will be maintained by pressure control scheme. To prevent
an excessive positive pressure, a hydrogen vent stack will be installed. This stack will
also serve as a gas purge system during plant start up operations.
After leaving the caustic recycle tank, the caustic solution will go directly to the product
storage tank and the recycle caustic stream to the electrolyser. The caustic heat
exchanger heats or cools the recycled caustic to maintain the electrolyser operating
temperature at 85 to 90 C. The electrolyser caustic strength will be monitored by the
caustic density indicator, and normally kept at approximately 32 wt%. This is the optimum
concentration for membrane performance by controlling the DM water feed quantity into
the recycled caustic stream.
During start-up, the caustic heat exchanger will warm the electrolyte in the electrolyser,
accelerating to full current load attainment without excessive voltage. To detect

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 28

abnormalities of electrolyser, voltage and temperature monitoring systems have been

included in the plant design.

4.3.4. Brine Dechlorination

Depleted brine from depleted brine tank will be taken to a brine de-chlorination section to
make return brine, which is free from chlorine. A typical brine de-chlorination section
consists of packed tower where vacuum is maintained with the help of steam ejector.
Chlorinated brine is sprayed at top of the column and liberated chlorine is sucked through
a cooler. After cooling, it is sent to chlorine gas absorption section. Dosing of
hydrochloric acid will be carried out in order to reduce the pH of brine up to the desired
level before feeding it into the dechlorination tower.
The brine stream will then be taken to the dechlorination tower to be treated again with
NaOH in order to remove traces of chlorine left as the same is very harmful for the
complete system. Dilute caustic will be fed to maintain the alkaline pH of return brine and
to kill traces of Cl2 left in dechlorinated brine. Sodium sulphite reduces NaOCl, but not Cl 2
to chloride. Return brine will be regularly tested to detect the presence of free chlorine
before this enters the return brine tank.

4.3.5. Hydrogen Gas Processing

Hydrogen gas is generated during electrolysis at between 85 to 90 C. The gas will be
introduced to the hydrogen gas coolers first with cooling water and then with chilled water,
where it will be cooled to approximately 18 C. From hydrogen cooler gas, hydrogen gas
will be taken to vent (during start-up) or to the HCl acid synthesis unit.

4.3.6. Chlorine Gas Cooling

The chlorine gas cooling system is capable of providing gaseous chlorine. No provision
has been made for liquefied chlorine production and storage.
The chlorine gas cooling section comprises of chlorine gas coolers (primary & secondary)
and a mist eliminator. Chlorine gas coming from the electrolyser at 90 C will be
saturated with water vapors and will contain traces of sodium chloride. The chlorine gas
will be cooled to between 40 to 45 C in the chlorine cooler with cooling water and then
up to -20C in the chilled water cooler.
During cooling, large quantities of water vapors get condensed. The water vapor will be
collected in the seal pot. Entrained water vapors and salt traces are removed in the mist
eliminator. A small quantity of process water will be added in the chlorine line in order to
dissolve entrained salt particles.

4.3.7. Caustic Concentration & Flaking Plant

This section of the plant will have flexibility to operate on only 50% caustic soda
production (Mode A) and flaking (Mode B) and production of both (Mode C). All the
three are described below.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 29

4.3.7.1. Mode A - Evaporation only

The 32% membrane cell liquor will be fed to the first stage falling film evaporator
operating on product side under a vacuum. During a single pass, the caustic solution is
evaporated to approximately 38%. The generated vapors are led via duct to a water
cooled surface condenser where they are indirectly condensed. Inert gasses are sucked
off by a watering vacuum pump. The 38% caustic solution discharged from the bottom
part of the first stage evaporator by means of pump is heated to a temperature of 136 C
through heat exchange.
During a single pass through the second stage falling film evaporator operating on
product side at atmospheric pressure, the caustic solution is concentrated to 50%. The
vapor generated within is used to heat the first effect evaporator.
The second stage evaporator will be heated by steam. The steam condensate will be
used to preheat the 38% solution and returns at battery limit. The vapor condensate will
be collected in a Tank and leaves the plant at a temperature of approx. 73 0C. The 50%
Caustic solution will be discharged from the bottom part of the second stage by means of
pump (P-1201 A/B). It will be cooled down to 45 Chlor-Alkali Plant C before being sent to
Battery Limit through heat exchange.
4.3.7.2. Mode B - Concentration/ Flaking
The 32% membrane cell liquor will be fed to the first stage falling film evaporator
operating on product side under a vacuum of about 113 mbar abs. During a single pass
through the evaporator, the caustic solution will be evaporated to approximately 46%.
The generated vapors will be led via duct to a surface condenser, where they will be
indirectly condensed by cooling water. Inert gases are sucked off by watering vacuum
pump.
The 46% caustic solution, which will be discharged from the bottom part of the first stage
evaporator by means of pump, is heated to a temperature of 128 C (typical value)
through heat exchanger. During a single pass through the second stage falling film
evaporator operating on product side at atmospheric pressure, the caustic solution will be
concentrated to about 61%. The vapor generated will be used to heat the first effect
evaporator along with the vapor coming from the concentration and flaking unit. The
second stage evaporator will be heated by steam. The steam condensate will be used to
preheat the 46% solution and returns at battery limit. The vapor condensate will be
collected in a tank and will leave the plant at a temperature of approx. 74 C.
The 61% caustic solution from the evaporation will be fed to a specially designed falling
film concentrator. During a single pass through this concentrator, the NaOH solution will
be dehydrated from 61% up to about 98.5%. The concentrator operates on product side
under atmospheric pressure and the generated vapor will be used to heat the first stage
evaporator in the evaporation plant.
The heat required for the concentration from 61% up to 98.5% is transferred by molten
salt. The heat transfer salt is circulated by pump through natural gas fired heater, where

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 30

it is heated to approximately 430 C. The flue gases pass through a combustion air preheater and are then vented through a stack into the atmosphere. The burner placed on
top of the molten salt heater, is designed for operation with preheated combustion air.
The highly concentrated caustic melt leaves the final concentrator through seal pot and is
fed by gravity to a specially designed flaking machine, where it is processed into flakes at
low temperature. The flakes are fed by gravity to a semi-automatic bagging scale. The
bagging scale is of air tight design in order to avoid moisture pick-up of the hygroscopic
flakes. The filled bag will be transported via a conveyor to the bag closing machine. The
bag is a double walled bag with a PE inline and a PP woven outer bag. The PE inline is
closed manually by a drill binder and the PP woven outer bag will be closed by a sewing
machine.
4.3.7.3. Mode C - Evaporation and Concentration/ Flaking
In this mode liquid caustic and flakes can be produced at the same time. The process
description is, in principle, the same as for Mode B concentration and flaking.
However, the process parameters are slightly different. The concentration after the first
evaporation stage is about 40% NaOH. The concentration after the second evaporation
stage is 50% NaOH.
After the second evaporation stage the caustic flow is split into two streams, one feeding
the final concentrator and the second one leading to the battery limit. The caustic going
to the battery limit is passes through a set of two heat exchangers where the caustic is
cooled down to a temperature of 45 C.
The concentration plant is working with the same principle as described under mode B
except that the feed concentration is 50% instead of 61% NaOH. The plant is controlled
by instruments to ensure fully automatic operation of the process. Operating personnel
are required only at the bagging and bag closing station. However, start up and shut
down of the plant requires some manual interactions.

4.3.8. Sodium Hypochlorite Plant

It is mandatory to install Waste Air Dechlorination (WAD) in the Chlor-Alkali Plant in order
to comply with the requirements of the applicable environmental legislation. During start
up and shut down of the plant, chlorine from the cell house is sent to the sodium
hypochlorite plant. In case of any leakage or excess pressure in the process, chlorine will
be sucked by the WAD section. The waste chlorine header will be connected to all
vulnerable points where there is a chance of any chlorine leakage including vents and
seal pots.
The sodium hypochlorite plant consists of the following sections

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Chlorine Suction System;

1st Stage Absorption System;

Project Number 44130065

Page 31

2nd stage Absorption System; and

Chlorine Suction System.

Chlorine gas from chlorine section as well as any leaked chlorine is sucked into the plant
through a suction blower. This blower handles only unabsorbed air and water vapors.
1st stage absorption
The 1st stage absorption system shall consist of caustic circulation tank, circulation pump,
chilled water PHE and packed column absorber. The 1 st absorber will face concentrated
chlorine. The maximum chlorine will get absorbed at this stage. Diluted caustic will be
circulated in the absorber from caustic circulation tank and pumped for absorption of
chlorine from passing through chilled water PHE to remove the heat of reaction. When
the batch is ready the same is transferred to sodium hypochlorite storage tank and fresh
diluted caustic is taken from polishing tower / 2nd absorber tank.
The reaction in the sodium hypochlorite plant can be summarized as below:
2 NaOH + Cl2 NaOCl + NaCl + H2O
Normally to get a stable product, 10 to 20 gpl of excess alkali is maintained in the product
and before transferring it is ensured that available chlorine is 150 gpl.
2nd Stage Absorption System
Since some chlorine will escape from 1 st absorber the 2nd stage absorption system will be
installed to absorb the remaining chlorine from waste air.
Additionally, this system will consist of one packed absorber with one circulation tank,
circulation pumps and plate heat exchanger.
The 2nd stage system consists of:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Chlorine Suction System;

Caustic Dilution and Over Head Tank;

1st Stage Absorption System; and

2nd stage Absorption System.

Project Number 44130065

Page 32

Figure 4-9 2nd Stage Absorption System

4.3.9. Hydrochloric Acid Plant

4.3.9.1. Principle of Operation
HCL is produced as a gas from the combustion of hydrogen and chlorine gases, then
absorbed into water and cooled. The combustion process is controlled to provide ultimate
safety.
During the combustion process, chlorine and hydrogen react in equal volume to produce
HCl gas.

H2
(Gas)

Cl2
(Gas)

2HCl
(Gas)

This exothermic reaction generates a flame temperature of around 2,500C, and a heat
load of approximately 1,000 kCal / kg of HCl when producing a cooled 33% aqueous
phase of HCl. The combustion process is operated with a slight excess of H 2 over
stoichiometric conditions operating the system with this excess of H 2 ensures the
complete Combustion of chlorine gas, thus preventing it from escaping into atmosphere
and producing a pure hydrochloric acid.
4.3.9.2. Synthesis Unit
The heart of the process is synthesis unit (or integrated burner absorber), constructed of
impregnated graphite materials encased in a water-cooled shell. The functions / process
steps of the synthesis unit include:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Combustion;

Gas cooling;

Project Number 44130065

Page 33

Absorption; and

Solution cooling.

Hydrogen and chlorine gas enter the top of the synthesis unit and are burnt into a specific
burner designed to ensure the complete combustion. The burner consists of special
tubes fitted inside which are easily removable for maintenance.
The addition of absorption water to the HCl gas is carried out at the top of the unit. The
gases and absorption water are then cooled down in vertical channels at counter current
of service side cooling water circuit. The wetted parts of unit are of the selected material
to avoid any corrosion.
At the bottom outlet of absorber, the HCl solution is separated from the gas which is
processed in a tail gas tower scrubber to recover the remaining non-absorbed HCl gas.
The synthesis unit is normally operated close to atmospheric pressure, but it is protected
against over pressurization with a rupture disc. At the bottom of assembly, and vented to
a sump pot beneath the synthesis unit.
4.3.9.3. Tail Gas Tower:
The purpose of the tail gas tower is to absorb or to scrub the gases coming from the
bottom of absorber. The gas components are mainly inert with some burnt hydrogen and
a little unabsorbed HCl. The absorption water enters the top of the tail gas tower through
a distributor and flows downwards over a packing as the gases flow upwards to be
exhausted to atmosphere. During this operation, the remaining HCl will be absorbed.
4.3.9.4. Safety:
The overall control philosophy of the HCl synthesis system design is fail-safe, which is
defined by opening contacts under abnormal conditions. The following safety interlocks
are provided to either prevent the system from being started or to cause the system to
shut down & the purge itself.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Flame failure;

Low cooling water flow;

Low absorption water flow;

Safety disc breakage;

Very high level in buffer tank;

Low N2 gas pressure while purging the unit during startup; and

Low instrument air pressure gauges.

Project Number 44130065

Page 34

During operation, if either of the above events occurs, the synthesis unit shuts itself down
that a purge with nitrogen can be carried out.

4.3.10. Demineralized water system

The process raw water will be DM by means of ion exchange treatment. The DM water
production unit consists of cationic and anionic exchangers, a degasser (to reduce the
CO2 before feeding the anionic exchanger), and a chemical dosing system for resin
regeneration. The resin regeneration will be performed with diluted solutions of
hydrochloric acid and sodium hydroxide. This unit will be designed to be operated
automatically by means of a Programmable Logic Controller (PLC). The effluent from the
DM unit will be mainly water with traces of acid and will be directed to wastewater
neutralization pit.

Cooling water unit

A closed-circuit cooling water unit will be installed at the proposed plant and will consist of
induced draft type cooling towers. The warm cooling water will be dispersed uniformly
over the entire cooling area by a distribution system. The air used for cooling will be
drawn up by fans located on the top of the cooling tower. The cooled water will be
collected in a water basin beneath the tower. The collected cooled water will be pumped
to various process units in plant, collected back in the cooling water basin and pumped
back to the cooling tower.
The cooling water will be treated with chemicals in order to prevent metal corrosion, scale
formation, and biological fouling, and thus help in increasing system operating efficiency
and the composition of the bleed-off sent to drain.

4.3.11. Chilled water system

A chilling unit will be installed at the plant to produce chilled water. The chilling unit will
include a vapor absorption system to avoid the use of any Ozone-depleting refrigerant.
The chilled water will be used at various stages of the process stream.

4.3.12. Compressed air system

The air compression unit will consist of two compressors (operational and stand-by) for
the supply of 100% of the compressed air demand for plant and instrument air.
Even though the membrane plant will be operated continuously, variations of instrument
air requirement can occur. The instrument air vessel will compensate these variations
and allow smooth operation of air system.
The compressed air system will also include a dryer which will consist of two units that
can be used alternatively as an absorber chamber or in case of regeneration as desorber
chamber.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 35

In addition, the dry air system will be used for air blanketing (through various inlets) the
caustic flakes, starting from the hoppers up to the bagging area, in order to prevent the
flakes from absorbing the moisture.

4.3.13. Steam supply system

A natural-gas fired boiler complete with a low-No x burner, a combustion air fan, and an
automatic control (for safety operation) will be installed at the plant to generate steam.

4.3.14. Control and instrumentation system

The plant will be equipped with a central control system enabling an automatic operation
of main process units and checking the critical parameters (temperatures, feed rate, liquid
levels, etc). These parameters are monitored with pre-alarms and sensors. Interlocks
will also be provided for personal safety and material protection. In addition, local control
panels will be provided at the burner system, spraying areas and at the bagging units.
Details of proposed online monitoring system are provided below in Table 4 -4.
Table 4-4: Proposed Online Monitoring System
Type

Description

Chlorine and hydrogen

sensors

Caustic Plant how many???

Meters
Voltage monitoring
equipment

Process control equipment

pH meter, ORP
Conductivity
Cell House
All the process parameters (temperature, pressure,
flow etc)
Analyzers are linked with an Automated DCS with
safety trip logics

4.3.15. Bagging Unit

A bagging unit will be installed to weigh and automatically fill the caustic flakes into bags.
The system will consist of an electronic weighing scale and a fully automatic fill and sealtype packaging machine, and will be operational 16 hours per day.

4.3.16. Transportation System

Transportation of main raw materials from ICAD 1 to the proposed plant will be via road.
In addition, finished products will be transported via road for distribution within the UAE
and beyond.
Standard Operating Procedures (SOP) will be prepared to ensure the following:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 36

Transportation is carried out safely in compliance all applicable EAD

rules/regulations and international conventions;

Materials to be transported are within allowable weight and volume limits;

No leakage/spillage of the materials from the vehicles occurs during

transportation and loading/unloading; and

Vehicle operators/drivers follow applicable UAE traffic laws/regulations.

4.3.17. Facility Construction

The following major activities are expected to occur as part of the project construction
effort:

Piping and underground piping works;

Civil works;

Construction works and installation of pre-fabricated structural steel and pipe

racks;

Building construction works and equipment machinery erection;

Pre-fabrication of piping spools and piping erection, testing and flushing systems
in all areas;

HP equipment and piping erection, and listing, flushing and pre-commissioning;

Electrical works and instrument erection;

Instrument calibration and loop checks;

Insulation and painting works; and

Mechanical completion, testing and pre-commissioning.

4.3.18. Air Emissions Control

In general the air emission sources within the project are very small and emission rates
are minimal. Most of the point source emissions at the proposed plant will be from the
following:
Construction phase impacts due to emissions of criteria air contaminants from
mobile non-road sources (i.e., construction equipment and vehicles);

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Construction phase impacts due to emissions of dust due to digging, piling and
other earth work;

Stack for Hydrochloric acid furnace (HCl vapors and Cl 2 gas);

Project Number 44130065

Page 37

Stack for Sodium hypochlorite tower (Cl2 gas);

Stack for natural-gas fired boiler (SPM, NOx, SOx, CH4, CO2);

Stack for Flaking Unit (SPM, NOx, SOx, CH4, CO2).

The primary source of air contaminants during the construction phase will be the various
internal combustion engines used at the construction site, which will include both nonroad construction equipment and some on-road vehicles. These mobile sources will emit
carbon monoxide (CO), volatile organic compounds (VOCs), nitrogen oxides (NO x) and
sulfur dioxide (SO2) into the atmosphere.
The operating horsepower of the equipment was estimated as the average horsepower
for a specific type of equipment utilizing the USEPA non-road emission factors.
Furthermore, since the specific number and type of equipment to be used onsite at any
given time has not yet been finalized, a conservative estimate of the type and number of
construction equipment to be used has been assumed. The corresponding NEVES
emission factors are presented in Table 4 -5 below. The maximum monthly and daily
estimated emissions during the construction period are summarized in Table 4 -6.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 38

Table 4-5: Construction Equipment - Air Emission Factors.

Expected Construction
Equipment

hp

CO
(g/bhp-hr)

VOCs
(g/bhp-hr)

NOx
(g/bhp-hr)

SO2
(g/bhp-hr)

Plate Compactors

3.1

0.83

9.3

0.93

Rollers

99

3.1

0.82

9.3

Excavators

143

5.2

0.71

10.75

0.93

Cranes

194

4.2

1.29

10.3

0.93

Off-Highway Trucks

489

2.8

0.86

9.6

0.87

Tractors/Loaders/Backhoes

77

6.8

1.43

10.1

0.93

Dumpers/Tenders

23

2.8

0.86

9.6

0.89

Generators < 50 hp

22

1.22

0.93

Air Compressors < 50 hp

37

1.22

0.93

4x4 Use (Petrol Fuel)*

N/A

2.06

0.04

0.14

0.40

4x4 Use (Diesel Fuel)*

N/A

0.61

0.15

0.2

0.40

Bus*

N/A

1.56

0.49

3.93

0.40

500 KVA Generators

50

5.0

1.22

8.0

0.93

Air Compressors

50

5.0

1.22

8.0

0.93

Table 4-6: Construction Emissions Estimates.

Construction Period
(days/month)
Length of working days
(hrs/day)
Expected Construction
Equipment
hp
Plate Compactors
8

26
10
Qty
1

Estimated Peak Construction Emissions

CO
VOCs
NOx
SO2
(kg/month) (kg/month) (kg/month) (kg/month)
6.0
1.6
17.9
1.8

Rollers

99

6.0

1.6

17.9

1.8

Excavators

143

4.0

1.1

11.9

1.2

Cranes

194

4.8

1.3

14.3

1.44

Off-Highway Trucks

489

3.0

0.8

8.9

0.9

Tractors/Loaders/Backhoes

77

11.9

3.2

35.7

3.6

Dumpers/Tenders

23

6.0

1.6

17.9

1.8

Generators < 50 hp

22

11.9

3.2

35.7

3.6

Air Compressors < 50 hp

37

23.8

6.4

71.4

7.2

4x4 Use (Petrol Fuelled)

***

10

59.5

16.0

178.5

18

4x4 Use (Diesel Fuelled)

***

59.5

16.0

178.5

18

Bus
***
Total Estimated Emissions
(kg/month)
Estimated Emissions (kg/day)

6.0
202

1.6
54

17.9
606

1.8
61

7.8

2.1

23.3

2.4

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 39

The movement of soils during construction activities will be anticipated to lead to the
generation of airborne dust. The occurrence and significance of dust generated by earthmoving operations will be difficult to estimate accurately, and depends upon
meteorological and ground conditions at the time and location of the earthwork.
Very small quantities of CO 2 emissions are released during the purification of brine with
sodium carbonate. It is estimated that 10 grams of carbon dioxide are released per ton of
caustic soda production. Fugitive CO2 emissions are also likely from the chlorine
destruction unit and handling.
During loading of caustic and NaOCl, fugitive emissions are not anticipated. However,
fugitive emissions are likely during HCl loading.

Control measures to minimize air emissions

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

The depleted brine from the electrolysis section, containing free chlorine, will be
de-chlorinated in a brine de-chlorination tank where most of the free chlorine will
be stripped out by vacuum and the stripped chlorine gas will be sent to the main
chlorine gas header. The de-chlorinated brine leaving the de-chlorination tank
will be allowed to react with sodium bisulfite solution at a pH of 9-9.5 for further
removal of chlorine;

All chlorine-containing waste gas streams will be directed to the chlorine

absorption unit. The chlorine absorption unit will be designed with a treatment
capacity sufficient to absorb the full cell-room production to prevent emissions of
chlorine gas in the event of emergencies and/or irregular plant operation until
the plant can be shut down. The chlorine absorption unit design will enable the
plant to lower the chlorine content in the emitted gas to less than 1.72 ppmv (5
mg/Nm3) in the worst-case scenario compared to EADs permissible limits of 20
ppmv. In addition, the emitted HCl vapor will be less than 6.70 ppmv (10
mg/Nm3) in the worst-case scenario compared to US EPAs permissible limits of
12 ppmv;

The steam boiler and the flaking unit will include low No x burners to effectively
reduce Nox emissions to meet the EAD permissible limit of 55 mg/Nm3. SOx
emissions will be below the MoEs permissible limit of 500 mg/Nm3;

Regular annual inspection of boiler and flaking unit will be conducted to avoid
any excess carbon dioxide release; and

A scrubbing unit with 95% efficiency will be provided to control fugitive emissions
during HCl loading.

Project Number 44130065

Page 40

4.3.19. Wastewater Treatment and Management

Wastewater sources
Waste water generated at the plant will originate from various operations as listed
below:

During regeneration of the ion-exchange resins (employed during secondary

brine purification process), wastewater containing trace amounts of dissolved
metals (nickel, zinc, iron, copper) will be generated;

During purification of the brine, high concentration of chloride, chlorates, and

oxidants may accumulate. Chlorates may also form as by-products during
electrolysis. Due to the recycling of the brine, the following components may
build-up;
o

Sulfate ions may often have a negative effect on the electrolysis process
(damages the anode coating). Bleeding of the brine treatment system will be
conducted periodically to reduce the levels of sodium sulfate and/or sodium
chlorate in the cells. Wastewater will be generated as result of bleeding of
the circuit.

Chlorinated hydrocarbons may be formed in a reaction between organic

contaminants in the electrolyzer and free oxidants. Releases of chlorinated
hydrocarbons will normally be very low (approximately 20 kg/year), typically
0.03-1.16 grams per ton of chlorine produced.

Wastewater resulting from wash-outs of unit components, exhaust air scrubber,

and floors;

Wastewater generated as a result of caustic evaporation; and

Sanitary wastewater generated during construction and operational phases.

Based on internationally accepted standard of 0.25 m 3 of sanitary wastewater
generated per person per day, the construction sanitary wastewater for estimated
500 workers will be 125 m3/day, and the operational sanitary wastewater for 45
employees will be 12 m3/day.

As mentioned earlier, with the exception of blowdown water, the proposed plant will not
have any wastewater discharge from the cooling water unit.

Control measures to minimize effluent

Recycling of brine (removing impurities) by ion-exchange resin unit. Subsequent

regeneration of resins will be accomplished by using caustic soda and acid
washing;

Using spent acid to control pH in process and wastewater streams;

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 41

Removal of precipitated salts from the brine through decantation/clarification and

filtration;

Minimizing the discharge of chlorate to water by applying acid conditions in the

anolyte (pH 1-2). Also, chlorate destruction in the brine circuit will be conducted to
remove chlorate before purging;

Removal of brine filtration sludge by flushing with a weak HCl solution. The acid
will cause the precipitate to dissolve and the resultant solution will be discharged
with the liquid effluent to the onsite wastewater treatment plant; and

Recycling of water, wherever possible, utilizing Reverse Osmosis (RO) unit.

4.3.20. Solid Waste Treatment and Management

Solid wastes generated at the Chlor-Alkali Plant during the brine purification will consist of
used materials such as pre-coat and feed material made of cellulose. The pre-coat filter
sludge from the brine softener will consist mainly of alpha-cellulose, contaminated with
iron hydroxide and silica. Spent membranes and gaskets from membrane cells will be
other waste streams remaining after their service life. The solid waste generated at the
proposed plant will be managed as per a Waste Management Plan (WMP).
On a general level, waste will be stored in a dedicated area and will be disposed following
relevant EAD regulations.

4.3.21. Fire and Toxic Gas Release Prevention and Control

The equipment configuration at the proposed plant will conform to best practices for
modern Chlor-Alkali plants.
Due to vulnerability of fire and toxic gases in any Chlor-Alkali plant (direct and indirect),
the following effective preventive and control measures will be taken at the proposed Al
Ghaith plant to minimize fire or other hazards and consequential damages:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Installation of fire detection and alarm system;

Installation of hydrant system;

Installation of automatically activated high velocity sprinkler system;

Placement of portable fire extinguishers;

Tie-up of hydrogen gas generated in the cell room to the gas header;

Use of "intrinsically safe" electrical equipment in the selected plant areas;

Project Number 44130065

Page 42

4.4.

A little amount of hydrogen gas will be vented to the atmosphere during upset
conditions through safety release valves. Venting system will be so designed that
concentration level of hydrogen in air will be always less than 1% with following
auxiliary equipment:
o

Flame arrestor in the vent line;

Flame sensor near vent point;

Automatic purging of steam in the vent pipe (interlock with flame sensor
will be provided);

Stack height will be designed as per the standard guidelines.

Installation of chlorine absorption unit designed with a treatment capacity

sufficient to absorb the full cell-room production in the event of emergencies;

Installation of chlorine and hydrogen gas detectors in the electrolysis cell room;

Implementation of Waste Air Dechlorination (WAD) in the sodium hypo plant for
neutralizing quantity of waste gas arising out of electrolyzers operation. This
system, utilizing double-stage scrubbing mechanism, will be designed to
neutralize all chlorine produced at full capacity for 15 minutes;

The composition of the vent stream that will be vented from chlorine absorption
unit and WAD during the normal operation will be as follows:

Air saturated with water: 99.9999%

Chlorine gas: 0.0000045%

HCl: Nil

Entire equipment will be backed-up by emergency power generator set;

Operation of control and instrumentation system enabling an automatic operation

of the unit by controlling the important process parameters such as temperature,
feed rate and liquid levels, monitoring the critical parameters with pre-alarms, and
interlocks for personal safety and material protection; and

Transportation of the raw materials and finished goods (in and out of the plant,
respectively) will be conducted safely and will be in compliance with applicable
UAE rules and regulations and international conventions.

Project Status and Schedule

4.4.1. Current Status

The Chlor-Alkali Project is currently within the development phase. The current status of
project implementation up to October 2011 includes the following:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Submission of initial draft PEHSR to Al Ghaith for comment 20 August 2011;

Project Number 44130065

Page 43

Submission of initial draft PEHSR to Zonescorp on 27 August 2011;

And.

4.4.2. Project Schedule

The current project schedule, including planned components and phases, is presented
within Annex XX.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 44

5.

ENVIRONMENT, IMPACTS, MITIGATION AND MONITORING

5.1.

Air Quality

5.1.1. Description of the Environment

5.1.1.1.

Regional Climate and Meteorology

The climate of the region is bi-seasonal, characterised by high temperatures and low
rainfall. The summers (May to October) are distinctly hot, with daytime temperatures
regularly exceeding 40C. Rainfall occurs occasionally during the summer, but is
generally restricted to the cooler winter months (November to April) when temperatures
can drop to 4C in some areas (usually inland) at night. Seasonal fluctuations in
temperatures are less well pronounced along the coast, where they are buffered by the
maritime influence.
Annual rainfall amounts vary according to location, but precipitation generally decreases
from north-east to southwest along the UAE. Coastal areas such as Abu Dhabi receive
about 80 mm of rain annually.
Fog occurs on 31 days or an average of 106 hours per year near the coast. Also near the
coast fog is more frequent in winter (76 days on average) than in summer to (48 days on
average). Fog incidence can last from half an hour to 10 hours, depending on the time of
formation and the weather conditions.
Humidity peaks in July and August at over 90%, and decreases through October, with the
least occurring from November through to April. The humidity over the cooler months can
fall to 10-20%.
The weather during much of the year is dominated by a ridge of high pressure extending
southwards into central Saudi Arabia with lower pressure over the eastern Gulf. The
result of this is the prevailing winds from the north and north western quadrants, known
by their Arabic name shamal, meaning north. Shamals occur mainly during the cooler
months, however they can also occur during the hot season, typically June and July.
Along the western coastal plain, sea breezes tend to dominate with light south southeasterlies at night being replaced by moderate northwesterly winds during daytime. A
strong northerly shamal is usually preceded in the UAE by strong southerly winds, raising
desert sands and reducing visibility. The shift to northerly winds may be quite sudden
and can be accompanied by rain, thunderstorms, or dust storms.
5.1.1.2.

Ambient Air Quality

The main source of air pollutants in Musaffah is traffic in addition to different industrial
activities, all contributing to emissions from small workshops and larger industrial
processes in the area.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 45

Modelled Air Quality

Computer modelling was used by EAD to assess impacts of emissions from stacks and
traffic on ambient air quality in different areas. Impacts of each source was be modelled
separately, thus allowing the identification of its contribution to the observed pattern. The
simulation model used produced hourly averages and maxima, 6-months averages and
maxima, and yearly averages and maxima.
NO2
The air pollution dispersion calculations show that inside the Abu Dhabi city, due to
emission conditions and prevailing wind, traffic is the main contributor to impact of
nitrogen oxides. The proposed one-hour air quality guideline for NO 2 (200 g/m3) is
exceeded inside Abu Dhabi city with the emissions from traffic alone (Error: Reference
source not found), but not in Musaffah. However, point sources like power plants will give
increased impact downwind in prevailing wind directions. Their contribution, added to the
contribution from traffic, can lead to exceedance of the proposed air quality guidelines in
areas outside the city centre (Error: Reference source not found) where these guidelines
were not exceeded with the contribution from traffic alone. Again, the present one-hour
air quality guideline for NO2 is not exceeded in Musaffah.

Figure 5-10 1-hour average NO2 concentrations (g/m3) from traffic emissions in Abu Dhabi
city (EAD, 2007)

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 46

Figure 5-11 Maximum 1-hour average NO2 concentrations (g/m3) from traffic and industrial
emissions in Abu Dhabi city (EAD, 2007)

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 47

SO2
The maximum 1-hour SO2 concentrations in Abu Dhabi city and surroundings does not
exceed the one-hour air quality guideline for SO 2 (350 g/m3), but it reaches a maximum
of 250 g/m3 in MIA (Error: Reference source not found). In the centre of Abu Dhabi city
the maximum 1-hour SO2 concentrations are between 100 and 125 g/m 3.

Figure 5-12 Maximum 1-hour average SO2 concentration (g/m3) from traffic and industrial
emissions in Abu Dhabi city (EAD, 2007)

Additionally, air quality in MIA was also measured in 2008 by a mobile laboratory over a
10-day period during the summer months. The mean measured values were averaged
to 1 hour, 8 hour, 24 hour and/or 1 year values for the parameters for which applicable
EAD Ambient Air Quality Standards (AAQS) exist. Neither the measurements nor the
calculated averaged values (Error: Reference source not found) exhibited exceedances
of the EAD AAQS parameters, except PM 10. For PM10, the 10-day measured value mean
and the calculated averaged value both exceeded the respective EAD AAQS. This can
be attributed to the emissions from industrial activity with in MIA as well as the naturally
high levels of PM10 occurring in the region due to its sandy top land profile (EAD, 2007).

This averaging was carried out using an in-house calculation method. The averaged values were derived from
the 10-day measured mean value.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 48

Table 5-7 Ambient Air Quality in Musaffah

10-day Measured Values (g/m3)
Parameter
Mean

Minimum

Maximum

NOX
NO

83.7
20.2

4.5
0

446.4
120.9

NO2

52.8

3.3

120.2

SO2

14.7

1.9

67.2

H2 S

9.7

2.6

24.3

CO

0.6

0.1

1.5

O3

41.4

126.3

PM10

135

28

572

Calculated
Averaged Value
(compared to
Mean)

Averaging
Period

EAD
AAQS

N/A

N/A

N/A

158.0
83.7
44.0
23.3
7.2
N/A
1.8
1.2
123.9
81.7
214.0

1 hour
24 hour
1 hour
24 hour
1 year
N/A
1 hour
8 hour
1 hour
8 hour
24 hour

400
150
350
150
60
N/A
30,000
10,000
200
120
150

(g/m3)

More recently, the ADNOC carried out continuous air quality monitoring employing a
mobile air quality monitoring station (trailer) positioned at the ESNAAD MIA site between
11 May, 2009 and 27 September, 2009. The parameters monitored were: SO 2, NO2, O3,
CO, PM10, NMHC, CH4 and H2S. Details of the monitoring methodology and reporting are
available in the Ambient Air Quality Monitoring at ESNAAD report produced by Nahla
Medical Supplies (Nahla Medical Supplies, 2009).
In summary, the monitoring results demonstrated that NO 2 1 hour and 24 hour averaged
concentrations, SO2 1 hour and 24 hour averaged concentrations, and CO 1 hour and 8
hour averaged concentrations were in compliance with their applicable corresponding
Ambient Air Quality Standards (AAQS).
For O3, the 1 hour averaged concentration was in compliance with the applicable
corresponding AAQS. The 8 hour averaged concentration, however, exceeded the
applicable corresponding AAQS 9, 6, 2 and 2 times in May, June, July and August 2009
respectively.
For PM10, 24 hour averaged concentration exceeded the applicable corresponding
ADNOC AAQS 3, 21, 22, 18 and 6 times in May, June, July and August 2009 respectively.
According to the survey report (Nahla Medical Supplies, 2009), these exceedances can
be attributed to a dust haze episode occurring over the Middle East during the monitoring
period.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 49

5.1.2. Environmental Impact Prediction and Evaluation

5.1.2.1.

Emissions from Operation of Fuel-Consuming Vehicles and Equipment

Construction
During the construction period, operation of vehicles and construction equipment with
internal combustion engines will lead to exhaust emissions of combustion products
including NO2, SO2, CO and PM10. Small amounts of volatile organic carbon compounds
(VOC) may also be emitted from unburned fuel in the equipment engine exhausts or other
fugitive emission sources such as fuel pipe fittings.
The air emissions inventory for all construction activities is presented in Table 4-4 and 45, in Section 4.3.18.
Due to the industrial nature of the Project area and existing operational emission sources
in adjacent industrial plants, incremental additions to the existing pollutant concentrations
from construction activities will be relatively small, transient, and restricted to the
immediate vicinity of the work site (i.e. within approximately 500 meters downwind of the
construction activity). It is to be noted that levels of particulate matter (PM 10) in the air are
already high in the region due to the surrounding desert environment, existing soil
disturbance, and winds.
Based on the above information, it is considered that the overall environmental impact to
air quality in the Project area for this aspect due to construction activities is of low risk.
Probability

Consequence

Significant

Rare

Minor

Low Risk

Operation
This section presents the air quality impact assessment from potential air quality impacts
associated with normal operations of the proposed Chlor-Alkali Plant. The air quality
impacts have been assessed in terms of predicted changes to air quality in the vicinity of
the proposed plant.
Atmospheric emissions will be generated through the operation of gas-fired plant
equipment, boiler, and flaking unit within the plant site. The Chlor-Alkali Plant process
design will utilize low-NOx burners for its single steam boiler and flaking unit that will
comply with EAD equipment-specific emission standards. The air emissions inventory for
all construction activities is presented in Table 4-4 and 4-5, in Section 4.3.18.
Most of the emission sources are not expected to have high criteria or GHG emissions.
The GHG emissions from these stacks will be mostly CO 2 and negligible quantities of
Methane during certain phases of the process cycle. The process will also be equipped
for hydrogen venting during emergencies. These venting events will be of very brief
duration and are not expected to have any significant impact on the air quality.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 50

The primary criteria air contaminants of interest for the Chlor-Alkali Plant project are NOx
and SO2, both of which are combustion derived. The proposed Chlor-Alkali Plant will emit
an overall total of 5 tons NO x/year and 32 tons SO2/year. Since the proposed project will
combust only natural gas, the resultant impact from CO and PM 10 will be minimal.
Due to the nominal magnitude of the NO x and SO2 emissions from the Chlor-Alkali Plant,
air quality dispersion modeling was not performed. The balance of the criteria pollutant
(i.e., CO, VOC and particulates) emissions are typically not under consideration for air
quality modeling.
Based on the above information, it is considered that the overall environmental impact to
air quality in the Project area for this aspect due to construction activities is of moderate
risk.
Probability

Consequence

Significant

Likely

Minor

Moderate Risk

Decommissioning
At the end of lifecycle of the Chlor-Alkali Plant, it is assumed all the assets of the site will
be decommissioned and the site will be restored, so far as is possible, to its original
condition. It is also assumed, therefore, that the foundations of the plant will also be
removed.
The impacts to air from operation of fuel consuming vehicles and equipment are likely to
be very similar to those of the construction phase. Therefore, it is considered that the
overall environmental impact to air quality in the Project area for this aspect due to
decommissioning activities is of low risk.

5.1.2.2.

Probability

Consequence

Significant

Rare

Minor

Low Risk

Emissions from Accidental Events

Construction
Accidental liquid or solid fuelled fires during construction activities would lead to
deterioration of ambient air quality. These fire(s) can be caused due to the presence of
an ignition source in the vicinity of the fuel storage tanks or an electrical short-circuit
taking place in the equipments internal or external wiring connections. Such a situation
would lead to emission of typical combustion products such as CO, NO x, SO2 etc.
In addition to this, ignition of any flammable maintenance-related chemicals within the site
temporary facilities or site, as well as occupation of the site offices by construction
personnel poses a risk to ambient air quality due to a fire occurring within these buildings.
Potential causal factors for this could include human accidents involving ignition sources

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 51

such as cigarettes as well as environmental factors such as build-up of high temperatures

within the chemicals storage area due to high ambient temperatures. Such a situation
would lead to emission of typical combustion products.
It is to be noted, however, that air quality impacts from any of the afore-mentioned events
would be short-term in nature i.e. only present until the fire is extinguished or the fuel runs
out.
Therefore, it is considered that the overall environmental impact to air quality in the
Project area for this aspect due to construction activities is of low risk.
Probability

Consequence

Significant

Rare

Minor

Low Risk

Operation
Accidental chlorine gas release impacts generally associated with chlor-alkali industrial
facilities are unlikely to occur during the operation of Chlor-Alkali Plant based on the
proposed preventive and control measures.
The common causes of chlorine gas release at chor-alkali facilities are listed below.
These causes are ranked in the order of severity of the leak and the hazard posed by its
occurrence.
1. Fire
2. Flexible connection failure
3. Fusible plug corrosion
4. Accidents caused by carelessness and ignorance
5. Valve packing failure
6. Gasket failure
7. Piping failure
8. Equipment failure
9. Physical damage of containers in collision accidents
10. Container failure
11. Chlorine pressure gauge failure

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 52

The USEPA has determined that chlorine is not a persistent pollutant, in that it photolyzes
rapidly to hydrochloric acid (HCl), a much less toxic substance, following the release.
Chlorine, as a powerful oxidizer, attacks the lungs, causing inflammation (pneumonitis)
and fluid accumulation (pulmonary edema), and is intensely irritating to the eyes;
prolonged and/or acute exposure may be fatal. Table 5 -8 below summarizes typical
symptoms of exposure to various concentrations of chlorine.
Table 5-8: Summary of Chlorine Health Effects
Concentration (ppm in air)

Health Effects

1-3 ppm

Mild mucous membrane irritation

5-15 ppm

Upper respiratory tract irritation

30 ppm

Immediate chest pain, vomiting, shortness of breath

(dsypnea) and cough

40-60 ppm

Inflammation of lung tissues (toxic pneumonitis) and

fluid accumulation (pulmonary edema)

430 ppm

Death within 30 minutes

1,000 ppm

Death within a few minutes

The Emergency Response Planning Guideline Level 2 (ERPG-2) value for chlorine gas is
3 ppm, which is set as end point concentrations for chlorine gas plume during emergency
response.
ERPG-2 is the maximum airborne concentration below which it is believed that nearly all
individuals could be exposed for up to one hour without experiencing or developing
irreversible or other serious health effects or symptoms which could impair an individuals
ability to take protective action.
The American Industrial Hygiene Association (AIHA) publishes ERPG levels for various
chemicals (http://www.aiha.org/Committees/documents/erpglevels.pdf.). If an EPRG-2
value has been published, the Emergency Response Guideline uses this number for
setting the Protective Action Distance (PAD). If an ERPG-2 value has not been
established, the PAD is set at 0.01 x Lethal Concentration (LC) 50.
The other useful exposure limits for chlorine are presented below in Table 5 -9.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 53

Table 5-9: Other Useful Exposure Limits for Chlorine

Standard Setting Body

Permissible Exposure,
(ppm)

Description

National
Institute
of
Occupational Safety and
Health (NIOSH)

0.5

Recommended
Limit (REL)

American Conference of
Governmental Industrial
Hygienist (ACGIH)

0.5

Threshold Limit Value (TLV)

Time Weighted Average
(TWA)

UK Health and Safety

Executive (HSE)

0.5

Long-term exposure limit (8

hour), OEL

USEPA

0.5

Environmental air limit

Occupational Safety and

Health
Administration
(OSHA)

1.0

Permissible Exposure Limit

(PEL)

NIOSH

1.0

Short Term Exposure Limit

(STEL)

ACGIH

1.0

STEL

UK HSE

1.0

STEL, OEL

NIOSH

10

Immediately Dangerous to
Life or Health (IDLH)

Exposure

Therefore, it is considered that the overall environmental impact to air quality in the
Project area for this aspect due to operational activities is of moderate risk.
Probability

Consequence

Significant

Rare

Major

Moderate Risk

Decommissioning
At the end of the lifecycle of the Chlor-Alkali Plant, it is assumed all the assets of the site
will be decommissioned and the site will be restored, so far as is possible, to its original
condition. It is also assumed, therefore, that the foundations of the plant will also be
removed.
The impacts to air from accidental events occurring are likely to be very similar to those of
the construction phase, especially due to the similar equipments that will be used during

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 54

both phases, as well as movement of flammable substances off site. In the events of a
fire occurring due to an accident during the decommissioning activities, typical
combustion products will be emitted. Similar to the construction phase, it is expected that
air quality impacts from any of the afore-mentioned events would only occur until the fire
is extinguished.
Therefore, it is considered that the overall environmental impact to air quality in the
Project area for this aspect due to decommissioning activities is of low risk.

5.1.2.3.

Probability

Consequence

Significant

Rare

Minor

Low Risk

Emissions of Greenhouse Gases

The Greenhouse Gas Protocol developed and issued by the World Resources Institute
and the World Business Council for Sustainable Development (WRI/WBCSD) defines
different sources of greenhouse gas emissions into a series of categories or scopes.
These definitions, as described below, have been used to determine the scope and
sources of emissions to be considered for the carbon footprint of the proposed Al Ghaith
Chlor-Alkali Plant:
Scope 1 Direct Emissions these are defined as GHG emissions from sources the
reporting company owns or controls including the following examples:

Generation of electricity, heat, or steam. These emissions result from combustion

of fuels in stationary sources, e.g., boilers, furnaces, turbines.

Physical or chemical processing.

Most of these emissions result from
manufacture or processing of chemicals and materials, e.g., cement, aluminum,
adipic acid, ammonia manufacture, and waste processing.

Transportation of materials, products, waste, and employees. These emissions

result from the combustion of fuels in company owned/controlled mobile
combustion sources (e.g., trucks, trains, ships, airplanes, buses, and cars).

Fugitive emissions. These emissions result from intentional or unintentional

releases, e.g., equipment leaks from joints, seals, packing, and gaskets; methane
emissions from coal mines and venting; hydrofluorocarbon (HFC) emissions
during the use of refrigeration and air conditioning equipment; and methane
leakages from gas transport.

Scope 2 Indirect Emissions these are defined as GHG emissions from the generation of
purchased electricity that is consumed in a companys owned or controlled equipment or
operations.
Scope 3 Other Indirect Emissions these are defined as indirect GHG emissions that do
not fall within Scope 2.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 55

Some of these activities will be included under scope 1 if the pertinent emission sources
are owned or controlled by the company (e.g., if the transportation of products is done in
vehicles owned or controlled by the company).
GHG emissions from the Chlor-Alkali Plant will consist primarily of nominal quantities of
CO2. CO2 emissions from normal operation of the natural gas fired units (boiler and
flaking unit) were estimated using USEPA AP-42 emission factors, and are provided in
Table 4 -5 and Table 4 -6. These estimates amount to a total of only 5521 t/year of CO 2.
This proportion is expected to be significantly lower based on future estimates of national
CO2 emissions when the Chlor-Alkali Plant is operational.
Fugitive emission of CO2 is likely during the purification of brine with sodium carbonate,
and it is estimated that 10 gm of carbon dioxide is released per ton of caustic soda
production. Fugitive CO2 emission is also likely from the chlorine destruction unit and
handling.
It is considered that the overall environmental impact to air quality in the Project area for
this aspect due to construction, operation and decommissioning is of low risk.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Significant

Likely

Insignificant

Low Risk

Project Number 44130065

Page 56

5.1.3. Mitigation Measures

5.1.3.1.

Potential Mitigation Measures

Phase

Consequence

Impact
Description

Probability

Score

Risk

Applicable
Environmental
Standard / Limits

Potential Mitigation

Adopt traffic routing to maximise travel on paved roads

wherever possible.
Minor

Construction

Rare

Enforce speed restrictions

Low

Ensure minimization of double-handling

Ensure wet suppression of unpaved routes

Enforce speed restrictions

Operation

Minor

Ensure minimization of double-handling

Likely

Emissions from
Operation of
Fuel-Consuming
Vehicles and
Plant Equipment

Ensure regular maintenance of construction machinery

and vehicles to ensure efficient operation

Low

Ensure regular maintenance of construction machinery

and vehicles to ensure efficient operation

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Minor

Decommissioning

Rare

Regular maintenance of the GTs according to

manufacturer specifications to limit potential for nondesign emissions due to malfunction

Low

Same as for the Construction Phase

Project Number 44130065

Page 57

EAD Ambient Air

Quality Standards
for the Emirate of
Abu Dhabi
WHO Air Quality
Guidelines 2005
IFC EHS
Guidelines on Air
Emissions and
Ambient Air
Quality 2007

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Construction,
operation and
decommissioning

Consequence
Insignificant

Emissions of
Greenhouse
Gases

Phase

Likely

Impact
Description

Probability

Score

Risk

Low

Applicable
Environmental
Standard / Limits

Potential Mitigation

Ensure valves on refrigerant gas cylinders are normally

kept shut
Use of alternate refrigerants that do not have a GHG
impact.

Project Number 44130065

Page 58

Not Applicable

Phase

Consequence

Impact
Description

Probability

Score

Risk

Construction

Minor

Ensure appropriate internal wiring is utilised in

construction machinery and it is run according to the
manufacturers specifications as well as regularly
inspected and maintained.

Rare

Emissions from
Accidental
Events

Applicable
Environmental
Standard / Limits

Potential Mitigation

Low

Prepare a project emergency response plan addressing

appropriate emergency procedures to be followed in case
of a fire occurring during construction works.
Ensure appropriate temporary storage of chemicals on
site in cognizance of their flammable nature and in
accordance with industry best practices.
Enforce an indoor no-smoking policy and train relevant
employees in fire safety to minimise occurrence of
human-induced fires.

Major

Operation

Rare

Procedural safeguards such as operating procedures and

training will be required as good management practices.
Moderate

Enforce a no-smoking zone around the back-up fuel

storage tanks to minimise the potential for fuel ignition

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Minor

Decommissioning

Rare

Enforce site emergency response requirements in the

event of a fire occurring, to facilitate putting it off at the
earliest possible

Low

Same as for the Construction phase

Project Number 44130065

Page 59

EAD Ambient Air

Quality Standards
for the Emirate of
Abu Dhabi
WHO Air Quality
Guidelines 2005
IFC EHS
Guidelines on Air
Emissions and
Ambient Air
Quality 2007

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 60

5.1.3.2.

Selected Mitigation Measures

Emissions from Operation of Fuel-Consuming Vehicles and Equipment

Construction
The overall potential for significant adverse impacts from construction-generated dust is
considered to be unlikely due to the following reasons:
Project construction activities will mostly involve native soils as per the Soil Baseline
Assessment conducted at the project site;
Dust and fugitive emissions are controlled through the application of the following
measures:
Regular inspection and dust suppression (misting) of stockpiles where
necessary (including wind shielding, storage away from site boundaries, and
restricted height of stockpiles);
Provisions for wheel washing and wet suppression during loading of wagons /
vehicles in instances of potential high dust environments;
Covering vehicles carrying dry spoils and other wastes;
Restricting vehicle speeds on access roads and other unpaved areas of the
site. A maximum speed of 20 km per hour will be strictly enforced over all
unimproved surfaces within the construction zones;
Equipment exhausts will be directed vertically upwards where possible and
stationery equipment will be sited as far from sensitive receptors and
inhabited buildings as is feasible;
Wherever possible plant and equipment engines will not operate for long
periods if the equipment is not in use. When feasible, electrically powered
equipment will be used instead of petrol or diesel, including welding
machines, pressure washers, air compressors, etc.;
Unpaved roads will be routinely misted with water during dry periods and
according to weather conditions; and
No onsite burning or incineration of waste materials will be allowed within the
construction zones.
Operations
The steam boiler and the flaking unit will include low NOx burners to effectively reduce
NOx emissions to meet EAD permissible limit of 55 mg/N m3. The SOx emissions will be
below the MoEs permissible limit of 500 mg/Nm3.
Entire chlorine gas from the electrolysis section will be will be sent to the main chlorine
gas header in the HCl synthesis unit. Chlorine-containing waste gas streams will be
diverted to the chlorine absorption unit where it will be absorbed by diluted caustic in the

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 61

scrubber to produce sodium hypochlorite. The chlorine absorption unit will be designed
with a treatment capacity sufficient to absorb the full cell-room production in the event of
emergencies.
The chlorine absorption unit will lower the chlorine content in the emitted gas during
operation to less than 1.72 ppmv (5 mg/Nm3) in the worst-case scenario compared to 20
ppmv of USEPAs permissible limits - Maximum Achievable Control Technology (MACT).
In addition, the emitted HCl vapour will be less than 6.70 ppmv (10 mg/N m3) in the worstcase scenario compared to 12 ppmv of USEPAs permissible limits (MACT).
All of the hydrogen gas produced during electrolysis of salt in the production will be used
onsite as chemical feedstock for production of HCl in the HCl synthesis unit. The
hydrogen gas will be safely handled in the production of HCl by providing an emergency
vent in the process line. The entire vent system will be designed to include a flame sensor
and a steam and nitrogen purging mechanisms. In addition, the process safety relief
valves will be connected to vent system, and during process upset, these safety relief
valves will be activated for venting the hydrogen gas to avoid unsafe conditions. The
Chlor-Alkali Plant will also install hydrogen gas holder in the system to minimize the
process upsets and to reduce venting.
During loading of caustic and NaOCl, fugitive emissions are not anticipated. However,
fugitive emissions are likely during HCl loading. A small scrubbing unit with an efficiency
of 95% will be provided to control these fugitive emissions during HCl loading.
Expected HCl concentration at the loading area will be less than 0.033ppm (0.05 mg/m 3)
and the HCl concentration in the scrubber outlet during loading operation will be
approximately 0.17 ppm (0.25 mg/m3).
In summary, the air emissions under normal operations for the Al Ghaith Chlor-Alkali
project are not expected to have any significant impact.
Decommissioning
Same as for the Construction phase above.
Emissions of Greenhouse Gases
Construction, Operation and Decommissioning
The EPC Site Environmental Manager and/or EPC Maintenance Manager will encourage
implementation of good construction practices with respect to handling GHG containing
materials such as refrigerants, as mentioned in Section Error: Reference source not
found. This will be to ensure that fugitive emissions from improperly closed storage
containers are prevented.
This would typically involve ensuring that safety valves on refrigerant gas containing
cylinders are only opened when they are in use and otherwise kept normally shut to
reduce the potential for fugitive emissions.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 62

However, the best form of mitigation would be to utilize alternate refrigerant gas that does
not have a GHG impact.
Emissions from Accidental Events
Construction
The EPC Site Environmental Manager will ensure that appropriate internal wiring is
utilised in construction machinery and it is run according to the manufacturers
specifications in order to reduce the potential for a fire occurring due to a short-circuit and
therefore the resulting combustion emissions. Additionally, it will also be ensured that the
machinery is regularly inspected and maintained in order to reduce the potential for nondesign performance of the equipment and therefore resulting higher direct exhaust
emissions.
The EPC Site Environmental Manager will also ensure that flammable chemicals on site
are temporarily stored in accordance with the manufacturers and MSDS requirements, in
order to reduce the potential for an accidental fire occurring.
As a further fire preventative measure, the EPC Site Environmental Manager will also
enforce an indoor no-smoking policy within the site buildings (i.e. offices) to reduce the
potential for human-induced fires occurring. Relevant employees will also be trained in
the measures to be followed in case a fire breaks out so that it can be controlled soon
after break-out and the risk to employees health reduced.
The EPC Site Environmental Manager will also prepare a project emergency response
strategy/plan addressing appropriate emergency procedures to be followed in case of a
fire occurring during construction works. Again, this will ensure that a fire can be
controlled soon after it breaks out and the risk of deterioration of ambient air quality and
employees health is reduced.
Operation
The potential for accidental release of chlorine gas poses a risk in chlor-alkali plants, and
that can be addressed on several levels requiring mitigation/control measures and
emergency response programs.
A quantitative risk assessment (QRA) will be performed at the Al Ghaith plant subsequent
to commissioning of the plant to further assess the accidental chlorine release hazards.
The caustic scrubber, with an overall operating efficiency of at least 95%, will be the
primary chlorine gas control device. As discussed earlier regarding the control measures,
entire chlorine gas produced will be sent to the main chlorine gas header in the HCl
synthesis unit. Moreover, chlorine-containing waste gas streams from the HCl synthesis
unit will be diverted to the chlorine absorption unit (hypo unit) where the gas will be
absorbed by diluted caustic in a double-staged scrubber to produce sodium hypochlorite.
The chlorine absorption unit will be designed with a treatment capacity sufficient to
absorb the full cell-room production in the event of emergencies.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 63

Excess chlorine vented to the scrubber can deplete the active scrubbing material and
cause over-chlorination of the scrubber. This will result in release of toxic chlorine gas.
Therefore, active safeguards will be incorporated within scrubbing mechanism to avoid
over-chlorination.
Following active safeguards will be included in the scrubbers to prevent over-chlorination:

Emergency and automatic shut-off of chlorine upon high Oxidation-Reduction

Potential (ORP) alarms. ORP will track the concentration of caustic in the
scrubber liquid;

Automatic or remote caustic injection to interrupt decomposition reaction; and

Use of contactors in the scrubbers to maintain slight vacuum on the chlorine vent
lines to reduce leaks to atmosphere.

In addition, procedural safeguards such as operating procedures and training will be

required as good management practices. Moreover, published guidance on scrubber
should provide specific information on the composition, quantity and duration of emission
expected during over-chlorination incidents.
The emergency response measures to be undertaken in an event of accidental chlorine
gas release are included in the Plant Disaster Management Plan (DMP). As discussed in
the plan, the initial isolation distance will extend equally in all directions from the release,
even upwind. When the gas is released at the ground level, the gas may travel upwind
due to natural turbulence created by the wind. Also, studies have shown, under windless,
night time conditions, the toxic dense gas spread out in all directions from the source near
the ground. As expected, the bulk of toxic gas or vapour plume will be carried downwind.
To assure that the plans are well organized for any contingency, the plant has adequate
resources to plan for emergency response.
Decommissioning
Same as for Construction phase.
5.1.3.3.

Mitigation Measures to Address Cumulative Impacts

No cumulative impacts are expected as a result of this project.

5.1.3.4. Residual Impacts
There are no significant residual impacts expected as a result of this project.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 64

5.1.4. Monitoring Program

5.1.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

Emissions from Operation of Fuel-Consuming Vehicles and Plant Equipment

Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Site traffic using paved roads

Daily

EPC Site Environmental

Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Daily

EPC Site Environmental

Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Daily

EPC Site Environmental

Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Maintenance of site vehicles and

construction machinery

Monthly

EPC Site Environmental

Manager

Weekly Environmental Inspection

Checklist,
Quarterly Environmental Audit
Report

Site traffic following speed restrictions

Daily

Al Ghaith Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Daily

Al Ghaith Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Site traffic following speed restrictions

Construction
Wet suppression of unpaved roads

Operation

Double-handling of vehicles minimized

Maintenance of site vehicles and plant

machinery

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Monthly

Al Ghaith Environmental
Manager

Project Number 44130065

Page 65

Weekly Environmental Inspection

Checklist,
Quarterly Environmental Audit
Report

Project Phase

Monitoring Activity

Frequency

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Site traffic using paved roads

Daily

Site traffic following speed restrictions

Daily

Al Ghaith Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Daily

Al Ghaith Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection
Checklist

Monthly

Al Ghaith Environmental
Manager

Weekly Environmental Inspection

Checklist,
Quarterly Environmental Audit
Report

Wet suppression of unpaved roads

Maintenance of site vehicles and

construction machinery

Al Ghaith Industries

Reporting

Al Ghaith Environmental
Manager

Decommissioning

PEHSR Chlor-Alkali Plant

Responsibility

Project Number 44130065

Page 66

Emissions of Greenhouse Gases

Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Construction

Shutting off safety valves on refrigerant

gas containing cylinders

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental
Inspection Checklist

Quarterly

Al Ghaith
Operations Manager

Quarterly Environmental Report

to EAD

Daily

Al Ghaith
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental
Inspection Checklist

Frequency

Responsibility

Reporting

Weekly

EPC Site
Maintenance
Coordinator

Weekly Field Maintenance

Report

Monthly

EPC Site
Environmental
Manager

Weekly Environmental
Inspection Checklist,
Quarterly Environmental Audit
Report

Flammable chemicals appropriately

stored

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental
Inspection Checklist

Indoor no-smoking policy enforced

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental
Inspection Checklist

Gas boiler stacks emissions:

Operation

- Concentrations of CO2

Decommissioning

Shutting off safety valves on refrigerant

gas containing cylinders

Emissions from Accidental Events

Project Phase
Construction

Monitoring Activity
Appropriate internal wiring utilized in
construction machinery

Maintenance of site vehicles and

construction machinery

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 67

Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Quarterly

EPC Site
Environmental
Manager

Quarterly Environmental Audit

Report

Daily

Al Ghaith
Environmental
Manager

N/A

Once

Al Ghaith Health
and Safety
Manager / Al
Ghaith Executive
Management

Process / Operational Procedure

Documentation

Quarterly

Al Ghaith
Environmental
Manager

Quarterly Environmental Audit

Report

Weekly

EPC Site
Maintenance
Coordinator

Weekly Field Maintenance

Report

Monthly

EPC Site
Environmental
Manager

Weekly Environmental
Inspection Checklist,
Quarterly Environmental Audit
Report

Flammable chemicals appropriately

stored

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental
Inspection Checklist

Indoor no-smoking policy enforced

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental
Inspection Checklist

Fire response procedure documented

and relevant employees trained in it
Controlled Access of plant
personnel/visitors to site

Operation

Appropriate Plant Disaster Management

Plan implemented

Fire response procedure documented

and relevant employees trained in it
Appropriate internal wiring utilised in
contraction machinery

Maintenance of site vehicles and

construction machinery
Decommissioning

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 68

Project Phase

Monitoring Activity
Fire response procedure documented
and relevant employees trained in it

Frequency

Responsibility

Reporting

Quarterly

EPC Site
Environmental
Manager

Quarterly Environmental Audit

Report

Monitoring programs suggested in Sections Error: Reference source not found will minimise the impact as far as considered
practical, with commitment to these measures provided in Section 7 Statement of Commitments of the EIA. These measures will
also be reflected in the EPC Contractors Project Construction Environmental Management Plan (CEMP) and the Al Ghaith
Industries Operations Environmental Management Plan (OEMP). Compliance monitoring carried out as part of implementation of
the afore-mentioned documentation (e.g. periodic inspections, audits) will assess for compliance of monitoring with the specified
mitigation measures.
5.1.4.2. Monitoring Program for Cumulative Impacts
The monitoring program presented in Section 5.1.4.1 is designed to help address both non-cumulative and cumulative impacts. No
additional monitoring is planned to deal with cumulative impacts specifically.
5.1.4.3. Monitoring Program for Residual Impacts
The monitoring program presented in Section 5.1.4.1 is designed to help evaluate residual impacts. No additional monitoring is
planned to deal with residual impacts specifically.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 69

5.2.

Marine Water

5.2.1. Description of Environment

The coast of the UAE forms the southern margin of the Arabian Gulf. EAD (2007)
describes the main coastal and marine habitats of Abu Dhabi as seagrass beds, salt
marshes, coral and mangrove communities. The Project site is a highly disturbed area.
Historically the site would have consisted of sheltered tidal flats consisting of fine-grained
sediments, mostly sand and mud. It may have supported mangrove and intertidal
communities. Common species found in these environments are crabs, shrimps,
gastropods, bivalves, polychaetes, foraminifera and fish. Now the marine environment
adjacent to the site is a well defined, dredged boating channel and is likely to contain a
low diversity of species. Water depths are relatively shallow and contain a microbial mat
type ecosystem. In the restricted lagoons, tidal movement tends to be at right angles to
the coast. During low tide extensive parts of channels are exposed and evaporation of
the intertidal waters results in increased salinities.
The Project site is located in the centre of the MIA, approximately 1.2 km away from the
coast. Due to the distance from any marine water, any consideration of impacts is not
necessary. There are no information gaps and no baseline survey or mitigation will be
required for this aspect. Impacts to local water bodies will be considered in the soil and
groundwater section.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 70

5.3.

Waste Management

5.3.1. Description of Environment

The UAE generates some of the highest volumes of waste per capita in the world. About
6 million tonnes of waste is produced in the Emirate of Abu Dhabi annually. The Al Ghaith
Project will generate solid waste, liquid waste and hazardous waste streams during
construction, operations and decommissioning of the plant which will add to the Emirates
waste management requirements.
Federal Law No. (24) of 1999, Article (52) states that all parties and/or individuals
involved in construction and/or demolition activities where waste can be generated, must
undertake all necessary precautions to prevent the dispersion of the generated waste to
the surrounding environment, including safe storage and transportation of such waste.
EAD has recently released a Code of Practice AD EHSMS CoP 16 Waste Management
which outlines the responsibilities for waste management. Additional information is
contained with the IFCs EHS Guidelines for Thermal Power Plants.
Particular requirements for waste generators are stated within Law No. (21) of 2005 for
the Emirate of Abu Dhabi as follows:

Reduce the generated waste by means of implementing the regulations, methods,

techniques and alternatives approved in the Emirate for classifying, sorting,
reusing or recycling waste.

Classify the generated waste to hazardous and non-hazardous waste as indicated

in the approved relevant guidelines.

In case of contract with the private sector for transporting, storage, treatment or
disposal of waste, the following must be carried out by Environmental Service
Providers permitted by the Competent Authority.

Waste generated from the Project will be managed using a lifecycle approach, which
takes into account the HSE risks associated with storage, handling and disposal. The
guiding philosophy is to ensure where possible waste is reduced, reused or recycled.
This is achieved through a process of identifying the waste; maintaining an inventory;
characterising the wastes; segregation; and then looking for ways to minimise waste
generation. Certain plastics, metals, glass, paper products, waste oil, and organic
material will be recycled wherever possible.
The Abu Dhabi Municipality is responsible for municipal solid waste treatment and
disposal in the Emirate. There are approximately ten operational landfill sites within the
Emirate. The largest is the Al Dhafra landfill which is approximately 60 km south west of
Abu Dhabi city. It is expected this landfill will receive the majority of solid wastes
generated by the Chlor-Alkali Project. Recycling centres at the Al Dhafra landfill include
construction waste and a proposed tyre recycling facility. The Abu Dhabi Municipality has
also planned a composting facility, a new sanitary landfill, and an inert waste landfill area
beside the existing landfill at the Al Dhafra site. There are additional plans for five

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 71

transfer stations for solid waste in the Western Region on the sites of existing landfills; a
new sanitary landfill beside the site of the existing landfill of Ruwais; a green waste
composting facility at the Ruwais site; upgrade of the green waste composting facilities at
Liwa and Ghayathi, and improved transportation systems for waste between the different
sites.
Liquid wastes from Al Ghaith are planned to be treated at the 300,000-cubic-metre-a-day
(cm/d) Al-Wathba wastewater treatment plant in Abu Dhabi or the 65,000-cm/d Al-Saad
wastewater treatment plant in Al-Ain.
Hazardous wastes will be removed by the appointed Environmental Service Provider for
treatment and disposed at approved Municipality sites. Solid hazardous wastes are
mostly disposed to landfill however a specialised plant to treat 15,000 tonnes of
hazardous waste has been proposed by the Centre of Waste Management Abu Dhabi for
Al Dhafra, about 12km from the current landfill site.
Medical waste will be treated within Musaffah and then removed to Al Dhafra landfill for
disposal. In Abu Dhabi there are currently only two private companies that collect,
transfer and treat medical waste by non-incineration techniques.
Hazardous liquid industrial wastes will be treated on site before being either discharged
into a sewerage network through consent with Abu Dhabi Sewerage Services Company
(ADSSC) or given to an appointed Environmental Service Provider for treatment and
disposal.

5.3.2. Environmental Impact Prediction and Evaluation

5.3.2.1.

Solid Waste

Construction
The Al Ghaith Project will generate approximately 50 m 3/week of solid waste during the
construction phase. This may comprise of scrap metal, timber, rocks, plastic, insulation
and packing material used for transport of materials; used lubricating oils, solvents and
cleaners from the maintenance of construction equipment; paint; and other wastes.
These could potentially impact the soil and groundwater.
Solid waste management on site will be described in detail in the CEMP and be done in
accordance with AD EHSMS CoP 16 Waste Management.
Given the control measures in place the magnitude of impacts from solid waste during
construction is considered to be local to the project site. Waste arising from construction
operations will occur but will be limited to a finite time period. The consequence of
disposing this waste from site will be insignificant. Overall, the risk posed by effectively
managed waste disposal will be low.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Likely

Insignificant

Low

Project Number 44130065

Page 72

Operation
Solid wastes generated at the Chlor-Alkali Plant during the brine purification will consist of
used materials such as pre-coat and feed material made of cellulose. The pre-coat filter
sludge from the brine softener will consist mainly of alpha-cellulose, contaminated with
iron hydroxide and silica.
During operation of sludge filtration, Chlor-Alkali Plant is expected to produce
approximately 475 tons of brine sludge waste /year.
The sludge filtration system will consist of:

Sludge receiving tank

Sludge filter

Sludge conveyer

Sludge container for disposal

Filtrate tank

Associated pumps

Brine sludge (based on analysis of sludge cake) will consists of:

Barium sulphate (BaSO4)

Magnesium hydroxide (Mg(OH)2)

Calcium chloride (CaCl2)

Sodium chloride (NaCl)

Sodium Sulphate (Na2SO4)

Insoluble materials and trace metals (copper, iron, nickel, zinc)

Spent membranes and gaskets from membrane cells will be other waste streams
remaining after their service life. Solid waste management on site will be done in
accordance with AD EHSMS CoP 16 Waste Management.
Waste from site will require frequent disposal, however the consequence of disposing this
waste from site will be insignificant. Overall, the risk posed by effectively managed waste
disposal will be moderate.
Probability

Consequence

Risk

Frequent

Insignificant

Moderate

Decommissioning
Decommissioning of the Al Ghaith Plant is expected to create a significant quantity of
solid waste, and waste water.
Solid waste management on site will be described in detail in the DEMP and be done in
accordance with AD EHSMS CoP 16 Waste Management.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 73

Given the control measures in place the magnitude of impacts from solid waste during
construction is considered to be local to the project site. Waste arising from construction
operations will occur but will be limited to a finite time period. The consequence of
disposing this waste from site will be insignificant. Overall, the risk posed by effectively
managed waste disposal will be low.

5.3.2.2.

Probability

Consequence

Risk

Likely

Insignificant

Low

Liquid Waste

Construction
It is expected that the Al Ghaith Project construction workers (approximately 500 workers)
will be housed within existing worker camp/camps located in the MIA labour camp area,
and as a result, approximately 62,500 litres of sanitary wastewater will be generated per
day.
Aqueous commissioning wastewater will be generated (the bulk being approximately 300
m
3) during hydro-testing; although it should be noted that hydro-testing will take place
infrequently) during the commissioning process.
Liquid waste management on site will be described in detail in the CEMP and be done in
accordance with AD EHSMS CoP 16 Waste Management.
Liquid waste arising from construction operations will occur but will be limited to a finite
time period. The consequence of disposing this waste from site will be insignificant.
Overall, the environmental risk posed as a result of liquid waste management during the
construction phase will be low.
Probability

Consequence

Risk

Likely

Insignificant

Low

Operation
It is expected that 8 m3/hour of wastewater will be generated intermittently during normal
process by the Chlor-Alkali Plant. Minimal amount of wastewater is also expected to be
generated via rainwater/stormwater runoff (approximately 12 liters/hour
discontinuously).
i.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Waste water generated at the plant will originate from various operations as
listed below:

During regeneration of the ion-exchange resins (employed during secondary

brine purification process), wastewater containing trace amounts of dissolved
metals (nickel, zinc, iron, copper) will be generated;

During purification of the brine, high concentration of chloride, chlorates, and

oxidants may accumulate. Chlorates may also form as by-products during

Project Number 44130065

Page 74

electrolysis. Due to the recycling of the brine, the following components may
build-up;
o

Sulfate ions may often have a negative effect on the electrolysis

process (damages the anode coating). Bleeding of the brine treatment
system will be conducted periodically to reduce the levels of sodium
sulfate and/or sodium chlorate in the cells. Wastewater will be
generated as result of bleeding of the circuit.

Chlorinated hydrocarbons may be formed in a reaction between

organic contaminants in the electrolyzer and free oxidants. Releases of
chlorinated hydrocarbons will normally be very low (approximately 20
kg/year), typically 0.03-1.16 grams per ton of chlorine produced.

Wastewater resulting from wash-outs of unit components, exhaust air

scrubber, and floors; and

Wastewater generated as a result of caustic evaporation.

As mentioned earlier, with the exception of blowdown water, the cooling water unit at the
proposed plant will not have any wastewater discharge.
ii.

iii.

Control measures to minimize effluent :

Recycling of brine (removing impurities) by ion-exchange resin unit.

Subsequent regeneration of resins will be accomplished by using caustic
soda and acid washing;

Using spent acid to control pH in process and wastewater streams;

Removal of precipitated salts from the brine through decantation/clarification

and filtration;

Minimizing the discharge of chlorate to water by applying acid conditions in

the anolyte (pH 1-2). Also, chlorate destruction in the brine circuit will be
conducted to remove chlorate before purging;

Removal of brine filtration sludge by flushing with a weak HCl solution. The
acid will cause the precipitate to dissolve and the resultant solution will be
discharged with the liquid effluent to the onsite wastewater treatment plant;
and

Recycling of water, wherever possible, utilizing Reverse Osmosis (RO) unit.

Treatment of waste water from the proposed plant:

Al Ghaith plans to install a wastewater treatment plant (WWTP) onsite to treat the
wastewater generated. The treated effluent will be re-used in the plant as process water
and also as irrigation water for the green belt.
The effluent from each process/utility area will be collected in trench drains, from where
the effluent will be diverted to the collection pit and further to the onsite combined WWTP.
Al Ghaiths WWTP will have a 100 m 3 tank with dual-compartments for neutralization and
storage of the wastewater streams.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 75

The combined WWTP will include:

Neutralization pit for pH adjustment (addition of acids and alkalis);

Removal of residual chlorine with the addition of sodium bi-sulphite;

Filtration consisting of dual-media sand and cartridge filters;

RO filtration; and

RO permeate recirculation.

The non-recyclable effluent with high Total Dissolved solids (TDS) and RO reject water
from the wastewater treatment plant will be disposed off in MIA Waste Management
Centre as per the current discharge practices from EAD.
It is expected that up to forty five (45) new staff will be required for the Chlor-Alkali Plant
(total for both shifts). This will result in generation of approximately less than 12 m 3/day
of sanitary water (based on 0.25 m 3/day sanitary wastewater generated per person and
the fact that a person will be within the Chlor-Alkali Plant for a few hours per day).
Liquid waste management on site will be managed in accordance with AD EHSMS CoP
16 Waste Management.
Liquid waste arising from operations will over regularly over a time period of 20 to 30
years. The consequence of disposing this waste from site will be insignificant. Overall,
the risk posed by effectively managed waste disposal will be moderate.
Probability

Consequence

Risk

Frequent

Insignificant

Moderate

Decommissioning
Decommissioning of the Al Ghaith facilities could potentially create a significant quantity
of wastewater (if decontamination is required).
As mentioned above, a decommissioning plan will be prepared which will also include
and provide measures to manage and adequately dispose of wastewater generated
during decommissioning. The project will keep its existing wastewater treatment plant in
service and decommission it last, whereby the wastewater generated can be treated, thus
helping to potentially reduce the impacts.
Liquid waste management on site will be described in detail in the DEMP and be done in
accordance with AD EHSMS CoP 16 Waste Management.
Liquid waste arising from decommissioning operations will occur but will be limited to a
finite time period. The consequence of disposing this waste from site will be insignificant.
Overall, the environmental risk posed as a result of liquid waste management during the
construction phase will be low.
Probability

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Consequence

Risk

Project Number 44130065

Page 76

Likely

5.3.2.3.

Insignificant

Low

Hazardous Waste

The Al Ghaith Plant is not expected to generate hazardous waste; in case it does
generate this, then this can be disposed off at the local Hazardous Waste Management
facility. Other facilities within MIA will also be generating wastes, but it is expected that
the MIA WMF (for regular and hazardous waste) will be able to meet the demands thus
helping mitigate the cumulative impacts arising due to waste generation.
Hazardous waste management on site will be described in detail during each project
phase and will be managed in accordance with AD EHSMS CoP 16 Waste Management.
Only designated, trained personnel will have access to the storage area. A spill response
plan will be in place and staff will be trained in handling hazardous waste and spill
response procedures. Spill kits will be easily accessible around the site during
construction.
Given the control measures in place the magnitude of impacts from hazardous waste is
considered to be local in nature. Overall, it is considered the impact as a result of solid
and liquid hazardous waste management during the construction, operation and
decommissioning phases will be low.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Possible

Insignificant

Low

Project Number 44130065

Page 77

5.3.3. Mitigation Measures

Potential Mitigation Measures

Operation

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Frequent

Construction

Likely

Solid Waste

Consequence
Insignificant

Phase

Insignificant

Impact
Description

Probability

Score

Environmental Risk

5.3.3.1.

Applicable
Environmental
Standard / Limits

Potential Mitigation

CEMP to include solid waste management.

Reduce, reuse, recycling of wastes where possible.
Low

Low

Dedicated solid waste storage area on site.

Storage area to have hard standing base and appropriate
drainage.
Segregate wastes where feasible.
Inventory maintained for wastes on site.

Project Number 44130065

Page 78

AD EHSMS CoP
16 Waste
Management

Environmental Risk

Consequence

Decommissioning

Insignificant

Phase

Probability

Impact
Description

Likely

Score

Moderate

Applicable
Environmental
Standard / Limits

Potential Mitigation

Waste transfer notes used for Environmental Service

Providers.
Appointed Environmental Service Provider to prepare a
waste management plan for the site including frequency
of collections.
Good site housekeeping.

Construction

Insignificant

Liquid Waste

Likely

Covering of soil stock piles.

Low

CEMP
include
liquid
management.
Colour to
coded
skips
andwaste
rubbish
bins around site.
Monitoring
andfor
treatment
of allstorage
effluentareas.
discharges to the
Clear signage
solid waste
marine environment to ensure that they meet ADWEAs
Training
of staff
in waste
management
permissible
discharge
limits
set for this procedures.
project.
Materialswater
ordered
a hydrotesting.
as needs basis.
Potable
usedonfor
Preparation
of arecycling
decommissioning
Reduce, reuse,
of wasteswaste
wheremanagement
possible.
plan.
Dedicated liquid waste storage area on site.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 79

AD EHSMS CoP
16 Waste
Management

Operation

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Environmental Risk

Consequence
Insignificant

Phase

Frequent

Impact
Description

Probability

Score

Moderate

Applicable
Environmental
Standard / Limits

Potential Mitigation

Liquid wastes stored in good quality, sealed and labelled

drums.
Incompatible liquid wastes stored separately.
Storage area to have hard standing base and appropriate
drainage.

Project Number 44130065

Page 80

Environmental Risk

Consequence

Decommissioning

Insignificant

Phase

Probability

Impact
Description

Likely

Score

Low

Applicable
Environmental
Standard / Limits

Potential Mitigation

Segregate wastes where feasible.

Inventory maintained for wastes on site.
Waste transfer notes used for Environmental Service
Providers.
Appointed Environmental Service Provider to prepare a
waste management plan for the site including frequency
of collections.
Good site housekeeping.
Clear signage for liquid waste storage areas.
Training of staff in waste management procedures.
Chemicals ordered on a as needs basis.
Spill response plan and appropriate staff spill response
training in place.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 81

Environmental Risk

Phase

Consequence

Impact
Description

Probability

Score

Applicable
Environmental
Standard / Limits

Potential Mitigation

CEMP to include hazardous waste management.

Dedicated hazardous waste storage area on site.
Hazardous liquid wastes stored in good quality, sealed
and labelled drums.
Incompatible hazardous wastes stored separately.
Storage area to have hard standing base and appropriate
drainage.

Construction,
operations and
decommissioning

Minor

Hazardous
Waste

Possible

Storage area only to be accessible to approved and

trained staff.
Segregate hazardous wastes where feasible.
Moderate

Inventory maintained for wastes on site.

Appointed Environmental Service Provider to prepare a
waste management plan for the site including frequency
of collections.
Clear signage for hazardous waste storage areas.
Chemicals ordered on a as needs basis.
Spill response plan and appropriate staff spill response
training in place.
Spill kits easily accessible on site.
Preparation of a decommissioning waste management
plan.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 82

AD EHSMS CoP
16 Waste
Management

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 83

5.3.3.2.

Selected Mitigation Measures

Final solid, liquid and hazardous waste mitigation measures will be presented in the
CEMP. It is planned that all mitigation measures presented in Section 5.3.3.1 will be
implemented as per best practice outlined in EAD Code of Practice AD EHSMS CoP 16
Waste Management.
5.3.3.3.

Mitigation Measures to Address Cumulative Impacts

The mitigation measures presented in Section 5.3.3.1 are designed to help address both
non-cumulative and cumulative impacts. No additional mitigation measures are planned
to deal with cumulative impacts specifically.
5.3.3.4.

Residual Impacts

Residual impacts associated with all waste management practises will be reduced to low
with the implementation of selected mitigation. Impacts will not be removed there will
continue to be the potential for accidental impacts from spills and leaks as well as the
ongoing impacts from solid waste and controlled effluent discharges. Therefore, scores
as presented in Section Error: Reference source not found remain applicable.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 84

5.3.4. Monitoring Program

5.3.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

Waste type

Measurements

Solid waste

Quantities and types of solid waste stored on site

Daily

Liquid waste

Quantities and types of liquid waste stored on site

Daily

Hazardous waste

Quantities and types of hazardous waste stored on site

Daily

Process water
discharge

Water quality testing against ADWEAs permissible discharge limits set for this
project

Monthly

Waste water treatment

plant discharge

Water quality testing against ADWEAs permissible discharge limits set for this
project

Monthly

Stormwater discharge

Water quality testing against ADWEAs permissible discharge limits set for this
project

Monthly

Sewage treatment plant

discharge

Water quality testing against ADWEAs permissible discharge limits set for this
project

Monthly

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Frequency

Project Number 44130065

Page 85

Responsibility
Al Ghaith
Environmental
Manager
Al Ghaith
Environmental
Manager
Al Ghaith
Environmental
Manager
Al Ghaith
Environmental
Manager
Al Ghaith
Environmental
Manager
Al Ghaith
Environmental
Manager
Shared Facilities
Environmental
Officer

5.3.4.2. Monitoring Program for Cumulative Impacts

The monitoring program presented in Section 5.3.4.1 is designed to help address both
non-cumulative and cumulative impacts. No additional monitoring is planned to deal with
cumulative impacts specifically.
5.3.4.3. Monitoring Program for Residual Impacts
The monitoring program presented in Section 5.3.4.1 is designed to help evaluate
residual impacts. No additional monitoring is planned to deal with residual impacts
specifically.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 86

5.4.

Geology, Seismicity, Soil and Groundwater

5.4.1. Description of the Environment

5.4.1.1.

General Geology

The Arabian Peninsula has a variety of environments, including sand and rock desert,
sabkha, and mountains. The UAE occupies a north-east corner of the Arabian Peninsula,
and is characterised by the Hajar Mountains running parallel to the east coast and south
into Oman along the UAE boarder, vast sand desserts stretching from the plains by the
mountains south to the Empty Quarter bordering Saudi Arabia, and coastal Sabkha flats.
The coastline is also characterised by a number of offshore islands.
The Project site is located on to the south of Abu Dhabi Island. Bedrock in the area is
recorded to comprise interbedded variable beds of clastic and carbonate sandstones,
gypsiferous mudstone, siltstone, gypsum, limestones, and conglomerates which are
mostly Pleistocene or recent in age.
Superficial deposits in the area are generally considered to comprise predominantly sand
dunes, wind-blown (aeolian) deposits and evaporite deposits interbedded with marine
sands and silts. Sabkha deposits are also common along the coastline of the UAE and
are generally encountered in the typically flat foreshore zone, where groundwater levels
are at or near the surface. The regional geological setting of the Project site is indicated
in Figure XXX.
5.4.1.2.

Seismicity

EAD (2008) describes the main tectonic province in Abu Dhabi as a passive plate margin
(intracratonic) which is dominated by large, gentle folds of various shapes and size
related to differential regional subsidence or uplift along the deep-seated basement faults.
Abu Dhabi Emirate is located in the northeast Rub Al Khali basin. The boundaries of this
basin are controlled by faults of different ages. Several left-lateral wrench faults have
been identified. Around Abu Dhabi a NE-SW fold alignment is dominant (the Jarn
Yaphour trend) with a system of faults running parallel to this trend. On the Arabian
Shield of the UAE mainland maximum predicted magnitudes are 5.0 5.5 (Richter).
In general, the Arabian plate is considered to be relatively stable and there is a low risk of
a large earthquake occurring in the vicinity of the site. While it remains a low risk, it
should be noted that where very loose, water bearing silty fine soils are present on site
there is a potential risk of liquefaction under earthquake loading. Liquefaction of fine soils
can result in excessive settlement of structures founded above such material. The Al
Ghaith Chlor-Alkali Plant site area comprises an upfilled platform of imported material.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 87

Figure 1-13

Figure 1-14

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Seismic events (plotted dots) within the Southern Arabian Gulf

since 1990. Plate boundaries are shown in yellow

Ground acceleration (m/s) with 10% probability of exceedance in

50 years

Project Number 44130065

Page 88

5.4.1.3.

Soil and Groundwater

The Project site borders a tidal channel and has a low gradient coastal profile. According
to EAD (2008) historically the landscape consisted of wide and extensive intertidal
cyanobacterial mats and evaporative flats. The tidal flat sediments and evaporites are
flanked by stranded high energy beach ridges and reworked late Holocene Aeolian and
outwash fans. The Holocene sediments accumulate on Neogene sedimentary rocks
consisting of a sequence of marls, sandstones, limestones and evaporates. Banked up
against the Neogene rocks and covering them are Quaternary carbonates. The
sedimentary rocks were deposited during the last major glacial eustatic low stand in the
Arabian Gulf. These largely Aeolian sands line the inner margins of the present day salt
flats or sabkhas, and their surface often lies close to the present water table. They
underlie much of the Holocene carbonate/evaporate complex.
Since development of the MIA the site has been up-filled and levelled which has changed
the nature of the site. The original coastal sabkha characteristics can generally be
observed after drilling below two meters below ground level. The up-fill is likely to have
been a mix of dredge spoil and imported soil from nearby borrow pits, consisting of
carbonaceous materials and silicates. The site is no longer influenced by tidal inundation.
It will however experience occasional heavy rainfall from storm events. Due to its close
proximity to the channel the water table will largely mirror the average seawater level.
Water levels are therefore likely to be two or three meters below ground level and
experience some mixing with the seawater.
Due to the high salinity of the groundwater it is not used for any potable, irrigation or
industrial use. It is not known whether there are any monitoring wells on site. The site
has been used for general material storage up until now and there is no known
contamination of soil or groundwater on site.

5.4.2. Environmental Impact Prediction and Evaluation

The proposed development is within an industrial site. The top soil at the site has been
removed, so there will be no new impact with regard to the loss or deterioration of soil as
a result of this project.
As natural groundwater quality in MIA is saline and it is not suitable for domestic or
industrial use, the main concern is that groundwater could provide a pathway for
contaminants to move away from their source, and possibly into the marine environment.
Groundwater occurs at a shallow depth beneath the site, and the soil profile above the
water table has a high hydraulic conductivity, which makes it easy for liquids to move from
surface to the water table. Thus the groundwater at this site is particularly vulnerable to
contamination from surface or underground sources.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 89

5.4.2.1.

Contamination of Soils and Groundwater

Construction
During construction, there is a risk of spills of fuel and oil from construction equipment
and temporary storage tanks. Other substances, such as paints, coating and cleaning
products may be used on site, and there is a potential of spills onto the ground, resulting
in the contamination of soil and groundwater. These potential impacts should be
managed through the use of environmental management plan for the construction phase
(CEMP). Storage and disposal areas should be clearly segregated and designed to
prevent spills from reaching the ground.
Other potential impacts relate to construction phase wastewater. The operation and
maintenance of temporary washing areas and toilets should be well managed to prevent
the accidental discharge of wastewater onto the ground. The construction wastewater
will be collected in a concrete-lined pit, neutralized, filtered and will be reused.
Similar potential impacts and management measures apply for the commissioning and
start-up phases. In addition, wastewater will be generated due to hydrotesting, cleaning,
boil-out and chemical washing of lines, vessels and tanks. A commissioning phase
management plan should be developed and followed to prevent the discharge of any
effluents and chemicals to the ground.
It is considered that the construction impacts relating to soil contamination will be
restricted to the site and immediate surrounding areas. The impacts are considered to be
temporary (as they will occur during the construction period of the project only) and
reversible as long as appropriate clean up operations are carried out allowing excavation
and removal of contaminated soils. The impacts could potentially be cumulative if
contamination of soils occurs associated with the construction of plant on adjacent
industrial facilities. Overall the environmental impact associated with soil contamination
during construction is low risk.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Rare

Minor

Low

Project Number 44130065

Page 90

Operation
The solvents and other chemicals proposed to be used in the process pose a risk of
contamination of the soil and groundwater if they are not handled and stored cautiously.
Moreover, spills of HCl and sodium hypochlorite might release large amount of acid
fumes and chlorine gas, respectively.
Any impacts are considered to be reversible through appropriate remediation works. The
impacts could potentially be cumulative if contamination of soils occurs associated with
the operation of the adjacent plant. Overall the environmental risk associated with soil
and groundwater contamination during operation is moderate.
Probability

Consequence

Risk

Likely

Minor

Moderate

Decommissioning
During decommissioning of the plant there will be the potential for contamination of site
soils and groundwater as a result of the planned activities of dismantling and demolition
of plant structures and equipment. Details of the decommissioning plan are not available
at the time of writing, therefore it is assumed that decommissioning will comprise the
removal of all site structures above ground level. Contamination of soil and groundwater
could potentially occur as a result of: spillage of residual fluids, oils and chemicals within
plant equipment during dismantling; spills and leaks of waste materials stored on site;
inappropriate handling of waste materials.
A decommissioning phase management plan should be developed and followed to
prevent the discharge of any effluents and chemicals to the ground.
It is considered that the decommissioning impacts relating to soil contamination will be
restricted to the site and immediate surrounding areas. The impacts are considered to be
temporary (as they will occur during the period of decommissioning only) and reversible
as long as appropriate clean up operations are carried out allowing excavation and
removal of contaminated soils and groundwater. The impacts could potentially be
cumulative if contamination occurs on adjacent industrial facilities at the during the same
period of decommissioning. Overall the environmental impact associated with soil
contamination during construction is low risk.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Rare

Minor

Low

Project Number 44130065

Page 91

5.4.3. Mitigation Measures

5.4.3.1.

Potential Mitigation Measures

Construction

Consequence

Contamination of Soil
and Groundwater

Minor

Phase

Probability

Impact Description

Rare

Score

Significance

Low

Applicable
Environmental
Standard / Limits

Potential Mitigation

Fuel, oil and chemical storage facilities to include 110%

secondary containment.
Refuelling & maintenance to be carried out at designated sealed
hardstanding area/s with appropriate spill clean up and
containment facilities.
Provision of spill kits in all vehicles.
Waste storage in designated sealed hardstanding area with
appropriate spill clean up and containment facilities.
Development of a CEMP and monitoring plan.
Emergency shut down and spill response procedures for a
hazardous waste spill will be required to be developed and
implemented by the EPC contractor.
Regular inspections of plant and equipment.
The EPC contractor will encourage workers to report all spills
using a no blame culture.
If inadvertent leakage or spillage of hydrocarbons occurs, EPC
Contractor will implement spill response measures to contain and
excavate any contaminated soil present.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 92

EHSMS CoP 12
Water Quality and
CoP 13 - Land
Management
version 1.2 July
2009
-

Phase

Consequence

Impact Description

Probability

Score

Significance

Applicable
Environmental
Standard / Limits

Potential Mitigation

EPC contractor to develop OEMP and environmental

monitoring plan.
Appropriate protocols will be established for the transfer
and disposal of contaminated fuel, oil and soil in
accordance with Municipality requirements in the Waste
Management Plan.

Minor

Operation

Likely

Fuel, oil and chemical storage facilities to include 110%

secondary containment.

Moderate

Refuelling & maintenance to be carried out at designated

sealed hardstanding area/s with appropriate spill clean up
and containment facilities.
Regular inspections of plant and equipment.
If any inadvertent leakage or spillage of hydrocarbons
occurs, the operator will implement spill response
measures to contain and excavate any contaminated soil
present.
Chemical Management, Waste Management, Emergency
and Spill Response plans will be established for the site.
All contaminated wastewater will be treated to within
appropriate discharge limits prior to disposal.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 93

EHSMS CoP 12
Water Quality and
CoP 13 - Land
Management
version 1.2 July
2009
-

Decommissioning

Consequence

Minor

Phase

Rare

Impact Description

Probability

Score

Significance

Low

Applicable
Environmental
Standard / Limits

Potential Mitigation

It is anticipated that activities and impacts, and hence

mitigation measures for decommissioning will mirror the
construction phase.

EHSMS CoP 12
Water Quality and
CoP 13 - Land
Management
version 1.2 July
2009
-

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 94

5.4.3.2.

Selected Mitigation Measures

Contamination of Soil and Groundwater

Construction
During construction there will be a potential for soil and groundwater contamination from
planned activities. Mitigation measures considered to be appropriate for this project
comprise the following:
1. Secondary containment (i.e. drip pans or concrete containment) will be provided
for fuel and chemical storage tanks such that containment is designed for a
minimum of 110% of the total volume of the largest storage tank
2. Fuel and chemical storage tanks will be located at a designated position and
appropriate clear signage and barrier protection from vehicular movements.
3. All hard-standing and bunds will be inspected on a regular basis and cracks
reported and repaired.
4. All temporary fuel storage tanks will be double-walled containers.
5. Acid wash waste, if applicable, during commissioning will be fully contained and
removed from site by authorised waste management contractors.
6. Refuelling will be undertaken in designated areas following set procedures, to be
set out in the CEMP.
7. Vehicles operating on site will undergo routine maintenance and regular
inspection to minimise the potential for leakage of oil and other fluids.
8. A regular equipment and tank inspection and repair program will be developed on
site.
9. Emergency shut down and spill response procedures for a hazardous waste spill
will be required to be developed and implemented by the EPC contractor.
10. The EPC contractor will encourage workers to report all spills using a no blame
culture.
11. If any inadvertent leakage or spillage of hydrocarbons occurs, the EPC
Contractor will implement spill response measures to contain and excavate any
contaminated soil present.
12. Chemical Management, Waste Management, Emergency and Spill Response
plans will be established for the site.
13. Appropriate protocols will be established for the transfer and disposal of
contaminated fuel, oil and soil in accordance with Municipality requirements in the
Waste Management Plan.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 95

14. Construction activities will not be scheduled when there is a significant potential
for rainfall and torrential run offs.
15. Adequate dust suppression, erosion and sedimentation controls will be
established as part of the CEMP, and appropriate soil conservation measures
taken including limiting the disturbed area.
16. Wherever possible use will be made of approved recycling facilities within the
UAE.
17. Temporary sewage units will be regularly inspected, maintained and emptied by
authorised waste management contractors.
18. All contaminated wastewater will be treated to within appropriate discharge limits
prior to disposal.
19. Treated sanitary wastewater will be treated to within appropriate discharge limits
prior to release to soakaways.
These measures when followed properly as part of a rigorous CEMP are considered
appropriate to mitigate against the potential for soil and groundwater contamination.
Operation
During operation of the plant there will be a potential for soil and groundwater
contamination from planned activities. Mitigation measures considered to be appropriate
for this project comprise the following:
1. EPC contractor to develop OEMP including an environmental monitoring plan.
2. Appropriate protocols will be established for the transfer and disposal of
contaminated fuel, oil and soil in accordance with Municipality requirements in the
Waste Management Plan.
3. Fuel, oil and chemical storage facilities to include 110% secondary containment.
4. Refuelling & maintenance to be carried out at designated sealed hardstanding
area/s with appropriate spill clean up and containment facilities.
5. If any inadvertent leakage or spillage of hydrocarbons occurs, the operator will
implement spill response measures to contain and excavate any contaminated
soil present.
6. Chemical Management, Waste Management, Emergency and Spill Response
plans will be established for the site.
7. All contaminated wastewater will be treated to within appropriate discharge limits
prior to disposal.
8. Routine and regular documented inspections of the
chemical/oil/fuel storage facilities and waste storage areas.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

plant

including

Project Number 44130065

Page 96

9. Immediate excavation and removal of any contaminated soil to the designated

waste facility.
These measures when followed properly as part of a rigorous OEMP will largely mitigate
against the potential for soil and groundwater contamination. However due to the
presence of plant and buildings associated with the facility on site there remains a
potential for soil and groundwater contamination to occur which cannot be identified by
visual assessment.
Decommissioning
A decommissioning strategy has not yet been developed for this project. Potential
mitigation measures as identified within 5.4.3.2 will be considered further prior to the
decommissioning phase and selected mitigation measures, implementation methods and
responsibilities detailed within the Decommissioning Environmental Management Plan.
For the purpose of this assessment, it is assumed the decommissioning mitigation
measures will mirror those as applied during the construction phase.
5.4.3.3. Mitigation Measures to Address Cumulative Impacts
The cumulative impacts identified are those that will impact soil and groundwater quality
from the combined operation of the current Project (Construction, Operation and
Decommissioning phases) and the existing potential releases to the terrestrial
environment from sources in the surrounding area where the Project is located.
With respect to the cumulative impacts identified for all construction phase aspects, these
will exist only for the time the construction activities are in progress, therefore as long as
the selected mitigation measures for these aspects detailed in Section 5.4.3.2 are
adhered to, no additional mitigation measures are required to address any cumulative
impact.
With respect to the cumulative impacts identified for all operation phase aspects, leaks
and spillages from operation of the plant can be controlled and minimised by
implementing the selected mitigation measures for these aspects detailed in Section
5.4.3.2. Assuming that the neighbouring facilities comply with the relevant mitigation
measures addressing their potential operational impacts to soil and groundwater, it is
envisaged that no additional mitigation measures are required to address the cumulative
impact of all the all industrial facilities within the vicinity of the proposed Al Ghaith ChlorAlkali Plant.
Cumulative impacts during decommissioning will be similar to that for the construction
phase and will occur over a similarly limited timescale.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 97

5.4.3.4. Residual Impacts

Contamination of Soil and Groundwater
With the implementation of all of the mitigation measures identified in Section 5.4.3.2, the
majority of potential contaminative impacts to soil will be largely removed. There still
remains a potential for contamination of soils as a result of the Project however, and
therefore the residual risk associated with this is considered to be low.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 98

5.5.

Marine Ecology

5.5.1. Description of the Environment

The coast of the UAE forms the southern margin of the Arabian Gulf. EAD (2007)
describes the main coastal and marine habitats of Abu Dhabi as seagrass beds, salt
marshes, coral and mangrove communities. The Project site is a highly disturbed area.
Historically the site would have consisted of sheltered tidal flats consisting of fine-grained
sediments, mostly sand and mud. It may have supported mangrove and intertidal
communities. Common species found in these environments are crabs, shrimps,
gastropods, bivalves, polychaetes, foraminifera and fish. Now the marine environment
adjacent to the site is a well defined, dredged boating channel and is likely to contain a
low diversity of species. Water depths are relatively shallow and contain a microbial mat
type ecosystem. In the restricted lagoons, tidal movement tends to be at right angles to
the coast. During low tide extensive parts of channels are exposed and evaporation of
the intertidal waters results in increased salinities.
The Project site is located in the centre of the MIA, approximately 1.2 km away from the
coast. Due to the distance from any marine water, any consideration of impacts is not
necessary. There are no information gaps and no baseline survey or mitigation will be
required for this aspect. Impacts to local water bodies will be considered in the soil and
groundwater section.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 99

5.6.

Terrestrial Ecology

5.6.1. Description of the Environment

URS has conducted a site-walkover survey of the Project site. The physical appearance
of the site is consistent with that of reclaimed and pre-disturbed (cleared) land. The site is
largely devoid of flora and fauna. Given the site comprises reclaimed marine dredge
spoil, it does not contain any sites of designated terrestrial ecological importance and
therefore is not considered to be of any ecological value. This project, therefore, is not
expected to have any impact on the terrestrial ecology of the project area and its vicinity.

5.6.2. Environmental Impact Prediction and Evaluation

5.6.2.1.

Loss of Habitat, Flora and Fauna

Construction
Information gathered during the site walkover indicated that the ecological diversity and
abundance is very low. The site is considered to be of little conservation interest. This is
likely due to the reclaimed and levelled nature of the site.
In all likelihood the flora and fauna associated with the site will be lost during construction
activities. Removal of terrestrial habitats will be permanent and irreversible within the
footprint of the plant and transportation routes for the duration of the construction phase
of the Project and also for the operational phase. Habitat removal on the site will,
however, be of rare probability and insignificant consequence due to the low diversity and
abundance of common species on site. Overall, the environmental impact associated
with this removal of habitat is considered of low environmental risk.
Probability

Consequence

Risk

Rare

Insignificant

Low

Operation
The footprint of the works established during the construction phase will remain during
the operational phase. Removal of terrestrial habitats will be permanent and irreversible
for the duration of the operational phase of the Project. Should any future maintenance
or extensions be planned for the site, potential for the removal of additional habitats
should be assessed at this time. Habitat removal on the site will, however, be of rare
probability and insignificant consequence due to the low diversity and abundance of
common species on site. Overall, the environmental impact associated with this removal
of habitat is considered of low environmental risk.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Rare

Insignificant

Low

Project Number 44130065

Page 100

Decommissioning
The footprint of the works established during the construction and operation phases will
be removed during the decommissioning phase.
At this point there is no
decommissioning plan in place and it is not known if the site shall be used for another
purpose or returned, in so far as is possible, to its original state. As shown by the
evidence of ecological succession on the site since previous filling/levelling activities, it is
reasonable to assume that species recolonisation will occur if the site is cleared and
restored. Therefore, assuming this case, the impacts will be temporary and reversible.
Overall, the environmental impact associated with this activity is considered of low
environmental risk.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Rare

Insignificant

Low

Project Number 44130065

Page 101

5.6.3. Mitigations Measures

5.6.3.1. Potential Mitigation Measures

Consequence

Environmental
Risk

Construction
Insignificant

Loss of habitat /
Disturbance to
Flora and Fauna

Phase

Rare

Impact
Description

Probability

Score

Vegetation clearing confined to that necessary for the

establishment of the plant.
Low

Insignificant

Rare

Operation

Insignificant

Rare
Al Ghaith Industries

Management strategies implemented to protect

remaining native vegetation communities by controlling
the occurrence and spread of weeds and minimising
the impact of soil erosion/sedimentation.

No specific measures are identified to mitigate the loss

of native habitat on site.
Low

Decommissioning

PEHSR Chlor-Alkali Plant

Applicable
Environmental
Standard / Limits

Potential Mitigation

Planting of vegetation (local species including flowering

plants, shrubs and trees) to provide green areas within
plant fence line will provide habitat for species including
insects and birds on site. Such areas would also be
visually appealing.

Site returned, in so far as is possible, to an original

state.
Low

Management strategies implemented to protect

remaining native vegetation communities by controlling
the occurrence and spread of weeds and minimising
the impact of soil erosion/sedimentation.

Project Number 44130065

Page 102

5.6.3.2.

Selected Mitigation Measures

Loss of Habitat
Construction
The impact of loss / disturbance will be realised during the construction phase. As such:
1. Clearing of vegetation will be confined to that necessary for the establishment of
the plant.
Areas for clearance will be established with the EPC Site
Environmental Manager before works.
2. Management strategies will be implemented to protect any remaining native
vegetation communities by controlling the occurrence and spread of weeds and
minimising the impact of soil erosion/sedimentation. This will include general
good housekeeping on site and assessment during the daily site inspection by
the EPC Site Environmental Manager.
These measures will not fully mitigate the loss of the present habitats as this impact is
unavoidable due to the footprint of the plant facilities. These measures will, however,
reduce the impact from loss of habitat as far as possible.
Operation
No specific measures have been identified to mitigate the loss of native habitat on site.
However:
1. Planting vegetation composed of local species, preferably coastal, within the
available space will provide green areas. Such landscaping within the plant
fence line will provide some habitat/shelter for species including insects and birds
on site, and though not directly mitigating for the impact, will provide areas of
some limited value. Such areas would also be visually appealing, particularly if
instated in administration or office areas. Basic landscaped areas also cost
relatively little to instate and maintain.
It should be noted that the impact of habitat loss will be realised during the construction
phase and that the operational phase will not further increase this impact. In addition,
landscaping mitigation will only provide alternate habitat and limited compensation and
will not provide any habitat recreation.
Responsibility for landscaping during the operational phase will be with the Al Ghaith
Plant Environmental Manager. This activity will be a continual activity, likely falling within
the plant maintenance schedule.
Decommissioning
A decommissioning strategy has not yet been developed for this project. Potential
mitigation measures as identified within Section Error: Reference source not found will be
considered further prior to the decommissioning phase and selected mitigation measures,

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 103

implementation methods and responsibilities detailed within the Decommissioning

Environmental Management Plan
For the purpose of this assessment, it is assumed the decommissioning mitigation
measures will mirror those as applied during the construction phase.
5.6.3.3.

Mitigation Measures to Address Cumulative Impacts

No cumulative impact was identified, therefore no mitigation is suggested.

5.6.3.4.

Residual Impacts

Loss of Habitat
With the implementation of the mitigation as selected in Section 5.9.3.2, the impact will
remain low as loss of habitat is unavoidable. Scores as identified in Section 5.9.2 remain
applicable.
Disturbance to Flora and Fauna
No potential mitigation measures have been identified for any project phase due to the
fact the site contains a low density and abundance of species and is of low conservation
interest. As such, the scores as attributed in Section 5.9.2 remain, and the overall impact
on flora and fauna is still considered to be low.

5.6.4. Monitoring Program

5.6.4.1. Monitoring Program for Compliance with Selected Mitigation Measures
Monitoring for compliance with selected mitigation measures during the construction
phase shall be undertaken by the EPC Site Environmental Manager during daily
inspections and shall be recorded within the Field HSE Report and the weekly
Environmental Inspection Checklist. No potential mitigation measures have been
identified for any other project phase due to the fact the site contains a low density and
abundance of species and is of low conservation interest. As such, the scores as
attributed in Section 5.9.2 remain, and the overall impact on flora and fauna is still
considered to be low.
5.6.4.2. Monitoring Program for Cumulative Impacts
No cumulative impacts were identified for any project phase; therefore no monitoring of
cumulative impacts is suggested.
5.6.4.3. Monitoring Program for Residual Impacts
The effects of the construction, operation, and decommissioning phases of this project on
terrestrial ecology are unlikely extend past the site boundaries. As the site has been
established as of low biological diversity and abundance, it is thought that the monitoring
of residual impacts throughout the lifecycle of the project is excessive and economically
unnecessary. The pre-construction survey will include ecological records of the site and

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 104

act as the standard if site restoration activities commence during decommissioning. A

post-decommissioning survey will be undertaken to establish the success of the site
reclamation if applicable.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 105

5.7.

Noise

5.7.1. Description of Environment

The Project site is located within a larger industrial zone and the background noise
environment is dominated by the associated activities, including road traffic, marine
vessels and fork-lift trucks.

5.7.2. Environmental Impact Prediction and Mitigation

5.7.2.1.

Emissions from Operation of Vehicles and Temporary Equipment

Construction
Operation of light and heavy vehicles and construction equipment (such as those for
piling) on site will lead to generation of noise in their vicinity. However, due to the
transient nature of these construction works as well as the existing industrial nature of the
wider area in which the Project is located, the overall incremental increase in noise levels
due to these activities is likely to be minor.
Keeping the above in view, it is considered that the overall environmental impact to noise
levels in the Project area for this aspect due to construction activities is of low
significance.
Probability

Consequence

Risk

Likely

Insignificant

Low

Operation
It is envisaged that during operation of the Chloro-Alkali plant, only light vehicles will
operate within the confines of the plant, with heavy vehicles or temporary constructionrelated equipment employed very rarely for certain maintenance work, as needed. This
coupled with the transient and infrequent nature of light vehicular traffic and constructionrelated equipment operation render the overall incremental increase in noise levels due to
these activities as minor.
Keeping the above in view, it is considered that the overall environmental impact to noise
levels in the Project area for this aspect due to operation activities is of low significance.
Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning
Similar to the Project construction phase, operation of light and heavy vehicles and
construction equipment on site during decommissioning and demolition works will lead to
generation of noise in their vicinity. However, due to the transient nature of these

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 106

activities as well as the existing industrial nature of the wider area in which the Project is
located, the overall incremental increase in noise levels due to these activities is likely to
be minor.
Keeping the above in view, it is considered that the overall environmental impact to noise
levels in the Project area for this aspect due to decommissioning activities is of low
significance.
Probability

Consequence

Risk

Likely

Insignificant

Low

5.7.2.2. Emissions from Operation of Chlor-Alkali Plant

Construction
Not applicable.
Operation
The major sources of noise emissions during operation of the plant will be the key
process equipment such as the gas boiler and associated process equipment. It is worth
taking note that with respect to ambient noise levels in the wider area where the Project is
located, the incremental noise levels generated by operation of the plant are expected to
be insignificant due to the location of the plant within MIA / ICAD-1. This is due to the fact
that the existing cumulative noise levels in the area will be contributed to by neighbouring
industrial processes and steelworks.
With all plant operational, there is a potential exceedance of the work area noise limit
within the gas boiler and associated process equipment buildings. The project requires
that in order to minimise noise exposure on personnel undertaking maintenance work
within these buildings the use of removable acoustic screens is required.
Hearing protection is recommended in areas where noise levels exceed 85 dB(A) and
should be considered mandatory in areas that exceed 90 dB(A). These areas require
demarcating with hearing protection signs, particular at the entrances to the buildings
noted above.
As noise from the operation of the Chlor-Alkali Plant will be ongoing the probability of
elevated noise levels occurring is frequent. However, taking into account the location of
the plant within the greater MIA the environmental consequence is deemed to be
insignificant, and therefore environmental risk will be moderate.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Frequent

Insignificant

Moderate

Project Number 44130065

Page 107

5.7.3. Mitigations Measures

5.7.3.1. Potential Mitigation Measures

Construction

Consequence
Insignificant

Emissions from
Operation of
Vehicles and
Temporary
Equipment

Phase

Likely

Impact
Description

Probability

Score

Environmental
Risk

Low

Applicable
Environmental
Standard / Limits

Potential Mitigation

Enforce speed restrictions

Equipment used on an intermittent basis to be shut
down between work periods or throttled down to a
minimum
All noisy activities such as piling to be carried out
during the day
Acoustic covers installed on engines, if applicable, and
kept closed when engines in use or idling
Ensure regular maintenance of temporary equipment
and vehicles to ensure efficient operation as per
specifications

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 108

EAD Noise
Allowable Limits

Phase

Consequence

Impact
Description

Probability

Score

Environmental
Risk

Applicable
Environmental
Standard / Limits

Potential Mitigation

Insignificant

Operation

Likely

Enforce speed restrictions

Equipment used on an intermittent basis to be shut
down between work periods or throttled down to a
minimum
Low

All noisy activities such as piling to be carried out

during the day

Construction

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Insignificant

Decommissioning

Likely

Ensure regular maintenance of temporary equipment

and vehicles to ensure efficient operation as per
specifications

Low

No impact

Same as for the Construction Phase

Not applicable

EAD Noise
Allowable Limits

Project Number 44130065

Page 109

Phase

Consequence

Impact
Description

Probability

Score

Environmental
Risk

Applicable
Environmental
Standard / Limits

Potential Mitigation

Installation of plant equipment that is designed to

adhere to the Project noise requirements/philosophy

Emissions from
Operation of
Chlor-Alkali Plant

Al Ghaith Industries

Moderate

Where noise levels could potentially exceed 90 dB(A)

hearing protection should be worn and acoustic
shielding in the design of noisy equipments or near to
them should be incorporated in the plant layout
It is recommended that low noise valves are used
where practicable to minimise noise emissions during
emergency situations and to protect any worker at a
position close to these

Decommissioning

PEHSR Chlor-Alkali Plant

Insignificant

Operation

Frequent

Ensure regular maintenance of plant equipment to

ensure efficient operation as per specifications

No impact

Not applicable

Project Number 44130065

Page 110

5.7.3.2.

Selected Mitigation Measures

Upon review of the potential mitigation measures in Section 5.7.3.1, appropriate and
feasible measures will be selected for enforcement on site and their implementation
frequency decided. Details on the suggested mitigation measures are provided
hereunder.
Emissions from Operation of Vehicles and Temporary Equipment
Construction
The EPC Site Environmental Manager will enforce speed restrictions on site traffic and
ensure that equipment used on an intermittent basis (such as bulldozers or idling cars)
will be shut down or throttled down to a minimum to cut down on unnecessary noise
emissions. Moreover, any known noisy activities such as piling will be scheduled such
that they occur during daylight hours in order to minimise potential disturbance to humans
as well as fauna during the night time when they are more sensitive to changes in noise
levels.
The EPC Site Environmental Manager will also ensure that all known noisy construction
equipment (such as hand tools or air compressors) have acoustic covers installed on their
noisy parts (e.g. engines), which are kept closed at all times.
The EPC Maintenance Manager will also ensure that all construction machinery and
vehicles operational on site are maintained according to a set schedule as per the
manufacturers specifications so that they are in good working condition at all times and
consequently non-design noise emissions are minimised.
Operation
Same as for the Construction phase above.
Decommissioning
Same as for the Construction phase above.
Emissions from Operation of Chlor-Alkali Plant
Construction
Not applicable.
Operation
Since the potential mitigation measures concern the design of the plant facilities, the EPC
Contractor in coordination with the Project Proponent will select the appropriate mitigation
measures to be implemented in order to reduce noise emissions from operation of the
plant. These measures are detailed hereunder.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 111

Plant equipment will be selected and installed that has been designed to adhere to the
Project noise philosophy as well as local regulations to minimise the potential for
exceedance of noise limits during normal operation of the plant.
The Chlor-Alkali Plant Operations Manager also will ensure that all plant equipment are
regularly maintained to manufacturer specifications in order to reduce the potential for
non-design performance of the equipment that can result in higher noise emissions from
equipments.
It is recommended that low noise valves are used where practicable to minimise noise
emissions during emergency situations and to protect any worker at a position close to
these valves.
Decommissioning
Not applicable.
5.7.3.3. Mitigation Measures to Address Cumulative Impacts
The cumulative impacts identified are those that will impact ambient air quality from the
combined operation of the current Project (Construction, Operation and Decommissioning
phases) and the existing noise emissions sources in the wider area where the Project is
located.
With respect to the cumulative impacts identified for all construction phase aspects, these
will be transient in nature since they will exist only for the time the construction activities
are in progress, therefore as long as the selected mitigation measures for these aspects
detailed in Section 5.7.3.31 are adhered to, no additional mitigation measures are
required to address their cumulative impact.
With respect to the cumulative impacts identified for all operation phase aspects, on the
current Project the noise emissions from operation of the Chlor-Alkali plant are the only
ones that can be controlled and minimised by implementing the selected mitigation
measures for these aspects detailed in Section 5.7.3.31. Assuming that the noise
emissions contributing facilities above are complying with the relevant mitigation
measures addressing their operational emissions, it is envisaged that no additional
mitigation measures are required to address the cumulative impact of all the facilities
including the Al Ghaith Chlor-Alkali Plant.
5.7.3.4. Residual Impacts
After application of the mitigation measures discussed in Section 5.7.3.2, the residual
impact for all the aspects during all three Project phases will remain unchanged from the
assessments provided in Section Error: Reference source not found.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 112

5.7.4. Monitoring Program

5.7.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

Emissions from Operation of Vehicles and Temporary Equipment

Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Site traffic following speed restrictions

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Noisy activities not conducted at night, as

far as practicable

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Appropriate acoustic covers installed on

noisy equipment

Daily

EPC Site
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Maintenance of site vehicles and

construction machinery

Monthly

EPC Site
Environmental
Manager

Weekly Environmental Inspection Checklist,

Quarterly Environmental Audit Report

Site traffic following speed restrictions

Daily

Al Ghaith
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Equipment/vehicles used on intermittent

basis shut down or throttled down to
minimum when not in use

Daily

Equipment/vehicles used on intermittent

basis shut down or throttled down to
minimum when not in use
Construction

Operation

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Al Ghaith
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Project Number 44130065

Page 113

Project Phase

Decommissioning

Monitoring Activity

Frequency

Noisy activities not conducted at night, as

far as practicable

Daily

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Daily

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Maintenance of site vehicles and plant

machinery

Monthly

Al Ghaith
Operations
Manager

Weekly Environmental Inspection Checklist,

Quarterly Environmental Audit Report

Site traffic following speed restrictions

Daily

Al Ghaith
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Equipment/vehicles used on intermittent

basis shut down or throttled down to
minimum when not in use

Daily

Noisy activities not conducted at night, as

far as practicable

Daily

Maintenance of site vehicles and plant

machinery

Al Ghaith Industries

Reporting

Al Ghaith
Environmental
Manager

Appropriate acoustic covers installed on

noisy equipment

Appropriate acoustic covers installed on

noisy equipment

PEHSR Chlor-Alkali Plant

Responsibility
Al Ghaith
Environmental
Manager

Al Ghaith
Environmental
Manager
Al Ghaith
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist
Daily Field HSE Report,
Weekly Environmental Inspection Checklist

Daily

Al Ghaith
Environmental
Manager

Daily Field HSE Report,

Weekly Environmental Inspection Checklist

Monthly

Al Ghaith
Operations
Manager

Weekly Environmental Inspection Checklist,

Quarterly Environmental Audit Report

Project Number 44130065

Page 114

Emissions from Operation of Chlor-Alkali Plant

Project Phase

Monitoring Activity

Frequency

Responsibility

Reporting

Construction

N/A

N/A

N/A

N/A

Plant equipment adhering to noise

philosophy

Once

EPC Engineering
Contractor

Plant Description
Documentation

Maintenance of plant equipment

As per manufacturer
specifications, Plant
Maintenance Philosophy

Al Ghaith Operations
Manager

Plant Maintenance Checklist

N/A

N/A

N/A

N/A

Operation

Decommissioning

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 115

Monitoring programs suggested in Sections Error: Reference source not found will
minimise the impact as far as considered practical, with commitment to these measures
provided in Section 7 Statement of Commitments of the PEHSR. These measures will
also be reflected in the EPC Contractors Project Construction Environmental
Management Plan (CEMP) and the Al Ghaiths Operations Environmental Management
Plan (OEMP). Compliance monitoring carried out as part of implementation of the aforementioned documentation (e.g. periodic inspections, audits) will assess for compliance of
monitoring with the specified mitigation measures.
5.7.4.2. Monitoring Program for Cumulative Impacts
As stated in Section 5.7.3.3, since the cumulative impacts from construction of the plant
will be transient and controlled by implementation of the selected mitigation measures
detailed in Section 5.7.3.2, no additional monitoring program is required to address them
other than the Project monitoring mentioned in Section Error: Reference source not
found. The same applies to the decommissioning stage of the Project.
5.7.4.3. Monitoring Program for Residual Impacts
As stated in Section 5.7.3.4, since no residual impacts have been identified after
application of the selected mitigation measures and their associated monitoring detailed
in Section Error: Reference source not found, no such additional monitoring is required.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 116

5.8.

Traffic
The impact associated with additional traffic on the roads around ICAD-1, MIA and the
wider emirate of Abu Dhabi introduced by the construction of the Chlor-Alkali Plant will not
be measureable and as such is deemed to be an insignificant factor in this PEHSR. As
such, the environmental impact resulting from traffic will not be considered.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 117

5.9.

Socio-Economic

5.9.1. Description of the Environment

A review of socio-economic impacts from the Project is a key component of any
environmental assessments carried out. Socio- economic impact assessment in the UAE
is an emerging field for which standard procedures and assessment methods are not yet
fully developed.
The socio-economic baseline was established by means of a desk based study. The
information was collated from publicly available resources. Nevertheless, limited
information regarding site specific socio- economic indicators are available in the public
domain, socio-economic data provided in this section is largely generic in nature.
5.9.1.1. UAE
The UAE is made up of seven emirates, namely Abu Dhabi, Dubai, Sharjah, Ajman,
Fujairah, Ras al-Khaimah, and Umm al-Quwain. Abu Dhabi is the largest Emirate in
terms of area, covering 81.2% of the UAEs 32,000 square miles (State of the
Environment - Abu Dhabi 2007).
Population
The total population of the UAE in 2008 was 4.5 million and is expected to reach 8.5
million by 2050 (UNPF, 2008). In a census conducted in 2005 by the UAE Ministry of
Economy the percentage of nationals to the total population was 22%, with expatriates
thus accounting for 78% (United Arab Emirates Ministry of Economy, 2006). The
projected average population growth rate for the period 2005 to 2010 is 2.9%,
significantly higher than those of other GCC countries. Error: Reference source not found
displays the total population of each Emirate in 2005, including male to female ratios.
Abu Dhabi has the highest population of the UAE although it is only marginally greater
than the Emirate of Dubai.

Figure 5-1-15 Total population of each UAE Emirate and their respective male to
female ratios in 2005 (United Arab Emirates Ministry of Economy, 2006)

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 118

Age Distribution
The age structure of the population in the UAE is detailed in Figure 5- 1 -16. The peak
population within the UAE as a whole lies within the 25 to 40 age range, with a peak at
30-34 years. The population is weighted heavily in favour of expatriate men between the
ages of 20 to 55 (United Arab Emirates Ministry of Economy, 2006).

Figure 5-1-16 UAE population by age group (United Arab Emirates Ministry of Economy, 2006)
Economy
The UAE economy has prospered in recent years with the country ranked 56th out of 180
countries worldwide in its contribution to the global GDP in 2007. Within the GCC, the
UAE ranked second to Saudi Arabia in its contribution according to the classification of
the International Monetary Fund in 2007 (Abu Dhabi Economic and Social Report, 2008).

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 119

5.9.1.2.

Musaffah Industrial Area

MIA is situated southeast of Abu Dhabi Island.

southern part of MIA. See Figure 4 -2.

The Project area is located on the

Population
Total estimated residential population of Musaffah is approximately 151,000 (Municipality
of Abu Dhabi City Website, 2009). The detailed demographics of the residential
population and total worker population in MIA are not available in public domain.
On the east of MIA, lies a residential area, which is primarily intended for accommodation
of workers employed in MIA. In addition, the residing population mostly comprises of
migrant male expatriate workers, typical of the general demographic of the MIA, with few
UAE nationals.
Age Distribution
The predominant male bias is expected to be even more pronounced in this area since
the majority of the population are male expatriates, working predominately on projects of
an industrial nature. No age structure data is available for the Musaffah Area however
the age structure is considered to be typical of the UAE, in favour of expatriate men
between the ages of 20 to 55.
Nearby Sensitive Receptors
Bul Syayeef Marine Protected Area (MPA) lies to the west of MIA, separated by an
approximately 500 m wide navigational channel. Bul Syayeef was declared as a Marine
Protected Area by EAD in 2007.
5.9.1.3.

Al Ghaith Chlor-Alkali Plant Site and Proposed Project Area

Land Use
The land use around the site consists of heavy industries and logistics, with XXX to the
east, XXX to the west and proposed XXX plant to the south. A naval school lies 1 km to
the southeast of the site on the Musaffah South Channels southern bank.
Economic Impacts
The AED XXX million / billion project will help relieve the increasing demands for caustic
and chlorine within the Emirate. The long term economic benefits both to the national,
regional and local community will be significant.
Population
No additional manpower shall be contracted. Local labour in Musaffah shall be utilized
for this development.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 120

Nearby Sensitive Receptors

The nearest sensitive receptor to the proposed Project site is the Musaffah labour
accommodation area, which is approximately 1.5 km north. The larger Musaffah
Residential Area is situated approximately 7.5 km east of the site. Storage facilities are
currently located within the Project area. Land usage of the surrounding area and the
nearest sensitive receptors are illustrated in Figure XXXX.

5.9.2. Environmental Impact Prediction and Evaluation

5.9.2.1.

Land Use and Community Impacts

Construction
There are no requirements to displace local residents through this project as the site is
designated for industrial purposes. There is very little public activity around the site.
Equipment and materials needed for the construction of the plant will be transported
along existing roads to the site.
In general, impacts on land use during construction are expected to be low as
development is in accordance with regional plans and in an area designated for such
works.
Probability

Consequence

Risk

Likely

Insignificant

Low

Operation
The Chlor-Alkali plant will operate within the boundaries of the MIA / ICAD-1, and as such
there is considered to be no impact on land use of the area. There is likely to be an
insignificant increase in environmental impact of the plant through air. Air quality impacts
are unlikely to affect the general community due to low volume of emissions and
dispersion. The impacts from the operation on the land use and community are
anticipated to be low.
Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning
The operational life cycle of the Chlor-Alkali Plant is likely to be 20 years or more.
Typically Chlor-alkali plants are upgraded and retrofitted over time to extend their
operational life cycle and meet ever more stringent environmental guidelines. Even when
the plant does become redundant it is likely the site will still be used for industrial
purposes due to the land zoning. So it is unlikely that full decommissioning and
restoration of the site will be required for many years. If decommissioning is eventually

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 121

required a decommissioning plan will need to be developed to ensure that the

installations can be removed to minimise the risk of pollution. Decommissioning will
involve dismantling of equipment and installations in reverse order to that of construction
and is likely to be a quicker process. Any contaminated soil will be treated as hazardous
waste and removed from site. Comprehensive analysis of the soil and groundwater will
be necessary to ensure there is no contamination prior to any transfer of ownership. All
material will need to be removed from site and recycled where possible or disposed to
landfill. The site will need to be re-contoured and landscaped prior to any transfer of
ownership. As such, the impacts from the operation on the land use and community are
anticipated to be low.
Probability

Consequence

Risk

Likely

Insignificant

Low

5.9.2.2.

Social Impacts

Construction
During construction the project will require up to an estimated 100 workers on site. Most
workers will be expatriate male labourers who will most likely be accommodated in worker
camps within MIA. The influx will not change the demographic gender and ethnic
dynamics of the population.
The impacts from the construction on the social aspects are anticipated to be low.
Probability

Consequence

Risk

Likely

Insignificant

Low

Operation
During operation the impacts on employment are less significant than during construction.
However, those who are employed will have longer term job security and are more likely
to bring their family and integrate in the community. They will require a higher standard of
housing and facilities such as shops, entertainment, a school, and a hospital. They are
also more likely to interact with the local Emiratis. It is estimated that the operational
workforce will be around 100 people. Including families the number of people that will be
added to the community is significant and is likely to help develop the area.
The impacts from plant operation on the social aspects are anticipated to be low.
Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 122

During decommissioning the number of workers on site will increase. There may be a
short term benefit to the community through employment opportunities. But once the
plant is dissembled and removed the social benefits will be gone. The roughly 100
people working on-site permanently will no longer be required. So unless the land can be
used for some other purpose which helps employee local people the social impacts will
be negative. It is entirely likely that when the Chlor-Alkali Plant is decommissioned in the
future a new plant may take its place or other industry will move in. Alternatively in 20
years time if the population of the area continues to expand this land with ocean views
may become valuable for residential purposes as has happened in many other parts of
the world.

5.9.2.3.

Probability

Consequence

Risk

Likely

Insignificant

Low

Economic Impacts

Construction
The total estimated expenditure for construction and operation of the project is USD xxxx
mil.. A large proportion of this expense will be early on in the construction phase when
the major components will be purchased and up to approximately XXX workers will be on
site. While the major system units will be imported other construction materials such as
concrete and steel rebar will be sourced locally.
While there is likely to be a beneficial multiplier effect from the money spent on this
project, which will spread through the economy, it may not be as high as in other places
as expatriate workers typically save a high proportion of their salaries to send home. As
they stay in fully catered camps they are not likely to spend large sums of money in the
local shops. Workers are also not taxed on their incomes. Therefore a large proportion
of money may move offshore. However, for every direct job created by the project there
will be supporting indirect jobs created. A project like this is only likely to benefit the
economy.
There is potential for inflationary pressure as a result of this project due to the shortage of
certain building materials locally and already strong demand for these products. The
added people involved in the project will also increase demand for foodstuffs and other
supplies. However, the overall impacts are not likely be significant or long term as once
operational the numbers of people on site will be relatively minor.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Likely

Insignificant

Low

Project Number 44130065

Page 123

Operation
The economic benefits of the new plant are large. Abu Dhabi is growing at a fast rate in
terms of population and new developments. This has put a significant strain on the
energy infrastructure of the Emirate. Without the development of new industry the
Emirates growth would slow. The construction of the Chlor-Alkali Plant is important to
the future of Abu Dhabi, and the oil and gas industry in particular. As such, the operation
of the plant is of major positive impact, and therefore low risk.
Probability

Consequence

Risk

Likely

Insignificant

Low

Decommissioning
Decommissioning will have obvious negative impacts on the economy. Approximately 50
people will be out of work and the Chlor-alkali production will no longer be available which
will increase the overall caustic and chlorine for consumers in Abu Dhabi. While there
may be some employment opportunities during the decommissioning process these will
be short term.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Probability

Consequence

Risk

Likely

Minor

Moderate

Project Number 44130065

Page 124

5.9.3. Mitigation Measures

5.9.3.1.

Potential Mitigation Measures

Consequence
Insignificant

Low

Insignificant

Low

Operation

Likely

Decommissioning

Construction
Likely

Social

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Applicable
Environmental
Standard / Limits

Potential Mitigation

No mitigation identified

Maintain as an industrial zone and avoid any new

residential or other recreational activities around the
site.

Prepare decommissioning plan for site.

Insignificant

Construction

Environmental
Risk

Low

Insignificant

Land Use

Probability

Phase

Likely

Impact Description

Likely

Score

Low

Ensure the site is tested and restored to original

condition, where possible.

Allow for re-contouring and landscaping of site.

No mitigation identified

Project Number 44130065

Page 125

Probability

Consequence

Likely

Insignificant

Low

Insignificant

Low

Insignificant

Phase

Likely

Impact Description

Likely

Score

Low

Environmental
Risk

Applicable
Environmental
Standard / Limits

Potential Mitigation

Decommissioning

Construction

Operation

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Likely

Economic

Insignificant

Operation
Provide adequate assistance and facilities to allow
permanent workers to integrate in the local
community.

Allow new high value development on the site to

provide replacement employment opportunities.

No mitigation identified

Low

No mitigation identified

Project Number 44130065

Page 126

Consequence
Minor

Phase

Probability

Impact Description

Likely

Score

Environmental
Risk

Applicable
Environmental
Standard / Limits

Potential Mitigation

Decommissioning

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Moderate

Allow new high value development on the site to

provide replacement employment opportunities.

Project Number 44130065

Page 127

5.9.3.2.

Selected Mitigation Measures

As the socio-economic benefits of the project are primarily beneficial mitigation measures
have not been identified for most aspects of the project. The only mitigation measure that
has been selected as an ultimate requirement of the project is:
1. A decommissioning plan for the site is produced. The decommissioning plan will
be the responsibility of the Operations Manager prior to any decommissioning
activities commencing and will need to consider issues such as waste handling
and disposal, site investigations, and restoration of the site. This plan will need
to be approved through EAD.
Note that other environmental mitigation measures including traffic management that will
benefit the community are addressed in separate sections.
5.9.3.3.

Mitigation Measures to Address Cumulative Impacts

No mitigation measures have been identified to address cumulative impacts as such

socio-economic impacts are all of major positive benefit.
5.9.3.4.

Residual Impacts

As only one mitigation measure has been selected, and this is a mandatory requirement
of the project, the residual impacts will remain unchanged. They are all considered Low
with the exception of the operational impacts on the social and economic factors, which
remain of major positive benefit.

5.9.4. Monitoring Program

5.9.4.1.

Monitoring Program for Compliance with Selected Mitigation Measures

No monitoring program is considered necessary at this stage of the Project. When the
site is eventually decommissioned post closure monitoring is recommended to ensure the
fitness of the land for the intended future use. This shall be determined within the
decommissioning plan.
5.9.4.2.

Monitoring Program for Cumulative Impacts

No monitoring program is considered necessary to deal with cumulative impacts.

5.9.4.3.

Monitoring Program for Residual Impacts

No monitoring program is considered necessary to deal with residual impacts.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 128

5.10. Impacts, Mitigation and Monitoring Summary

5.10.1. Mitigated Impacts
Table 5-10 Summary of Environmental Impacts, Mitigation and Monitoring

Emissions
from
operation of
fuel
consuming
vehicles
and
equipment

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Phase

Signific
ance

Low

Air Quality

Impact

Construction

Receptor

Mitigation

Monitoring

The EPC Site Environmental Manager will ensure that

all site light and heavy vehicles and construction
machinery traffic used paved/gatch roads wherever
possible and traffic on unpaved roads is limited to
reduce generation of particulate dust emissions. For
the same reason, speed restrictions will also be
imposed on site traffic, traffic will be planned and
managed to reduce double trips, and unpaved routes
will be sprinkled with water as required to dampen
down the soil.
Moreover, the EPC Site Environmental Manager will
also ensure that all construction machinery and
vehicles operational on site are maintained according
to a set schedule as per the manufacturers
specifications so that they are in good working
condition at all times and consequently non-design
exhaust emissions are minimised.

Responsible Party

Daily monitoring of site traffic using paved

roads to be reported in daily field HSE report
and weekly Environmental Checklist.
Daily monitoring of site traffic following speed
restrictions to be reported in daily field HSE
report and weekly Environmental Checklist.
Daily monitoring of wet suppression of site
unpaved roads to be reported in daily field
HSE report and weekly Environmental
Checklist.
Monthly maintenance reporting on site
vehicles and construction machinery to be
reported in weekly Environmental Checklist
and quarterly Environmental Audit Report.

Project Number 44130065

Page 129

EPC Site
Environmental
Manager

Low

Combustion
and Fugitive
Emissions
from
Operation of
AL GHAITH
Plant

No Impact

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Operation

Emissions
from
operation of
fuel
consuming
vehicles
and
equipment

Air Quality

Emissions
from
operation of
fuel
consuming
vehicles
and
equipment

Decommissioning

Signific
ance

Construction

Phase

Air Quality

Impact

Air Quality

Receptor

Mitigation

Monitoring

The Al Ghaith Plant Environmental Manager will

ensure that speed restrictions and minimization of
double-handling are ensured on all light and heavy
vehicles travelling within the plant during operations,
in order to reduce the generation of exhaust.

Daily monitoring of site traffic following speed

restrictions to be reported in daily field HSE
report and weekly Environmental Checklist.

Similar to the Construction Phase, the Al Ghaith Plant

Operations Manager will also ensure that all
construction machinery and vehicles operational on
site are maintained according to a set schedule as per
the manufacturers specifications so that they are in
good working condition at all times and consequently
non-design exhaust emissions are minimised.

Same as for the Construction phase above.

Daily monitoring of minimization of doublehandling of vehicles to be reported in daily

field HSE report and weekly Environmental
Checklist.
Monthly maintenance reporting on site
vehicles and construction machinery to be
reported in weekly Environmental Checklist
and quarterly Environmental Audit Report.

Same as for the Construction phase above.

Responsible Party

Al Ghaith Plant
Environmental
Manager
Al Ghaith Plant
Operations Manager

Al Ghaith Plant
Environmental
Manager
Al Ghaith Plant
Operations Manager

Not applicable.

Not applicable.

Project Number 44130065

Page 130

Not applicable.

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

Low

Combustion
and Fugitive
Emissions
from
Operation of
AL GHAITH
Plant

Operations

Air Quality

Since the potential mitigation measures concern the

design of the plant facilities, the EPC Contractor in
coordination with the Project Proponent will select the
appropriate mitigation measures to be implemented in
order to reduce combustion-related and fugitive
emissions from operation of the Al Ghaith plant.
These measures are detailed hereunder.
With respect to fugitive emissions, the EPC
Engineering Coordinator will ensure that appropriate
flow level controllers are installed in the back up fuel
storage tanks in order to alert operators to fuel levels
in the tank in excess of design levels and
consequently trigger appropriate action to mitigate the
scenario where VOCs are built up at the top of the
tank resulting in their accelerated fugitive emissions.

EPC Engineering
Contractor
Maintenance of plant equipment as per
manufacturer specifications and Plant
Maintenance Philosophy to be documented
in Plant Maintenance Checklist

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

No Impact

Combustion
and Fugitive
Emissions
from
Operation of
AL GHAITH
Plant

Decommissioning

Air Quality

The Al Ghaith Plant Operations Manager will ensure

that all plant equipment are regularly maintained to
manufacturer specifications in order to reduce the
potential for non-design performance of the
equipment that can result in higher direct emissions
from equipments such as the GTs as well as fugitive
emissions from equipments such as valves and
flanges.

Not applicable.

Not applicable.

Project Number 44130065

Page 131

Al Ghaith Plant
Operations Manager
(Third Party
Specialist if
required)

Not applicable.

Emission of
Greenhouse
Gasses

Phase

Signific
ance

Mitigation

Monitoring

The EPC Site Environmental Manager and/or EPC

Maintenance Manager will encourage implementation
of good construction practices with respect to
handling GHG containing materials such as
refrigerants, as mentioned in Section 5.1.2.3. This
will be to ensure that fugitive emissions from
improperly closed storage containers are prevented.
Low

Impact

Construction

Air Quality

Receptor

This would typically involve ensuring that safety

valves on refrigerant gas containing cylinders are only
opened when they are in use and otherwise kept
normally shut to reduce the potential for fugitive
emissions.

Responsible Party

Daily monitoring of shutting off safety valves

on refrigerant gas containing cylinders to be
reported in the daily Field HSE Report, and the
weekly Environmental Inspection Checklist.

EPC Site
Environmental
Manager

Same as for Construction phase above.

Al Ghaith Plant
Environmental
Manager

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Emission of
Greenhouse
Gasses

Decommissioning

Air Quality

However, the best form of mitigation would be to

utilize alternate refrigerant gas that does not have a
GHG impact.

Same as for Construction phase above.

Project Number 44130065

Page 132

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Low

Emissions
from
accidental
events

Construction

Air Quality

The EPC Site Environmental Manager will ensure that

appropriate internal wiring is utilised in construction
machinery and it is run according to the
manufacturers specifications in order to reduce the
potential for a fire occurring due to a short-circuit and
therefore the resulting combustion emissions.
Additionally, it will also be ensured that the machinery
is regularly inspected and maintained in order to
reduce the potential for non-design performance of
the equipment and therefore resulting higher direct
exhaust emissions.
The EPC Site Environmental Manager will also
ensure that flammable chemicals on site are
temporarily stored in accordance with the
manufacturers and MSDS requirements, in order to
reduce the potential for an accidental fire occurring.
As a further fire preventative measure, the EPC Site
Environmental Manager will also enforce an indoor
no-smoking policy within the site buildings (i.e.
offices) to reduce the potential for human-induced
fires occurring. Relevant employees will also be
trained in the measures to be followed in case a fire
breaks out so that it can be controlled soon after
break-out and the risk to employees health reduced.
The EPC Site Environmental Manager will also
prepare a project emergency response strategy/plan
addressing appropriate emergency procedures to be
followed in case of a fire occurring during construction
works. Again, this will ensure that a fire can be
controlled soon after it breaks out and the risk of
deterioration of ambient air quality and employees
health is reduced.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Responsible Party

Weekly monitoring of appropriate internal

wiring utilised in construction machinery to
be reported in weekly field maintenance
report.
Monthly monitoring of the maintenance of site
vehicles and construction machinery to be
reported in Weekly Environmental Inspection
Checklist and Quarterly Environmental Audit
Report.
Daily monitoring of appropriate storage of
flammable chemicals to be reported in
weekly field maintenance report.
Daily enforcement of indoor no smoking policy
to be reported in weekly field maintenance
report.
Quarterly monitoring of fire response
procedure documentation and review of
appropriate training for staff to be
documented within the Quarterly
Environmental Audit Report.

Project Number 44130065

Page 133

EPC Site
Environmental
Manager

Emissions
from
accidental
events

Phase

Signific
ance

Mitigation

Monitoring

To reduce the risk of a human induced fire occurring

near to the large diesel inventory on site in the back
up fuel storage tanks, as well as to prevent any
adverse effects on humans in the vicinity of the tanks,
the Plant Operator will enforce controlled access of
personnel/visitors to the back-up fuel storage tanks.
Moreover, the area around the storage tanks will
strictly be a no-smoking zone in order to minimise the
potential for the fuel being ignited.
Low

Impact

Operation

Air Quality

Receptor

In addition to these, the Plant Operator will also

exercise control over the inventory of fuel entering the
back-up fuel storage tanks and stored in them via the
flow level controllers assembly as part of the tanks, in
order to prevent an overflow occurring and raising the
potential for a fire occurring due to accidental ignition.

All

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Monitoring undertaken once for appropriate

flow level control in back-up fuel storage tanks.
To be undertaken by the Plant Control Room
Operator, and reported within the Plant
Description Documentation.

Al Ghaith Plant
Environmental
Manager

Quarterly monitoring of the fire response

procedure and the appropriate training of staff
to be reported in the Quarterly
Environmental Report.

Low

Decommissioning

Cumulative

Daily monitoring of the Controlled Access of

plant personnel/visitors to back-up fuel storage
tanks reporting not applicable.

Same as for Construction phase.

Same as for Construction phase.

EPC Site
Environmental
Manager

Air Quality

Emissions
from
accidental
events

Air Quality

The Plant Operator will also be responsible for

enforcing the site emergency response requirements
in the event of a fire occurring to facilitate controlling
the fire at the earliest.

Responsible Party

No additional mitigation required.

No additional monitoring required.

Project Number 44130065

Page 134

Residual

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Phase

Signific
ance

Impact

All

Air Quality

Receptor

Mitigation

Monitoring

No additional mitigation required.

No additional monitoring required.

Project Number 44130065

Page 135

Responsible Party

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. CEMP to include solid waste management.

2. Reduce, reuse, recycling of wastes where
possible.
3. Dedicated solid waste storage area on site.
4. Storage area to have hard standing base and
appropriate drainage.
5. Segregate wastes where feasible.

7. Waste transfer notes used for Environmental

Service Providers.
Low

Solid Waste

Construction

Waste Management

6. Inventory maintained for wastes on site.

Daily monitoring of quantities and types of

solid waste stored on site to be recorded on
waste checklists by the EPC Site
Environmental Manager

8. Appointed Environmental Service Provider to

prepare a waste management plan for the site
including frequency of collections.
9. Good site housekeeping.
10. Covering of soil stock piles.
11. Colour coded skips and rubbish bins around site.
12. Clear signage for solid waste storage areas.
13. Training of staff in waste management
procedures.
14. Materials ordered on a as needs basis.
15. Preparation of a decommissioning waste
management plan.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 136

EPC Site
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. OEMP to include solid waste management.

2. Reduce, reuse, recycling of wastes where
possible.
3. Dedicated solid waste storage area on site.
4. Storage area to have hard standing base and
appropriate drainage.
5. Segregate wastes where feasible.

7. Waste transfer notes used for Environmental

Service Providers.
Low

Solid Waste

Operation

Waste Management

6. Inventory maintained for wastes on site.

Daily monitoring of quantities and types of

solid waste stored on site to be recorded on
waste checklists by the Al Ghaith Plant
Environmental Manager

8. Appointed Environmental Service Provider to

prepare a waste management plan for the site
including frequency of collections.
9. Good site housekeeping.
10. Covering of soil stock piles.
11. Colour coded skips and rubbish bins around site.
12. Clear signage for solid waste storage areas.
13. Training of staff in waste management
procedures.
14. Materials ordered on a as needs basis.
15. Preparation of a decommissioning waste
management plan.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 137

Al Ghaith Plant
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

Daily monitoring of quantities and types of

solid waste stored on site to be recorded on
waste checklists by the Site Environmental
Manager (Contractor)

Site Environmental
Manager
(Contractor)

1. DEMP to include solid waste management.

2. Reduce, reuse, recycling of wastes where
possible.
3. Dedicated solid waste storage area on site.
4. Storage area to have hard standing base and
appropriate drainage.
5. Segregate wastes where feasible.

7. Waste transfer notes used for Environmental

Service Providers.
Moderate

Solid Waste

Decommissioning

Waste Management

6. Inventory maintained for wastes on site.

8. Appointed Environmental Service Provider to

prepare a waste management plan for the site
including frequency of collections.
9. Good site housekeeping.
10. Covering of soil stock piles.
11. Colour coded skips and rubbish bins around site.
12. Clear signage for solid waste storage areas.
13. Training of staff in waste management
procedures.
14. Materials ordered on a as needs basis.
15. Preparation of a decommissioning waste
management plan.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 138

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. CEMP to include liquid waste management.

2. Monitoring and treatment of all effluent discharges
to the marine environment to ensure that they meet
ADWEAs permissible discharge limits set for this
project.
3. Potable water used for hydrotesting.
4. Reduce, reuse, recycling of wastes where
possible.
5. Dedicated liquid waste storage area on site.
6. Liquid wastes stored in good quality, sealed and
labelled drums.
7. Incompatible liquid wastes stored separately.

Liquid
Waste

Moderate

9. Segregate wastes where feasible.

Construction

Waste Management

8. Storage area to have hard standing base and

appropriate drainage.

10. Inventory maintained for wastes on site.

11. Waste transfer notes used for Environmental
Service Providers.
12. Appointed Environmental Service Provider to
prepare a waste management plan for the site
including frequency of collections.

Daily monitoring of quantities and types of

liquid waste stored on site- to be recorded on
site checklist by EPC Site Environmental
Manager
Pre-discharge monitoring of water quality of
dewatering discharge testing against
permissible discharge limits set for this
project/EAD limits to be undertaken by EPC
Site Environmental Manager

13. Good site housekeeping.

14. Clear signage for liquid waste storage areas.
15. Training of staff in waste management
procedures.
16. Chemicals ordered on a as needs basis.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

17. Spill response plan and appropriate staff spill

Project Number 44130065

Page 139

EPC Site
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. OEMP to include liquid waste management.

2. Monitoring and treatment of all effluent discharges
to the marine environment to ensure that they meet
ADWEAs permissible discharge limits set for this
project.
3. Potable water used for hydrotesting.
4. Reduce, reuse, recycling of wastes where
possible.
5. Dedicated liquid waste storage area on site.
6. Liquid wastes stored in good quality, sealed and
labelled drums.
7. Incompatible liquid wastes stored separately.

Liquid
Waste

Critical

9. Segregate wastes where feasible.

Operation

Waste Management

8. Storage area to have hard standing base and

appropriate drainage.

10. Inventory maintained for wastes on site.

11. Waste transfer notes used for Environmental
Service Providers.
12. Appointed Environmental Service Provider to
prepare a waste management plan for the site
including frequency of collections.

Continuous monitoring of closed circuit cooling

water discharge for temperature at the Al
Ghaith Plant discharge point. To be the
responsibility of the Al Ghaith Plant Operations
Manager.
Monthly monitoring of desalination plant brine
water discharge with water quality testing
against ADWEAs permissible discharge limits
set for this project to be conducted by Al
Ghaith Plant Environmental Manager

13. Good site housekeeping.

14. Clear signage for liquid waste storage areas.
15. Training of staff in waste management
procedures.
16. Chemicals ordered on a as needs basis.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

17. Spill response plan and appropriate staff spill

Project Number 44130065

Page 140

Al Ghaith Plant
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. DEMP to include liquid waste management.

2. Monitoring and treatment of all effluent discharges
to the marine environment to ensure that they meet
ADWEAs permissible discharge limits set for this
project.
3. Potable water used for hydrotesting.
4. Reduce, reuse, recycling of wastes where
possible.
5. Dedicated liquid waste storage area on site.
6. Liquid wastes stored in good quality, sealed and
labelled drums.
7. Incompatible liquid wastes stored separately.

9. Segregate wastes where feasible.

Moderate

Liquid
Waste

Decommissioning

Waste Management

8. Storage area to have hard standing base and

appropriate drainage.

10. Inventory maintained for wastes on site.

11. Waste transfer notes used for Environmental
Service Providers.
12. Appointed Environmental Service Provider to
prepare a waste management plan for the site
including frequency of collections.
13. Good site housekeeping.
14. Clear signage for liquid waste storage areas.

Daily monitoring of quantities and types of

liquid waste stored on site- to be recorded on
site checklist by Site Environmental Manager
(Contractor)
Pre-disposal water quality testing of hydrotest
water against ADWEAs permissible discharge
limits set for this project/EAD limits to be
undertaken by the Site Environmental
Manager (Contractor).
Pre-discharge monitoring of water quality of
dewatering discharge testing against ADWEAs
permissible discharge limits set for this
project/EAD limits to be undertaken by Site
Environmental Manager
(Contractor).Continuous

15. Training of staff in waste management

procedures.
16. Chemicals ordered on a as needs basis.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

17. Spill response plan and appropriate staff spill

Project Number 44130065

Page 141

Site Environmental
Manager
(Contractor)

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. CEMP to include hazardous waste management.

2. Monitoring and treatment of all effluent discharges
to the marine environment to ensure that they meet
ADWEAs permissible discharge limits set for this
project.
3. Reduce, reuse, recycling of hazardous wastes
where possible.
4. Dedicated hazardous waste storage area on site.
5. Hazardous liquid wastes stored in good quality,
sealed and labelled drums.
6. Incompatible hazardous wastes stored separately.

Hazardous
Waste

Moderate

8. Storage area only to be accessible to approved

and trained staff.
Construction

Waste Management

7. Storage area to have hard standing base and

appropriate drainage.

9. Segregate hazardous wastes where feasible.

10. Inventory maintained for wastes on site.
11. Waste transfer notes used for Environmental
Service Providers.

Daily monitoring of quantities and types of

hazardous waste stored on site- to be
recorded on waste checklist by EPC Site
Environmental Manager

12. Appointed Environmental Service Provider to

prepare a waste management plan for the site
including frequency of collections.
13. Good site housekeeping.
14. Clear signage for hazardous waste storage
areas.
15. Training of staff in waste management
procedures.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Project Number 44130065

Page 142

EPC Site
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. OEMP to include hazardous waste management.

2. Monitoring and treatment of all effluent discharges
to the marine environment to ensure that they meet
ADWEAs permissible discharge limits set for this
project.
3. Reduce, reuse, recycling of hazardous wastes
where possible.
4. Dedicated hazardous waste storage area on site.
5. Hazardous liquid wastes stored in good quality,
sealed and labelled drums.
6. Incompatible hazardous wastes stored separately.

Hazardous
Waste

Moderate

8. Storage area only to be accessible to approved

and trained staff.
Operation

Waste Management

7. Storage area to have hard standing base and

appropriate drainage.

9. Segregate hazardous wastes where feasible.

10. Inventory maintained for wastes on site.
11. Waste transfer notes used for Environmental
Service Providers.

Daily monitoring of quantities and types of

hazardous waste stored on site- to be
recorded on waste checklist by Al Ghaith Plant
Environmental Manager

12. Appointed Environmental Service Provider to

prepare a waste management plan for the site
including frequency of collections.
13. Good site housekeeping.
14. Clear signage for hazardous waste storage
areas.
15. Training of staff in waste management
procedures.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Project Number 44130065

Page 143

Al Ghaith Plant
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

Daily monitoring of quantities and types of

hazardous waste stored on site- to be
recorded on waste checklist by Site
Environmental Manager (Contractor)

Site Environmental
Manager
(Contractor)

1. DEMP to include hazardous waste management.

2. Monitoring and treatment of all effluent discharges
to the marine environment to ensure that they meet
ADWEAs permissible discharge limits set for this
project.
3. Reduce, reuse, recycling of hazardous wastes
where possible.
4. Dedicated hazardous waste storage area on site.
5. Hazardous liquid wastes stored in good quality,
sealed and labelled drums.
6. Incompatible hazardous wastes stored separately.

8. Storage area only to be accessible to approved

and trained staff.
Moderate

Hazardous
Waste

Decommissioning

Waste Management

7. Storage area to have hard standing base and

appropriate drainage.

9. Segregate hazardous wastes where feasible.

10. Inventory maintained for wastes on site.
11. Waste transfer notes used for Environmental
Service Providers.
12. Appointed Environmental Service Provider to
prepare a waste management plan for the site
including frequency of collections.
13. Good site housekeeping.
14. Clear signage for hazardous waste storage
areas.
15. Training of staff in waste management
procedures.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 144

No additional monitoring identified.

No monitoring identified.

No monitoring identified.

No additional mitigation measures identified.

Residual
impact

No additional monitoring identified.

Cumulative
Impact

No additional mitigation measures identified.

Disturbance
to site soils

Low

Monitoring

No mitigation identified.

Disturbance
to site soils

Low

Mitigation

All Phases

Signific
ance

All Phases

Phase

Construction

Impact

Operation

Geology, Seismicity, Soil, Geology, Seismicity, Soil,

and Groundwater
and Groundwater

Waste
Waste
Management Management

Receptor

No mitigation identified.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 145

Responsible Party

Disturbance
to site soils

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Phase

Signific
ance

Low

Impact

Decommissioning

Geology, Seismicity, Soil,

and Groundwater

Receptor

Mitigation

Monitoring

No mitigation identified.

No monitoring identified.

Project Number 44130065

Page 146

Responsible Party

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

1. Secondary containment (i.e. drip pans or concrete

containment) will be provided for fuel and chemical
storage tanks such that containment is designed for a
minimum of 110% of the total volume of the largest
storage tank
2. Fuel and chemical storage tanks will be located at
a designated position and appropriate clear signage
and barrier protection from vehicular movements.
3. All hard-standing and bunds will be inspected on a
regular basis and cracks reported and repaired.
4. All temporary fuel storage tanks will be doublewalled containers.
5. Acid wash waste, if applicable, during
commissioning will be fully contained and removed
from site by authorised waste management
contractors.
6. Refuelling will be undertaken in designated areas
following set procedures, to be set out in the CEMP.
7. Vehicles operating on site will undergo routine
maintenance and regular inspection to minimise the
potential for leakage of oil and other fluids.

ismicity, Soil, and Groundwater

8. A regular equipment and tank inspection and repair

program will be developed on site.
9. Emergency shut down and spill response
procedures for a hazardous waste spill will be
required to be developed and implemented by the
EPC contractor.
10. The EPC contractor will encourage workers to
report all spills using a no blame culture.
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Daily inspection of Fuel and chemical storage

facilities to be undertaken by the EPC Site
Environmental Manager and reported in the
Daily Field HSE Report, and Weekly
Environmental Inspection Checklist
Hardstanding areas and bunds inspected
weekly by the EPC Site Environmental
Manager and reported in the Weekly
Environmental Inspection Checklist
Vehicle inspections inspected weekly by the
EPC Site Environmental Manager and
reported in the Weekly Environmental
Inspection Checklist

Project Number 44130065

Page 147

Responsible Party

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. EPC contractor to develop OEMP including an

environmental monitoring plan.
2. Appropriate protocols will be established for the
transfer and disposal of contaminated fuel, oil and soil
in accordance with Municipality requirements in the
Waste Management Plan.

Contaminati
on of soil

Moderate

4. Refuelling & maintenance to be carried out at

designated sealed hardstanding area/s with
appropriate spill clean up and containment facilities.

Operation

Geology, Seismicity, Soil, and Groundwater

3. Fuel, oil and chemical storage facilities to include

110% secondary containment.

5. If any inadvertent leakage or spillage of

hydrocarbons occurs, the operator will implement spill
response measures to contain and excavate any
contaminated soil present.
6. Chemical Management, Waste Management,
Emergency and Spill Response plans will be
established for the site.
7. All contaminated wastewater will be treated to
within appropriate discharge limits prior to disposal.
8. Routine and regular documented inspections of
the plant including chemical/oil/fuel storage facilities
and waste storage areas.

Weekly inspection of Fuel and chemical

storage facilities to be undertaken by the Al
Ghaith Plant Environmental Manager and
reported in the Weekly Environmental
Inspection Checklist.
Weekly inspection of Plant facilities to be
undertaken by Al Ghaith Plant Environmental
Manager and recorded in the Weekly
Environmental Inspection Checklist.
Monthly inspection and maintenance of site
vehicles and plant machinery to be undertaken
by the Al Ghaith Plant Environmental Manager
and reported in the Weekly Environmental
Inspection Checklist, and the Quarterly
Environmental Audit Report

9. Immediate excavation and removal of any

contaminated soil to the designated waste facility.
These measures when followed properly as part of a
rigorous OEMP will largely mitigate against the
potential for soil contamination. However due to the
presence of plant and buildings associated with the
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Project Number 44130065

Page 148

Al Ghaith Plant
Environmental
Manager

Contaminati
on of soil

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Phase

Signific
ance

Moderate

Impact

Decommissioning

Geology, Seismicity, Soil, and

Groundwater

Receptor

Mitigation

Monitoring

Responsible Party

Same as for Construction phase.

Same as for Construction phase.

Site Environmental
Manager
(Contractor)

Project Number 44130065

Page 149

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

1. Secondary containment (i.e. drip pans or concrete

containment) will be provided for fuel and chemical
storage tanks such that containment is designed for a
minimum of 110% of the total volume of the largest
storage tank
2. Fuel and chemical storage tanks will be located at
a designated position and appropriate clear signage
and barrier protection from vehicular movements.
3. All hard-standing and bunds will be inspected on a
regular basis and cracks reported and repaired.
4. All temporary fuel storage tanks will be doublewalled containers.
5. Acid wash waste, if applicable, during
commissioning will be fully contained and removed
from site by authorised waste management
contractors.
6. Refuelling will be undertaken in designated areas
following set procedures, to be set out in the CEMP.
7. Vehicles operating on site will undergo routine
maintenance and regular inspection to minimise the
potential for leakage of oil and other fluids.

ismicity, Soil, and Groundwater

8. A regular equipment and tank inspection and repair

program will be developed on site.
9. Emergency shut down and spill response
procedures for a hazardous waste spill will be
required to be developed and implemented by the
EPC contractor.
10. The EPC contractor will encourage workers to
report all spills using a no blame culture.
Contaminati
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Daily inspection of Fuel and chemical storage

facilities to be undertaken by the EPC Site
Environmental Manager and reported in the
Daily Field HSE Report, and Weekly
Environmental Inspection Checklist
Hardstanding areas and bunds inspected
weekly by the EPC Site Environmental
Manager and reported in the Weekly
Environmental Inspection Checklist
Vehicle inspections inspected weekly by the
EPC Site Environmental Manager and
reported in the Weekly Environmental
Inspection Checklist

Project Number 44130065

Page 150

Responsible Party

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

1. EPC contractor to develop OEMP including an

environmental monitoring plan.
2. Appropriate protocols will be established for the
transfer and disposal of contaminated fuel, oil and soil
in accordance with Municipality requirements in the
Waste Management Plan.

Contaminati
on of
shallow
groundwate
r

Moderate

4. Refuelling & maintenance to be carried out at

designated sealed hardstanding area/s with
appropriate spill clean up and containment facilities.

Operation

Geology, Seismicity, Soil, and Groundwater

3. Fuel, oil and chemical storage facilities to include

110% secondary containment.

5. If any inadvertent leakage or spillage of

hydrocarbons occurs, the operator will implement spill
response measures to contain and excavate any
contaminated soil present.
6. Chemical Management, Waste Management,
Emergency and Spill Response plans will be
established for the site.
7. All contaminated wastewater will be treated to
within appropriate discharge limits prior to disposal.
8. Routine and regular documented inspections of
the plant including chemical/oil/fuel storage facilities
and waste storage areas.

Weekly inspection of Fuel and chemical

storage facilities to be undertaken by the Al
Ghaith Plant Environmental Manager and
reported in the Weekly Environmental
Inspection Checklist.
Weekly inspection of Plant facilities to be
undertaken by Al Ghaith Plant Environmental
Manager and recorded in the Weekly
Environmental Inspection Checklist.
Monthly inspection and maintenance of site
vehicles and plant machinery to be undertaken
by the Al Ghaith Plant Environmental Manager
and reported in the Weekly Environmental
Inspection Checklist, and the Quarterly
Environmental Audit Report

9. Immediate excavation and removal of any

contaminated soil to the designated waste facility.
These measures to minimise contamination
occurrences within the soil horizon will largely mitigate
against the potential for shallow groundwater
contamination. However, due to the presence of plant
PEHSR Chlor-Alkali Plant
Al Ghaith Industries

Project Number 44130065

Page 151

Al Ghaith Plant
Environmental
Manager

Residual
Impacts

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Signific
ance

Geology, Seismicity, Soil,

and Groundwater

Cumulative
Impact

Phase

All

Impact

All

Geology, Seismicity, Soil, and Groundwater

Receptor

Mitigation

Monitoring

No additional mitigation identified.

Monitoring the cumulative impacts on soil and

groundwater is not generally practicable, due
to the spatial distribution of monitoring points
generally required and the associated often
prohibitive costs. However, permanent
groundwater monitoring wells, if established
across the Al Ghaith site, would allow regular
monitoring of groundwater quality throughout
all phases of the project. During the
construction phase, weekly monitoring would
be suitable under the responsibility of the EPC
Site Environmental Manager with results
reported weekly. During the operations phase
of the project, annual monitoring would
potentially be sufficient under the responsibility
of the Al Ghaith Plant Environmental Manager.
The decommissioning phase would mirror the
construction monitoring requirements.

Al Ghaith Plant
Environmental
Manager

No additional mitigation measures identified.

Permanent groundwater monitoring boreholes

to be established on the Al Ghaith Plant site,
and quarterly routine monitoring program to be
established to be reported in Quarterly
Environmental Audit Report to EAD

Al Ghaith Plant
Environmental
Manager

Project Number 44130065

Page 152

Responsible Party

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

Low

Loss of
habitat
within Al
Ghaith
project site

Construction

Terrestrial Ecology

1. Clearing of vegetation will be confined to that

necessary for the establishment of the plant. Areas
for clearance will be established with the EPC HSE
Site Coordinator before works.
2. Management strategies will be implemented to
protect any remaining native vegetation communities
by controlling the occurrence and spread of weeds
and minimising the impact of soil
erosion/sedimentation. This will include general good
housekeeping on site and assessment during the
daily site inspection by the EPC HSE Site
Coordinator.

Monitoring for compliance with selected

mitigation measures during the construction
phase shall be undertaken by the EPC Site
Environmental Manager during daily
inspections and shall be recorded within the
Field HSE Report and the weekly
Environmental Inspection Checklist..

These measures will not fully mitigate the loss of the

present habitats as this impact is unavoidable due to
the footprint of the plant facilities. These measures
will, however, reduce the impact from loss of habitat
as far as possible.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 153

EPC Site
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

Low

Loss of
habitat
within
Chlor-Alkali
project site

Operation

Terrestrial Ecology

No specific measures have been identified to mitigate

the loss of native habitat on site. However:
1. Planting vegetation composed of local species,
preferably coastal, within the available space will
provide green areas. Such landscaping within the
plant fence line will provide some habitat/shelter for
species including insects and birds on site, and
though not directly mitigating for the impact, will
provide areas of some limited value. Such areas
would also be visually appealing, particularly if
instated in administration or office areas. Basic
landscaped areas also cost relatively little to instate
and maintain.

No monitoring identified.

Al Ghaith Plant
Environmental
Manager

No monitoring identified.

Site Environmental
Manager
(Contractor)

It should be noted that the impact of habitat loss will

be realised during the construction phase and that the
operational phase will not further increase this impact.
In addition, landscaping mitigation will only provide
alternate habitat and limited compensation and will
not provide any habitat recreation.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Loss of
habitat
within
Chlor-Alkali
project site

Decommissioning

Terrestrial Ecology

Responsibility for landscaping during the operational

phase will be with the Al Ghaith Plant Environmental
Manager. This activity will be a continual activity,
likely falling within the plant maintenance schedule.

Same as for Construction phase.

Project Number 44130065

Page 154

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

No mitigation identified.

No monitoring identified.

Low

No mitigation identified.

No monitoring identified.

Low

Residual
impact.

Monitoring

No mitigation identified.

No monitoring identified.

Cumulative
impact.

Mitigation

No cumulative impact was identified, therefore no

mitigation is suggested.

No monitoring identified.

Construction

Disturbance
to flora and
fauna within
Chlor-Alkali
Project site

All

Operation

Disturbance
to flora and
fauna within
Chlor-Alkali
Project site

All

Decommissioning

Terrestrial
Ecology

Disturbance
to flora and
fauna within
Chlor-Alkali
Project site

Terrestrial
Ecology

Signific
ance

Terrestrial Ecology

Phase

Terrestrial
Ecology

Impact

Terrestrial
Ecology

Receptor

No additional mitigation measures identified.

No additional monitoring identified.

Project Number 44130065

Page 155

Responsible Party

Emissions
from
operation of
vehicles
and
temporary
equipment

Phase

Signific
ance

Mitigation

Monitoring

The EPC Site Environmental Manager will enforce

speed restrictions on site traffic and ensure that
equipment used on an intermittent basis (such as
bulldozers or idling cars) will be shut down or throttled
down to a minimum to cut down on unnecessary
noise emissions. Moreover, any known noisy
activities such as piling will be scheduled such that
they occur during daylight hours in order to minimise
potential disturbance to humans as well as fauna
during the night time when they are more sensitive to
changes in noise levels.
Low

Impact

Construction

Noise

Receptor

The EPC Site Environmental Manager will also

ensure that all known noisy construction equipment
(such as hand tools or air compressors) have acoustic
covers installed on their noisy parts (e.g. engines),
which are kept closed at all times.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Emissions
from
operation of
vehicles
and
temporary
equipment

Operation

Noise

The EPC Maintenance Manager will also ensure that

all construction machinery and vehicles operational
on site are maintained according to a set schedule as
per the manufacturers specifications so that they are
in good working condition at all times and
consequently non-design noise emissions are
minimised.

Same as for the Construction phase above.

Responsible Party

Daily monitoring of site traffic following speed

restrictions to be recorded in daily site HSE
Report and also in weekly Environmental
Inspection Checklist.
Daily monitoring of equipment/vehicles used
on intermittent basis shut down or throttled
down to minimum when not in use to be
recorded in daily site HSE Report and also in
weekly Environmental Inspection Checklist.
Daily monitoring of noisy activities not
conducted at night (as far as is practicable)
to be recorded in daily site HSE Report and
also in weekly Environmental Inspection
Checklist.

EPC Site
Environmental
Manager

Daily monitoring of appropriate acoustic

covers installed on noisy equipment to be
recorded in daily site HSE Report and also in
weekly Environmental Inspection Checklist.
Monthly monitoring of maintenance of site
vehicles and construction machinery to be
recorded in weekly Environmental Inspection
Checklist and quarterly Environmental Audit
Report.

Same as for the Construction phase above.

Project Number 44130065

Page 156

Al Ghaith Plant
Environmental
Manager

Noise

Emissions
from
operation of
vehicles
and
temporary
equipment

Decommissioning

Noise

Emissions
from
operation of
Chlor-Alkali
Plant

Construction

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Mitigation

Monitoring

Low

Signific
ance

Impact

Same as for the Construction phase above.

Same as for the Construction phase above.

No Impact

Phase

Receptor

Not applicable.

Not applicable

Project Number 44130065

Page 157

Responsible Party

Al Ghaith Plant
Environmental
Manager

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Responsible Party

Maintenance of plant equipment as per

manufacturer specifications and Plant
Maintenance Philosophy to be recorded in
Plant Maintenance Checklist

Al Ghaith Plant
Operations Manager

Moderate

Emissions
from
operation of
Chlor-Alkali
Plant

Operation

Noise

Since the potential mitigation measures concern the

design of the plant facilities, the EPC Contractor in
coordination with the Project Proponent will select the
appropriate mitigation measures to be implemented in
order to reduce noise emissions from operation of the
Al Ghaith plant. These measures are detailed
hereunder.
Plant equipment will be selected and installed that
has been designed to adhere to the Project noise
philosophy as well as local regulations to minimise the
potential for exceedance of noise limits during normal
operation of the plant.
The Al Ghaith Plant Operations Manager also will
ensure that all plant equipment are regularly
maintained to manufacturer specifications in order to
reduce the potential for non-design performance of
the equipment that can result in higher noise
emissions from equipments.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

No Impact

Emissions
from
operation of
Al Ghaith
Plant

Decommissioning

Noise

It is recommended that low noise valves are used

where practicable to minimise noise emissions during
emergency situations and to protect any worker at a
position close to these valves.

Not applicable.

Note applicable.

Project Number 44130065

Page 158

Emissions
from
abnormal
events

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Phase

Signific
ance

Low

Impact

Construction

Noise

Receptor

Mitigation

Monitoring

The EPC Maintenance Manager will ensure that all

construction machinery and vehicles operational on
site are maintained according to a set schedule as per
the manufacturers specifications so that they are in
good working condition at all times and consequently
non-design noise emissions are minimised.
In case malfunctioning equipment generating
high/non-design levels is found on site, contingency
procedures established by the Maintenance
Department will be in place to address the issue and
rectify it at the earliest possible.

Monthly monitoring of maintenance of site

vehicles and construction machinery to be
recorded in weekly Environmental Inspection
Checklist and the quarterly Environmental
Audit Report.

Project Number 44130065

Page 159

Responsible Party

EPC Site
Environmental
Manager

Emissions
from
abnormal
events

Phase

Signific
ance

Low

Impact

Operation

Noise

Receptor

Mitigation

Monitoring

To reduce the risk of a human induced explosion

occurring near to the large diesel inventory on site in
the back up fuel storage tanks and leading to elevated
noise levels, as well as to prevent any adverse effects
on humans in the vicinity of the tanks, the Plant
Operator will enforce controlled access of
personnel/visitors to the back-up fuel storage tanks.
Moreover, the area around the storage tanks will
strictly be a no-smoking zone in order to minimise the
potential for the fuel being ignited and resulting in a
potential explosion.

Daily enforcement of indoor no smoking policy

to be reported in weekly field maintenance
report.

In addition to these, the Plant Operator will also

exercise control over the inventory of fuel entering the
back-up fuel storage tanks and stored in them via the
flow level controllers assembly as part of the tanks, in
order to prevent an overflow occurring and again
raising the potential for excessive noise emissions
due to a resulting explosion.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Emissions
from
abnormal
events

Decommissioning

Noise

The Plant Operator will also be responsible for

enforcing the site emergency response requirements
in the event of an explosion occurring to facilitate the
appropriate mitigation measures to be implemented to
control the ensuing fire and any associated elevated
noise levels.

Same as for Construction phase.

Responsible Party

Daily monitoring of the Controlled Access of

plant personnel/visitors to back-up fuel storage
tanks reporting not applicable.
Monitoring undertaken once for appropriate
flow level control in back-up fuel storage tanks.
To be undertaken by the Plant Control Room
Operator, and reported within the Plant
Description Documentation.

Al Ghaith Plant
Environmental
Manager

Quarterly monitoring of the fire response

procedure and the appropriate training of staff
to be reported in the Quarterly
Environmental Report.

Monthly monitoring of maintenance of site

vehicles and construction machinery to be
recorded in weekly Environmental Inspection
Checklist and the quarterly Environmental
Audit Report.

Project Number 44130065

Page 160

EPC Site
Environmental
Manager

No monitoring identified.

Al Ghaith Plant
Environmental
Manager

No monitoring identified

No additional mitigation measures identified.

Land used
and
community
impacts

Low

Residual
impact

No mitigation identified.

Land used
and
community
impacts

Low

All

No additional mitigation measures identified.

All

Cumulative
impact

Construction

Monitoring

Operation

Mitigation

Noise

Signific
ance

Noise

Phase

Socioeconomic

Impact

Socioeconomic

Receptor

Maintain as an industrial zone and avoid any new

residential or other recreational activities around the
site

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 161

Responsible Party

Receptor

Impact

Phase

Signific
ance

Mitigation

Monitoring

Low

Land used
and
community
impacts

Decommissioning

Socio-economic

As the socio-economic benefits of the project are

primarily beneficial mitigation measures have not
been identified for most aspects of the project. The
only mitigation measure that has been selected as an
ultimate requirement of the project is:
1. A decommissioning plan for the site is produced.
The decommissioning plan will be the responsibility of
the Operations Manager prior to any
decommissioning activities commencing and will need
to consider issues such as waste handling and
disposal, site investigations, and restoration of the
site. This plan will need to be approved through EAD.

No monitoring program is considered

necessary at this stage of the Project. When
the site is eventually decommissioned post
closure monitoring is recommended to ensure
the fitness of the land for the intended future
use. This shall be determined within the
decommissioning plan.

Responsible Party

Al Ghaith Plant
Environmental
Manager

Decommissioning

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Operation

Social
impact

No monitoring identified.

Major

Construction

Socioeconomic

Social
impact

No mitigation identified.

Provide adequate assistance and facilities to allow

permanent workers to integrate in the local
community.

No monitoring identified.

Low

Socioeconomic

Social
impact

Socio-economic

Note that other environmental mitigation measures

including traffic management that will benefit the
community are addressed in separate sections.

As mitigation for land use during decommissioning

phase.

As monitoring for land use during

decommissioning phase.

Project Number 44130065

Page 162

Decommissioni
ng
All

Residual
impact

All

Socio- Socio-economic
economic
Socioeconomic

Cumulative
impact

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Low

Operation

Economic
impact

No mitigation identified.

No monitoring identified.

Major

Construction

Socioeconomic

Economic
impact

Monitoring

No mitigation identified.

No monitoring identified.

Low

Socioeconomic

Economic
impact

Mitigation

As mitigation for land use during decommissioning

phase.

As monitoring for land use during

decommissioning phase.

Signific
ance

Impact

No additional mitigation measured identified.

No additional monitoring measure identified.

Phase

Receptor

No additional mitigation measured identified.

No additional monitoring measure identified.

Project Number 44130065

Page 163

Responsible Party

5.11. Risk Assessments

In line with EAD technical guidance for EIA (2010) and the EAD EHSMS, accidental
environmental risks associated with the Al Ghaith Project have been assessed within this
section of the EIS.
Accidental impacts are considered to be those impacts which occur due to unplanned
events, mishaps, or failures during any project stage (construction, operation, or
decommissioning). Examples of accidental events include (but are not limited to) the
following:

Failure of materials

Failure of equipment

Non-conformance with procedure

Unforeseen non-routine process

Process equipment/processes not performing according to design parameters

Examples of accidental environmental impacts include (but are not limited to) the
following:

Spills

Leaks

Uncontrolled discharge

Uncontrolled emissions

Generation of wastes (hazardous and non-hazardous)

Fire

Explosion

Process blow-downs

Within the EHSMS, AD EHSMS CoP05 Risk Management (v1.2 July 2009) presents the
methodology for the environmental assessment of accidental impacts.
The
environmental consequence and probability of an accidental impact is used to determine
the level of Risk which may result from the associated project activity. Each
environmental impact is ranked to yield both a consequence and probability score. This
is achieved through the use of prescriptive tables which provide a definition for each
assigned rank (see Table 5 -11 and Table 5 -12).
Environmental consequence of project interactions are ranked between 1 (insignificant
consequences) and 5 (catastrophic consequences), while probability of occurrence is
also ranked from 1 (rare) through to 5 (frequent). Once scores for consequence and

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 164

probability have been established, they are then used to determine the Risk of the
environmental impact through the use of a matrix.
The Risk Categories matrix determines significance through the product of the
environmental consequence of the interaction and the probability of the action occurring,
and is expressed as Risk = probability x consequence. This Risk is expressed as a
number between 1 and 25, with:

1-3 representing low risk

4-6 representing moderate risk

8-12 representing high risk

15-25 signifying extreme risk

The lower half of the matrix provides details on the action which must be taken for
environmental impacts defined within these categories. If a risk is identified as extreme,
the activity/industry can not proceed in its current form as the risk is too high. Other
required actions include design or procedure modifications such as remedial planning and
further action subject to the environmental assessment. The Matrix is shown in Figure 1
-17.
Section 5.11.1 presents the Environmental Hazard and Effects Register (EHER).
Accidental environmental impacts for the Al Ghaith Project are identified and assessed for
the magnitude of the potential environmental risk within the EHER.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 165

Table 5-11
Score

1.

Insignificant
Consequence

Potential Environmental Impact and Potential Incident Consequence Rating from AD EHSMS CoP05

Land-based Ecosystem

Insignificant environmental
impact. Occasional damage by
erosion, or of flora and fauna.
Some disruption to flora or
fauna habitats

Aquatic Ecosystem

Atmosphere/ Waste/ Other

Cultural Heritage (Indigenous

and Modern)

Temporary nuisance from noise,

odour, dust, other air emissions,
greenhouse gasses, vibration,
visual impact.
Occasional short-term impact
and / or disruption to aquatic
flora and fauna.

Minor use of water, fuels and

energy and other natural
resources.

Minor repairable damage to

commonplace structures.

Results in the generation of

significant quantities of nonhazardous wastes.

2.

Minor
Consequence

Minor impacts on fauna/flora

and habitat, but no negative
impacts on ecosystem function.
Limited damage to a minimal
area of land of no significant
value (i.e. no unique habitats).
Temporary damage/disruption
(<1 month) to flora or fauna
habitats.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Minor impact on aquatic

ecosystem, including flora,
fauna and habitat. No
significant impact on water
resources.

Minor environmental impact due

to contained release of pollutant
(including odour, dust and
noise) fire or explosion with no
lasting detrimental effects. No
outside assistance required.
Significant use of water, fuels
and energy and other natural
resources.

Project Number 44130065

Page 166

Minor repairable damage to

structure / items of cultural
significance, or minor
infringement of cultural values /
sacred locations.

Score

3.

4.

Moderate
Consequence

Major
Consequence

Land-based Ecosystem

Aquatic Ecosystem

Atmosphere/ Waste/ Other

Cultural Heritage (Indigenous

and Modern)

Significant changes in
flora/fauna populations and
habitat. Disruption to, or some
death of, rare flora or fauna, but
not resulting in eradication of
endangered species. Nonpersistent but possibly
widespread damage to land;
damage that can be remediated
without long-term loss; localised
persistent damage; or
significant temporary damage
(<1 year) to ecosystem.

Significant localised impacts but

without longer-term impact on
aquatic ecosystems, and/or
short term impacts on water
resources.

Creation of noise, odours, dust,

other controlled/uncontrolled air
emissions, greenhouse gasses,
vibration, and visual impact at
significant nuisance levels.

Moderate damage to
structures / items of cultural
significance, or significant
infringement of cultural values /
sacred locations.

Significant widespread impact

on protected wildlife (e.g.
migratory shorebirds, marine
plants, fish breading grounds),
or aquatic ecosystems of
moderate duration.

Major environmental impact due

to uncontained release, fire or
explosion with detrimental
effects. Outside assistance
required.

Major damage to structures /

items of cultural significance, or
major infringement of cultural
values / sacred locations.

Continuous and serious

damage by erosion or to flora or
fauna. Major disruption to, or
frequent death of, rare flora or
fauna.
Major destruction of significant
habitat.

5.

Catastrophic
Consequence

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Long-term and significant

change in population (e.g.
eradication of endangered
species) or habitat with negative
impact on ecosystem function.
Widespread destruction to a
significant area of land, rare
flora and fauna and/or
groundwater resource.

Damage to an extensive portion

of aquatic ecosystem resulting
in severe impacts on aquatic
populations and habitats and /
or long-term impact on water
resources.

Catastrophic environmental
impact due to uncontained
release, fire or explosion with
detrimental effect. Outside
assistance required.
Extensive chronic discharge of
persistent hazardous pollutant.
Results in the generation of
significant quantities of
intractable wastes

Project Number 44130065

Page 167

Irreparable damage to highly

valued structures / items /
locations of cultural significance
of sacred value.

Table 5-12

Probability of occurrence of Environmental Risk from AD EHSMS CoP05

Description

Likely Frequency

Probability

Frequent

Continuous or will happen frequently

Often

5 12 times per year

Likely

1 5 times per year

Possible

Once every 5 years

Rare

Less than once every 5 years

Consequence (from Table 5 -11)

Probability
(from Table 5 -12)

Insignificant (1)

Minor (2)

Moderate (3)

Major (4)

Catastrophic (5)

Rare (1)

Possible (2)

10

Likely (3)

12

15

Often (4)

12

16

20

Frequent/Almost Certain (5)

10

15

20

25

15 25

Extreme Risk

Activity should not proceed in current form.

8 12

High Risk

Activity should be modified to include remedial planning and action and be subject to
detailed EHS Assessment

46

Moderate Risk

Activity can operate subject to management and/or modification

13

Low Risk

No action required, unless escalation of risk is possible

Figure 1-17

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Risk Categories Matrix from AD EHSMS CoP05

Project Number 44130065

Page 168

5.11.1. Environmental Hazard and Effects Register

This Environmental Hazard and Effects Register (EHER) provides a description of:

Environmental hazards that could be encountered during a phase, activity, or

process associated with the Al Ghaith Project;

The level of environmental risk associated with each identified hazard (accidental
event); and

Control and recovery measures that will be implemented to minimise risk and
occurrence of each hazard (accidental event).

Accidental environmental risks associated with the Al Ghaith Project are qualitatively
screened using the AD EHSMS CoP05 methodology (as described in the previous
section) to determine the risk consequences.
Table and Error: Reference source not found present the EHER for the Construction and
Operational phases of the Al Ghaith project respectively. Decommissioning has not been
included within this section specifically as no information is available at this point in the
schedule to confirm the methodologies or equipment which will be utilised at this point, or
to document the scale of the decommissioning activities. It is therefore assumed that
when the Chlor-Alkali Plant has reached the end of its operational life, the site will be
returned, in so far as is possible, to its pre-Chlor-Alkali construction state. As such, it is
also assumed that any decommissioning activities that take place will mirror the activities
of the construction stage, and therefore the EHER as developed for the construction
phase (see Table ) can be used as a guide to the expected potential accidental impacts of
the decommissioning phase. Accidental impacts during the construction phase should be
considered within the future Decommissioning Plan.
No High or Extreme Environmental Risks have been highlighted for this project. Only
Low and Moderate Environmental Risks have been identified. As such, the CEMP and
OEMP shall be required to include the control and mitigation measures for accidental
environmental impacts as identified within Table and Error: Reference source not found
as the necessary management and/or modification required as part of the EHSMS.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 169

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

LPGs during
construction

Fire/
explosion risk.

Low Risk RiskEnvironmental

Insignificant Consequence

Rare Probability
Rare

H-01.03

Equipment
damage,
personnel
injury/
fatality,
damage to
environment,
reputation.

Low Risk

Fire/
explosion risk.

Potential
consequences
include
equipment
damage,
personnel
injury and
fatality,
damage to
environment
and damage to
reputation.

Insignificant

Natural gas
for boilers

General

H-01.06

Risk Potential
Consequences

Threats / Top Event

Sources

HAZid

Environmental Hazard and Effects Register for the Project

General

Guideword/Activity

Table XXX

Project Number 44130065

Page 170

Risk Controls

Prevention
Controls

Mitigation/Recovery
Controls

Flame
scanners
should be
installed. Gas
line
inspections to
be carried
out regularly.
Additional
preventative
maintenance
procedures to
be carried
out regularly.
Use of LPG
during
construction
adheres to
Health and
Safety
guidance,
operations
procedures
implemented.

Emergency response
team, first aid,
emergency response
procedure

Emergency response
team, first aid,
emergency response
procedure

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Lube and seal

oil

Low Risk RiskEnvironmental

Low Risk

Insignificant Consequence

Rare Probability
Rare

H-02.01

Breach of
containment
resulting in
spillage of
lube/ seal oil.

Insignificant

Fire/
explosion risk.

Consequences

Threats / Top Event

Sources

HAZid

Guideword/Activity
General

Acetylene

Equipment
damage,
personnel
injury/
fatality,
damage to
environment,
reputation.

General

H-01.03

Risk Potential

Damage to
environment.

Project Number 44130065

Page 171

Risk Controls

Prevention
Controls

Mitigation/Recovery
Controls

Use of
Acetylene
during
construction
adheres to
Health and
Safety
guidance,
operations
procedures
implemented.
Oil held in
appropriate
containers,
regular
equipment
maintenance,
operational
procedures in
place.

Emergency response
team, first aid,
emergency response
procedure

Appropriate spill kit

equipment on site.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Corrosion
inhibitors

Low Risk RiskEnvironmental

Low Risk

Insignificant Consequence
Insignificant

Rare Probability
Rare

H-21.11

Breach of
containment
resulting in
spillage of
corrosion
inhibitors.

Low Risk

Diesel fuel

General

H-02.03

Breach of
diesel fuel
containment
resulting in
spill and
potential
source of fire.

Damage to
environment.
Equipment
damage,
environmental
damage,
personnel
injury and/or
fatality,
damage to
reputation.

Insignificant

Hydraulic oil

General

H-02.02

Breach of
containment
resulting in
spillage of
hydraulic oil.

Rare

Consequences

Threats / Top Event

Sources

HAZid

General

Guideword/Activity

Risk Potential

Damage to
environment.

Project Number 44130065

Page 172

Risk Controls

Prevention
Controls

Mitigation/Recovery
Controls

Oil held in
appropriate
containers,
regular
equipment
maintenance,
operational
procedures in
place.
Oil held in
appropriate
containers,
regular
equipment
maintenance,
operational
procedures in
place.
Corrosion
inhibitors
held in
appropriate
containment
units,
operational
procedures in
place.

Appropriate spill kit

equipment on site.

Appropriate spill kit

equipment on site,
emergency response
team, first aid,
emergency response
procedure.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Sodium
hypochlorite

Insignificant

Low Risk RiskEnvironmental

Low Risk
Low Risk

Breach of
containment
resulting in
spillage of
sodium
hypochlorite.

Insignificant Consequence

Rare Probability

Consequences
Damage to
environment.

Insignificant

Breach of
containment
resulting in
spillage of
used engine
oils.

Rare
H-22.04

Al Ghaith Industries

Damage to
environment.
Rare

Used engine
oils

General

H-21.17

PEHSR Chlor-Alkali Plant

Threats / Top Event

Sources

HAZid

Guideword/Activity
General

Scale
inhibitors

General

H-21.12

Breach of
containment
resulting in
spillage of
scale
inhibitors.

Risk Potential

Minor injury,
minor
environmental
impact.

Project Number 44130065

Page 173

Risk Controls

Prevention
Controls

Mitigation/Recovery
Controls

Scale
inhibitors
held in
appropriate
containment
units,
operational
procedures in
place.
Engine oils
held in
appropriate
containment
units,
operational
procedures in
place.
Sodium
hypochlorite
held in
appropriate
containment
units,
operational
procedures in
place.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Al Ghaith Industries

Breach of
containment
resulting in
spillage.

Low Risk RiskEnvironmental

Low Risk

Insignificant Consequence

Moderate Risk

Minor

Damage to
environment,
chemical
burns.
Possible

H-30.01

Dangerous
goods in
transport
activities

Insignificant

Possible
Caustic soda

Breach of
containment
resulting in
spillage of
caustic soda.

General

H-23.04

PEHSR Chlor-Alkali Plant

Possible Probability

Consequences

Threats / Top Event

Sources

HAZid

Guideword/Activity
General

Hydrochloric
acid

Damage to
environment,
chemical
burns.

General

H-23.02

Breach of
containment
resulting in
spillage of
hydrochloric
acid.

Risk Potential

Environmental
, personnel
injury.
Project Number 44130065
Page 174

Risk Controls

Prevention
Controls

Mitigation/Recovery
Controls

HCl held in
appropriate ,
bunded
containment
units,
operational
procedures in
place.
Caustic soda
held in
appropriate
bunded
containment
units,
operational
procedures in
place.
All dangerous
goods in
transit held
in
appropriate
containment
tankers,
operational
safety
procedures in
place.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Trained first aider

on site. Appropriate
spill/ splash kits
available.

Al Ghaith Industries

Ref

ER operations

Low Risk RiskEnvironmental

Low Risk
Low Risk

Damage to
environment.

Damage to
environment.

Low Risk

ER operations

Low Risk

Possible
Ref

Release of
compressor
oil.
Waste water
exceeds
environmental
discharge
limits.

Insignificant Insignificant Insignificant Insignificant Consequence

Rare Probability

Consequences
Environmental
impact.

Rare

Waste Water
System
PEHSR Chlor-Alkali Plant

Rare

Ion exchange
regeneration
waste

Breach of
containment
resulting in
spillage.

Environmental
impact.
Rare

Filter
backwash

Breach of
containment
resulting in
spillage.

Environmental
impact.

Insignificant

Ref

Threats / Top Event

Sources

HAZid

Guideword/Activity
Primary
Brine
Section

Ref

Waste sludge

Instrument Air
System

Secondary
Brine
Section

Secondary
Brine
Section

Ref

Breach of
containment
resulting in
spillage.

Risk Potential

Project Number 44130065

Page 175

Risk Controls

Prevention
Controls

Mitigation/Recovery
Controls

Sludge held
in
appropriate
containment
units.
Brine held in
appropriate
containment
units.

Appropriate spill/
splash kits available.

Liquid must
be held in
appropriate
containment
units.
Safety valve
controls
implemented.
Regular
maintenance
and checking
of safety
valves.
Appropriate
procedures
for informing
regulator in
place.

Appropriate spill/
splash kits available.

Appropriate spill/
splash kits available.

Appropriate spill/
splash kit equipment
on site.

Ref

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Neutralization
tank

Off spec
discharge.

Low Risk RiskEnvironmental

Insignificant Consequence

Rare Probability

Consequences

Threats / Top Event

Sources

HAZid

Effluent
Neutralization
System

Guideword/Activity

Risk Potential

Damage to
environment.

Project Number 44130065

Page 176

Risk Controls

Prevention
Controls

pH
adjustment
prior to
discharge.

Mitigation/Recovery
Controls

None

5.11.2. Control of Major Accident Hazards Report

If a high-risk environmental accidental impact is documented in the EHER (see Section
5.11.1), then under the EAD Technical Guidance for EIA (2010) and the EAD EHSMS, the
proponent is required to write a COMAH report. As no high-risk environmental impacts
have been documented, the submission of a COMAH report is not required for this
project.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 177

5.12. Environmental Management Framework

This section details the Environmental Management Framework for the Al Ghaith Project.
The information provided below is based on the current understanding of the Project and
the associated life cycle phases as best described at this point. It is recognised that
concerns or key issues may change throughout the duration of the Project, and as such
the environmental management of the Project is designed to be both active and reactive
throughout the Projects life. The main documents associated with the environmental
management of the Al Ghaith Project include:

This EIS document.

The Construction Environmental Management Plan (CEMP) to be produced and

approved by EAD before construction works begin.

The Operational Environmental Management Plan (OEMP) to be submitted to EAD

for approval no later than 1 month prior to beginning the operation unless EAD
has agreed to an alternate date. The operation can not commence until written
approval has been received from EAD.

In addition, a Decommission Environmental Management Plan is also a requirement.

This plan has not been considered further within this section as the responsibility for its
completion will lie with the Al Ghaith Project Company to address prior to the scheduled
decommissioning phase, estimated at over 20 years from the operational start date.
The sub-sections below present the information, as best given at this point in the Project,
which relate to the EMF. It should be noted that a full EMF is required to be submitted to
EAD within 12 months after the start of the proposed Project. This information is also
presented to inform the subsequent production of the required CEMP and OEMP.

5.12.1. Environmental Management Program Objectives

The Project-specific Environmental Management Framework (EMF) shall be developed
throughout the life of the Project. It shall facilitate the implementation, tracking, and
reporting of the mitigation and monitoring measures that are identified and committed to
in this EIA report.
The purpose of the EMF is to establish procedures and work practices that will mitigate or
minimise potential impacts to the environment resulting from project activities and provide
effective on-going auditing and monitoring procedures. Implementation of the EMF
ensures the Project meets all relevant Federal Laws governing environmental protection
and complies with relevant guidance and regulations published by EAD.

5.12.2. Roles and Responsibilities

This section details the roles and responsibilities with regard to environmental
management as foreseen at this stage in the Project. This section will be built upon and
greater detail provided during the production of the required CEMP and OEMP as part of
the Environmental Management Framework (EMF) for the Project.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 178

5.12.2.1.

Environment Agency - Abu Dhabi

EAD will evaluate the subsequent management plans as required for the Project, namely
the CEMP and OEMP. EAD will need to issue a Construction Environmental Permit or No
Objection Certificate (NOC), potentially with additional conditions, prior to the start of
construction for the Project. At their discretion, EAD may carry out site inspections to
verify compliance with the required plans.
5.12.2.2.

Al Ghaith Project Company

With overall responsibility for the Project, the Al Ghaith must demonstrate that the Project
minimises or removes any impact to the environment during the lifecycle phases
(construction, operation and decommissioning). The Al Ghaith will be required to formally
review and approve the subsequent management plans (CEMP, OEMP etc) prior to their
submission to EAD.
During Construction the Al Ghaith is responsible for:

Reviewing internal
management.

and

external

audit

reports

relating

to

environmental

Ensuring implementation of any recommendations made in the site audits.

Liaison with EAD representatives throughout the construction and operational phase
of the Project. Al Ghaith will:
o

Report to EAD on a quarterly basis, providing a summary of the audit

reports received; and

Inform EAD immediately should any event occur on site that could have a
significant negative impact on the environment.

During Operational activities the Al Ghaith is responsible for:

Reviewing internal and external audit reports relating to environmental management

and the implementation of the OEMP.

Implementation of the OEMP. Even when specific activities (for example, waste
disposal) are assigned to Subcontractors, it is ultimately the responsibility of Al
Ghaith to ensure OEMP compliance

Ensuring implementation of any recommendations made in the site audits.

Liaison with EAD representatives throughout the construction and operational phase
of the Project. Al Ghaith will:
o

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Report to EAD on a quarterly basis, providing a summary of the audit

reports received; and

Project Number 44130065

Page 179

Inform EAD immediately should any event occur on site that could have a
significant negative impact on the environment.

Details on the individual role responsibilities are provided below:

Operations Manager
The Operations Manager shall directly, or through the supervision of his project team, be
responsible for compliance with the approved OEMP. He will notify the Al Ghaith in
writing of any nominated environmental incident, including details of mitigation measures
taken and amendments made to avoid the future reoccurrence of the incident.
Environmental Manager
The Al Ghaith shall install an Environmental Manager during the operational phase of the
plant, who has demonstrable experience in environmental management of industrial
developments. The Environmental Manager will:

Oversee the implementation of the OEMP and ensure that each Subcontractor is
made aware of, and compliant with, its requirements.

Carry out environmental meetings to ensure that environmental awareness is

promoted throughout the workforce, including the use of posters and other means
as appropriate.

Conduct environmental reviews, regular audits and monitoring.

Report any OEMP non-compliances to the Project Manager.

Report any significant adverse environmental incident, and submit an appropriate

incident report form to the Project Manager.

Be responsible for communication with the EAD-approved third party auditor

regarding environmental reporting.

5.12.2.3.

EPC Consortium

Al Ghaith has appointed XXXX as their EPC Contractors during the construction phase.
The EPC Consortium is responsible for:

Reviewing and approving the CEMP.

Implementation of the CEMP. Even when specific activities (for example, site
preparation or waste disposal) are assigned to Subcontractors, it is ultimately the
responsibility of the EPC Consortium to ensure CEMP compliance.

HSE department review and providing recommendations on all project construction

documentation.

Carrying out periodic HSE audits and review of the Project during the construction
phase to verify that the CEMP is being effectively implemented.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 180

Details on the individual role responsibilities are provided below:

Project Manager
The Project Manager, on behalf of the EPC Consortium, is responsible directly, or by
overseeing his project team, for compliance with the approved CEMP. He will notify the Al
Ghaith in writing of any nominated environmental incident, including details of mitigation
measures taken and amendments made to avoid the future reoccurrence of the incident.
Site Environmental Manager
The EPC Consortium will nominate a Site Environmental Manager, who has
demonstrable experience in environmental management of construction sites and of
implementing CEMPs. The Site Environmental Manager will:

Oversee the implementation of the CEMP and ensure that each Subcontractor is
made aware of, and compliant with, its requirements.

Carry out environmental meetings to ensure that environmental awareness is

promoted throughout the workforce, including the use of posters and other means
as appropriate.

Conduct environmental reviews, regular audits and monitoring.

Report any CEMP non-compliances to the Project Manager.

Report any significant adverse environmental incident, and submit an appropriate

incident report form to the Project Manager.

Be responsible for communication with the EAD-approved third party auditor

regarding environmental reporting.

5.12.2.4.

Subcontractors

It is the responsibility of those Subcontractors whose activities have at least one interface
with identified key environmental aspects to be fully knowledgeable of the environmental
management requirements and project environmental requirements.
Subcontractors directly in charge of activities such as waste transportation and disposal
will be registered and approved by EAD. Registration documentation must be provided to
Al Ghaith prior to commencement of any activities.
Subcontractors are expected to demonstrate a proactive behaviour towards
environmental concerns. It is their responsibility to provide information requested by
either the Al Ghaith or the EPC Consortium (during construction) with regard their scope
of activities and to demonstrate compliance with the applicable environmental
requirements.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 181

Subcontractors will provide a method statement to the Al Ghaith or to the EPC

Consortium to specify how the requirements of the CEMP and OEMP, respectively, will be
met.

5.12.3. Training and Competence

Training of relevant personnel (including Subcontractors and, where necessary, visitors)
in procedures required to ensure the effective implementation of environmental
management will be undertaken in a systematic and timely manner.
Through various training programs, staff will be made aware of their specific
responsibilities and required actions. Attendance at training sessions will be mandatory
for nominated personnel. Training sessions will be documented and details of topics and
participants provided in the monthly Internal Environmental Audit reports completed by
the Site Environmental Manager during construction and the Environmental Manager
during operations. Training required shall be determined within the CEMP/OEMP,
through it is envisaged the following will be considered:

Orientation sessions to be undertaken on an as-needs basis.

Specific on-going and refresher topic-based training sessions, undertaken on an

as-needs basis, covering areas such as:

Spill response;

Emergency response;

Environmental incident reporting; and

Waste handling.

Tool box talks, undertaken on a continuous basis.

It is expected that the majority of training sessions will be organised by the EPC
Consortium during the construction phase due to the high number of workers on site and
conducted internally, by the Site Environmental Manager or a nominated third party.

5.12.4. Communication
Communication required for effective environmental management of the Al Ghaith Project
shall be determined within the CEMP/OEMP, through it is envisaged the following will be
considered:
5.12.4.1.

Meetings

Regular environmental meetings should be held and will include CEMP/OEMP

implementation as an agenda item. Any environmental incident reports will be discussed
in the environmental meetings. Regular HSE talks will be held on site for all relevant
staff.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 182

5.12.4.2.

Construction Signage

The following information should be posted to notice boards at the main construction site
office:

Specific individuals and their HSE responsibilities.

Audit timing and summary of findings.

Locations of HSE procedures.

Description of any incidents and the responses.

Signs (as well as cones and high visibility warning tape) should be used around any open
trench excavations, No smoking / No open fire signs should be displayed in areas of high
fire risk, and Emergency Response Charts displayed in prominent locations.
The Site Environmental Manager will also post prepared Environmental Emergency
Response Charts, detailing procedures, at prominent locations (for example, at the site
office, in the canteen, at notice boards, etc.). The Emergency Response Charts should
be produced in languages such that it can be understood by all personnel (e.g. Arabic,
English, Hindi and Urdu).
5.12.4.3.

Operational Communication

Environmental management procedures and contact details of relevant staff should be

provided within the operations Induction Manual to all staff working in site. Environmental
memos and bulletins to be circulated or pinned to staff boards throughout the operational
phase to deliver key environmental messages, to communicate plant environmental
statistics, and to encourage staff to become familiar with environmental concerns
The Environmental Manager will also post prepared Environmental Emergency Response
Charts, detailing procedures, at prominent locations (for example, at the site office, in the
canteen, at notice boards, etc.). The Emergency Response Charts should be produced in
languages such that it can be understood by all personnel (e.g. Arabic, English, Hindi and
Urdu).

5.12.5. Monitoring and Reporting

The objective of the monitoring programme is to establish that mitigation measures as
stated in this EIA are applied as controls during the construction and operational periods
and that these controls are effective. All monitoring will be the responsibility of the Site
Environmental Manager during construction and the Environmental Manager during
operations. Monitoring results shall be reported to the Site Project Manager during
construction and Operations Manager during operations, and also through the Internal
Audit process to Al Ghaith. All monitoring results will be submitted Al Ghaith on a monthly
basis, though temperature, salinity and turbidity results should be submitted immediately.
Any perceptible changes should be reported to Al Ghaith immediately.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 183

5.12.6. Audit and Inspection

5.12.6.1.

Internal Audits

During construction, the Site Environmental Manager should arrange regular inspections
and monthly internal environmental audits to:

Provide a summary of the Projects status with respect to construction works and
the environment;

Confirm that the CEMP is being actively implemented;

Achieve efficient monitoring of the Projects environmental status; and

Allow for continuous improvement of environmental performance.

An Environmental Inspection Checklist should be provided as part of the CEMP and

routinely submitted to Al Ghaith on a monethly basis. This form should been developed
to facilitate the completion of thorough site inspections, as required by the internal
auditing process.
The operations Environmental Manager should also perform regular inspections and
monthly internal environmental audits to:

Provide a summary of the Projects environmental status with respect to ongoing

operations and the environment;

Confirm that the OEMP is being actively implemented;

Achieve efficient monitoring of the Projects environmental status; and

Allow for continuous improvement of environmental performance.

The Site Environmental Manager during conastruction and the Environmental Manager
during operation will ensure the follow-up of corrective actions and recommendations for
formal closeout.
The audit report should include, but not be limited to:

Contact numbers for auditors and QA & Environmental Manager.

Audit date, and auditor details.

For construction phase internal audits, the status of the Project shall be reported
including notification of any schedule changes for the construction programme.

Summary of audit findings / responses.

Field-testing/monitoring and laboratory results (if any).

Non-conformance / corrective actions / recommendations.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 184

Other information (such as reported incidents).

Supporting documents, such as the completed Environmental Inspection Checklist

and any Environmental Incident Reports, Dust Control Sheets, Waste Transfer
Forms etc.

Each Internal Environmental Audit report will be submitted for review to the Site Project
Manager during construction and the Operatons Manger during the operational phase.
5.12.6.2.

External Audits

Al Ghaith is responsible for ensuring regular (quarterly) external HSE audits are carried
out by an EAD-approved third party auditor for both construction and operational phases.
Al Ghaith should usually be informed in advance of any impending audit, which in order
to:

Allow time for necessary documents to be made available;

Ensure Project activities are not adversely affected; and

Enable HSE personnel to be available to answer any questions or conduct any site
inspections.

As part of the external audit all site environmental practices should be reviewed to ensure
compliance with local, national and international requirements.
Findings are required to be reported in a Site Visit Report via Aconex (a project
collaboration, document management software and online project management system)
with a date for the responsible party to respond with the mitigation actions taken. EAD
are also likely to undertake compliance audits on an adhoc basis.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 185

6.

HEALTH AND SAFETY IMAPCT ASSESSMENT

6.1.

Summary
An assessment of the health and safety risks for the construction and operational phases
of the Project was undertaken at the HAZID/ENVID session. The HAZID/ENVID looked in
detail at the construction phase and also highlighted any key issues for the
commissioning and operations phase.
No High Risk Occupational Health Hazards have been identified by the HAZID/ENVID.
All risks were classified as Medium or Low according to the Zonescorp Risk Matrix.
Overall, the facilities and nature of construction of the Chlor-Alkali Plant at the All Ghaith
site will be typical of chlor-alkali plants elsewhere in the UAE, and wider world. No
significant new or unusual hazards have been identified. No new or different occupational
issues are anticipated for the construction of the facility.
The operations at the new facility will involve operation, and maintenance of plant
equipment, these or similar operations are already carried out at within ICAD-1, and in
MIA. No new or different risks or hazards are anticipated during the operational phase.
The existing hazards are already managed by the ESNAAD HSEMS.

6.2.

Overview
The Zonescorp Code of Practice (CoP) on HSEIAs and CoP on Risk Management states
that the HSEIA should demonstrate that all High Occupational Health Risks have been
systematically identified, and suitable action to mitigate these risks and to protect
employees from these risks have been or will be taken in accordance with Zonescorp
Codes of Practice on Environment, Health, and Safety guidance.
A systematic Health and Safety Risk Assessment has been conducted for the Project
construction, commissioning and operations phases as part of this PEHSR and this has
not identified any Extreme or High health and safety risks as defined in the Zonescorp
Codes of Practice on Environment, Health, and Safety guidance.
The following section of the PEHSR therefore focuses on discussing the Moderate and
Low risk hazards identified and how all HSE risk - including that resulting from
Moderate and Low risk hazards - will be managed and controlled via the Al Ghaith /
EPC Contractor project/site/operations specific HSE Management System.
Health and safety risk assessment is a discipline devoted to anticipation, recognition,
evaluation, and control of environmental factors or stresses arising in the workplace,
which may cause sickness and impaired health to workers.
As part of the Preliminary Environment, Health and Safety Review (PEHSR) performed
for the Chlor-Alkali Plant in ICAD-1, the PEHSR describes the health hazards involved
and arising from the activities involved in the construction, pre-commissioning,
commissioning and operations phases of this project.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 186

These activities will expose personnel to a variety of occupational health risks, which may
impact worker health. These are classified as:
Physical e.g.: noise, heat, vibration, UV
Chemical e.g.: exposure to solvents, oils
Biological e.g.: legionella, food poisoning
Ergonomic e.g.: posture, manual handling
This assessment was performed by a multi-disciplined team as part of the HAZID/ENVID.
During construction, the main significant physical occupational health risks will be heat
stress, high exposure to sun and outdoors UV radiation, dust exposure from grit blasting
operations and vehicle movements, and noise from compressed air tools etc. Suitable
controls will be in place for all these hazards including prevention/ minimisation strategies,
controls and awareness / monitoring programmes, procedures and PPE as necessary.
In terms of biological health risks particular attention will be given to fitness to work
assessments of labourers with medicals being required for all workers from abroad.
Only relatively low hazard chemicals will be used during construction and operations.
These are in common use and staff will be suitably trained and familiar with their safe
handling. The solvents and other chemicals proposed to be used in the Chlor-Alkali
process may spill and present potential environmental impacts.
The operating design for the facility incorporates a standard suite of controls to avoid
accidental releases. Moreover, the equipment configuration at the proposed plant will
conform to best practices for modern Chlor-Alkali plants.
In terms of ergonomic health hazards, these are numerous and include a wide range of
activities such as lifting, lowering, pushing, pulling or carrying. These occupational
hazards are relevant to both the construction and operations phases and will be
controlled by appropriate training and work procedures and practices.
Management has a duty of care and must be sensitive to the diversity and individual
requirements of its workforce. Elements that must be considered by management and in
particular by health care personnel include:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 187

 occupation

dietary habits

literacy, education and training

sanitation

culture

hygiene standards

language

public health

religion

endemic conditions

tradition

medical and health beliefs

superstition

alternative and traditional medicine

gender

local law and political climate

family

safety culture (fatalism and education)

The importance of familiarity with cultural norms of the workforce is an important factor in
the successful implementation of health and safety controls, etc.

6.3.

Health and Safety Risk Assessment

Health and safety risk assessment is the primary method for classifying risks to health. It
is a discipline that is devoted to anticipation, recognition, evaluation and control of
environmental factors or stresses arising in, or from, the workplace, which may cause
sickness, impaired health and well being or significant discomfort among workers.
Occupational health is an integral part of the health management system. It is concerned
with the interrelationship between work and health, i.e. the effects of work on health and
the effects of peoples health on their capacity to work.

Figure 6-18 Schematic Representation of the Effects of Work on Health

By identifying health hazards in the workplace and subsequent evaluation of health risks,
OHRA takes existing control measures into account and recommends further preventive
or control actions where appropriate.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 188

Four steps are accepted as being essential in the health and safety risk assessment
process:
1. Hazard identification. Identifying the agent responsible for the health problem and
its adverse effects.
2. Dose/response assessment. Describing the potential health effects of the hazard at
different levels of exposure.
3. Exposure assessment. Estimating the magnitude, duration and frequency of
exposure and the number of people exposed via different routes.
4. Risk characterization. Combining steps 2 and 3 to quantify the risk level in a specific
population.
OHRA is not an exact science; in assessing the implications of exposure to occupational
hazards for human health there are many uncertainties.

6.3.1.

Health and Safety Risk Assessment Objectives

As per the Zonescorp guidelines, the cornerstone of a health and safety risk assessment
is to carry out a Risk Assessment, in which the activities of an operation are reviewed in
order to:
Identify and create an inventory of agents potentially hazardous to health;
Evaluate (assess) the risk to health associated with exposure to these agents
against specified screening criteria;
Decide on the control measures required, if any, to remove or reduce the risk to
health to a level as low as reasonably practicable;
Consider any emergency (recovery) measures needed to mitigate acute and/or
chronic health effects, should control measures fail.
When applied systematically within an organisation, risk assessments can be used as a
management tool to assist in:
The comprehensive identification of work place health hazards for risk and health
impact assessments;
Prioritising the implementation of risk assessments, focusing first on those activities
involving the greatest potential risk to health;
Prioritising the implementation of additional control measures, where necessary, to
minimise the health risk to a level as low as reasonably practicable;
Including risk assessments as an integral component of introducing new, or
changes to existing, plants/processes/activities to ensure health hazards are
adequately controlled before the new/revised operation commences;

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 189

 Educating staff on the health hazards, risks and measures of control appropriate to
their tasks;
Determining appropriate records on staff exposures to health hazards which, when
combined with health surveillance records, can be used to identify health trends and
problem areas for action, to fulfil legal requirements and to safeguard the company
against unforeseen liabilities.

6.3.2.

Legal and Regulatory Compliance

In addition to the Zonescorp requirement that throughout industrial activities the risks to
health are to be identified, it is a legal requirement in the United Arab Emirates (UAE) that
employee health is to be protected. Occupational health matters in the emirate of Abu
Dhabi are regulated by:
UAE Federal Law No 8 of 1980: Regulation of labour relations
UAE Federal Law No 77 of 2005: regarding the handling of hazardous material;
UAE Federal Law No 1 of 2002: regarding the handling of radioactive material;
UAE Federal Law No 3 of 1978: regarding the conservation of petroleum resources
where there are some preventive measures to be followed;
Ministerial Order No. 32 of 1982 regarding the protection of workers;
Ministerial Order No. 467 of 2005 regarding the restriction of outdoor working hours
in summer.
The health and safety risk assessment has been performed in compliance with the
Zonescorp CoP EHS04 and EHS03 as well as local laws. Also international regulations
on occupational health were consulted in order to provide the most accurate and relevant
assessment.

6.3.3.

Scope of Work

The activities involved in the construction, operation and decommissioning phases of the
project will expose employees to a variety of health hazards. These include various
environmental factors or stresses that can be classified as physical, chemical, biological,
ergonomic and psycho-social.
PHYSICAL HAZARDS such as
Noise
Vibration: Whole Body and Hand-Arm vibration
Non-ionizing radiation

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 190

 Thermal work environment

CHEMICAL HAZARDS such as
Irritants
Sensitizers (particularly skin and respiratory)
Alkalis/caustic agents
Potential Carcinogens
Exposure to fumes from welding activities
BIOLOGICAL HAZARDS such as
Bacteria or viral infections that would develop from possibility sub-standard and
close living conditions
Personnel hygiene from a workforce that is most likely originating from developing
countries
Food pathogens, drinking water management
ERGONOMIC HAZARDS such as
Heavy and bulky loads stresses
Machinery ergonomic stresses
Repetitive movements and Upper Limb disorders
Working at height
The risk assessment addresses the life cycle of any operation and takes account of all
employees, contractors and third parties at work. The risk assessment is adequately
performed at an early stage of the project and should be reviewed periodically and
revisited when there is a significant change or as required by local legislation.

6.4.

Methodology
A comprehensive HAZID/ENVID/OHRA study has been undertaken for Phases 1-3 of the
Project. The study was carried out at the Al Ghaith offices in Musaffah, Abu Dhabi, on
10th July, 2011. The study team consisted of representatives from Al Ghaith Industries
and URS.
The output from the study has been used to develop a HER for the Project, which is
contained within this section of the PEHSR. The hazards have been assessed against
the Zonescorp risk matrix to assess their impact in terms of:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 191

 Health and Safety impact on people;

Environmental impact from accidental and planned events;
Impacts on Company assets; and
Impacts on Company reputation.
An analysis of the hazards by risk and project phase is also presented, to provide an
indicative risk profile of the project.
The HER demonstrates that all hazards and effects have been identified, understood, and
are being properly controlled. It demonstrates that the facility is adequately controlled
and that preparations are in place to handle any consequence that could result, if control
is ever lost. The purpose of the HER is to present in a clear and concise form the results
of the analysis made of each hazard or effect present in the facility/project. The HER has
been developed based on the guidelines set out in the Zonescorp CoP EHS03 and
EHS04.
For each entry into the HER the following information has been provided
Phase (i.e. operational);
Hazard description;
Consequence;
Risk Ranking (See section below); and
Safeguards/Controls in place.
Hazards associated with the Decommissioning Phase have not been assessed. Overall,
these are likely to present similar challenges to those associated with construction,
though this will depend on the extent to which adjacent or interconnected facilities are
operational at that time. The decommissioning of these facilities will present similar
challenges and issues to the many other existing facilities of a similar nature in the region.
A more detailed assessment will need to be undertaken as the plant approaches the
decommissioning phase when requirements, methods and expectations may have
changed considerably.

6.4.1. Risk Classifications

Each hazard was measured in terms of the potential impact posed to each impact area
(people, environment, assets, reputation) using the Risk Assessment Matrix (RAM)
(Zonescorp EHS03), shown below in table XX.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 192

Table 6-13 Risk Assessment Matrix

Consequence
Probability
Insignificant (A)

Minor (B)

Moderate (C)

Major (D)

Catastrophic (E)

Rare (1)

A1

B1

C1

D1

E1

Possible (2)

A2

B2

C2

D2

E2

Likely (3)

A3

B3

C3

D3

E3

Often (4)

A4

B4

C4

D4

E4

Frequent (5)

A5

B5

C5

D5

E5

Red
Amber

Yellow
Green
1.
2.
3.

Extreme Risk

Activity or industry should not proceed in current form.

High Risk

Activity or industry should be modified to include remedial planning and

action and be subject to detailed EHS Assessment.

Moderate Risk

Activity or industry can operate subject to management and / or

modification.

Low Risk

No action required, unless escalation of risk is possible.

Risk is the combination of probability (1 to 5) and consequence (A to B).

Probability: Refer to Appendix XX for definitions of probability of occurrence in relation to each impact area.
Consequence: Refer to Appendix XX for definitions of potential EHS impact & potential incident consequence
rating.

The severity was assessed on the basis of the unmitigated hazard and the probability of
occurrence was assigned based on the likelihood of that scale of event occurring given
the safeguards (prevention, control, detection, mitigation) provided.
The impacts addressed in this section are grouped into categories related to the
causative factor, such as physical presence, air emissions, noise, fluid discharges, solid
wastes, and wastewater.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 193

6.4.2. Acceptance Criteria

Acceptance criteria for control, mitigation and recovery measures provided for EHS
hazards have generally been specified according to the method suggested in the
Appendix 1 of Zonescorp CoP EHS03, as reproduced below.
Figure 6-19

6.4.3. Hazards
Accidents and hazard can be defined as an event or process, which presents a threat,
and may lead to severe or catastrophic consequences, to people, assets, the
environment and/or company reputation. Consequences may be immediate or delayed
and may occur outside as well as inside the site. There will generally be a high potential
for escalation.
Examples of hazards and accidents would include, but are not limited to:
Loss of containment of flammable and/or toxic fluids leading to fire, explosion and/or
toxic injury;
Events resulting in structural failure which could lead to further progressive collapse;
Gas leakage;
Well blowouts;
Ships colliding with offshore installations or onshore jetties used for bulk loading
explosive, flammable or toxic substances;
Delivery vehicles colliding with or otherwise affecting industrial facilities;

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 194

 Other external hazards affecting offshore and onshore sites e.g.

accommodation/work barges alongside fixed installations, helicopters and aircraft,
road/marine product tankers.
The consequences of the hazards identified in the HAZID/ENVID/OHRA workshop have
been assigned risk classifications.
During the HAZID/ ENVID study 44 issues were highlighted as posing potential threat to
all or a combination of either people, the environment, company assets or company
reputation.
Table 6-14 Overview of HAZID/ENVID/OHRA Findings

Risk to
Risk to People
Risk to Environment
Risk to Assets
Risk to Reputition

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Extreme
0
0
0
0

Overall Risk Classification

High
Moderate
0
19
0
1
0
6
0
1

Low
25
26
37
43

Project Number 44130065

Page 195

Table XXX. Environmental, Health and Safety Register

Risk Potential

H-01.03

LPGs during
construction

Consequences

Fire/ explosion risk.

Potential
consequences include
equipment damage,
personnel injury and
fatality, damage to
environment and
damage to
reputation.

Fire/ explosion risk.

Equipment damage,
personnel injury/
fatality, damage to
environment,
reputation.

D1

A1

A1

A1

D1

A1

A1

A1

C1

A1

A1

A1

General

H-01.03

Acetylene

Fire/ explosion risk.

Equipment damage,
personnel injury/
fatality, damage to
environment,
reputation.

General

H-05.02

Argon

Canister becomes
projectile due to
uncontrolled release
of gas.

Equipment damage,
personnel injury/
fatality, reputation.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Reputation

H-01.06

Natural gas for

boilers

Threats / Top Event

E1

A1

Assets

General

Sources

Environment

General

HAZid

People

Guideword/
Activity

Risk Controls

B1

Project Number 44130065

Page 196

B1

Prevention Controls

Flame scanners
should be installed.
Gas line inspections
to be carried out
regularly. Additional
preventative
maintenance
procedures to be
carried out
regularly.
Use of LPG during
construction
adheres to Health
and Safety
guidance,
operations
procedures
implemented.
Use of Acetylene
during construction
adheres to Health
and Safety
guidance,
operations
procedures
implemented.
Use of Argon during
construction
adheres to
applicable Health
and Safety
guidance,
operations
procedures
implemented.

Mitigation/Recovery
Controls

Emergency response
team, first aid,
emergency response
procedure

Emergency response
team, first aid,
emergency response
procedure

Emergency response
team, first aid,
emergency response
procedure

Emergency response
team, first aid,
emergency response
procedure

Risk Potential

H-02.03

Lube and seal

oil

Breach of
containment
resulting in spillage
of lube/ seal oil.

Damage to
environment.

A1

A1

A1

A1

Hydraulic oil

Breach of
containment
resulting in spillage
of hydraulic oil.

Damage to
environment.

A1

A1

A1

A1

Diesel fuel

Breach of diesel fuel

containment
resulting in spill and
potential source of
fire.

Equipment damage,
environmental
damage, personnel
injury and/or fatality,
damage to
reputation.

B1

Fire/ explosion risk.

Equipment damage,
personnel injury
and/or fatality,
damage to
reputation.

A1

Personnel injury.

B1

Personnel injury.

D1

General

H-03.05

Hydrogen

General

H-05.03

Water under
pressure

General

H-06.01,2

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Consequences

Reputation

General

H-02.02

Threats / Top Event

Assets

General

H-02.01

Sources

Environment

General

HAZid

People

Guideword/
Activity

Risk Controls

Personnel at
height

Lack of control/
improper use of fire
fighting equipment.
Fall from height.

A1

A1

Prevention Controls

Oil held in
appropriate
containers, regular
equipment
maintenance,
operational
procedures in place.
Oil held in
appropriate
containers, regular
equipment
maintenance,
operational
procedures in place.
Oil held in
appropriate
containers, regular
equipment
maintenance,
operational
procedures in place.
Purging of hydrogen
adheres to Health
and Safety
guidance,
operations
procedures
implemented.

A1

A1

A1

A1

A1

A1

Fire training for ERT

B1

Platforms with
handrails to be used
at all times along
with safety harness,
appropriate training
and hazard

Project Number 44130065

Page 197

Mitigation/Recovery
Controls

Appropriate spill kit

equipment on site.

Appropriate spill kit

equipment on site.

Appropriate spill kit

equipment on site,
emergency response
team, first aid,
emergency response
procedure.
Emergency response
team, first aid,
emergency response
procedure
Trained first aider on
site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.

Risk Potential

Consequences

Reputation

Threats / Top Event

Assets

Sources

Environment

HAZid

People

Guideword/
Activity

Risk Controls

Prevention Controls

Mitigation/Recovery
Controls

awareness provided.

General

H-06.03

Overhead
equipment

Falling load from

height.

Personnel injury and

damage to
equipment.

C1

A1

A1

General

H-08.05

Equipment
with moving/
rotating parts

Fingers or limbs
trapped in rotating
equipment.

Personnel injury.

C1

A1

A1

General

H-08.06

Use of
hazardous
hand tools

Improper use and

electric shock.

Personnel injury.

C1

A1

A1

General

H-08.07

Use of knives,
machetes etc

Careless and
improper use.

Personnel injury.

C1

A1

A1

H-10.03

Engine &
turbine
exhaust
systems

General

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Personnel exposure
to hot exhaust.

Personnel injury.

A1

A1

Project Number 44130065

Page 198

A1

Overhead
equipment
maintained
regularly. No work
carried out
underneath moving
equipment.
Guards installed,
maintenance for
guards kept up to
date, work permit
system applied.
Maintenance of hand
tools, appropriate
training provided,
PPE available
Maintenance, PPE,
safety procedures &
appropriate training
provided.
PPE, access to
exhaust restricted,
appropriate
operational controls
in place, training
provided.

Trained first aider on

site.

Trained first aider on

site.

Trained first aider on

site.
Trained first aider on
site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.

Risk Potential

Open flame via

cutting and
welding
activities

General

Consequences

Reputation

H-14

Threats / Top Event

Assets

Sources

Environment

HAZid

People

Guideword/
Activity

Risk Controls

Prevention Controls

Only to be carried
out be certified
welders, welding
procedures should
be followed at all
times, PPE, work
permit, protection
area
Burner management
systems, operating
procedures,
preventative
maintenance

Misuse/ improper
handling.

Fire, personnel injury.

H-14.02

Direct fired
furnaces

Fire/ explosion risk.

Fire, personnel injury,

damage to
equipment.

D1

D1

C1

General

H-14.03

Flares

Fire/ explosion risk.

Equipment damage,
personnel injury/
fatality, damage to
reputation.

A1

A1

A1

Flame arrester,
elevated dispersion
stack

General

H-15.01

Voltage > 50 600V in cables,

Equipment

Short circuit.

Fire, personnel injury,

fatality.

D1

D1

B1

Design to British
Standards, UAE
design codes

General

H-15.02

Voltage > 50600V in

equipment

Short circuit

Fire, personnel injury,

fatality.

D1

D1

B1

Design to British
Standards, UAE
design codes

General

H-15.03

Voltage > 600V

Short circuit

Fire, personnel injury,

fatality.

D1

D1

B1

Design to British
Standards, UAE
design codes

General

H-15.04

Lightning
discharge

Lighting strike.

Fire, personnel injury,

fatality.

D1

D1

B1

Do not work with

conductor material
during storms.

General

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

C1

B1

Project Number 44130065

Page 199

A1

Mitigation/Recovery
Controls

Trained first aider on

site.

Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Trained first aider on
site.

Risk Potential

B1

No confined space
working situations
present on site.

C1

Small working
volume, PPE,
operational
procedures, training

Fatality.

H-20.06

Chlorine

Uncontrolled release
from process pipes
(10kg max release).

Personnel injury,
fatality.

General

H-21.11

Corrosion
inhibitors

Breach of
containment
resulting in spillage
of corrosion
inhibitors.

Damage to
environment.

A1

A1

A1

A1

General

H-21.12

Scale
inhibitors

Breach of
containment
resulting in spillage
of scale inhibitors.

Damage to
environment.

A1

A1

A1

A1

H-21.17

Used engine
oils

Breach of
containment
resulting in spillage
of used engine oils.

Damage to
environment.

General

H-22.04

Sodium
hypochlorite

Breach of
containment
resulting in spillage
of sodium
hypochlorite.

Minor injury, minor

environmental
impact.

A1

A1

A1

A1

General

H-23.02

Hydrochloric
acid

Breach of
containment
resulting in spillage
of hydrochloric acid.

Damage to
environment,
chemical burns.

C2

A2

A2

A2

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

A1

Prevention Controls

Asphyxiation.

General

D1

Reputation

Consequences

Assets

Threats / Top Event

Excessive N2

General

H-19.04

Sources

Environment

General

HAZid

People

Guideword/
Activity

Risk Controls

D1

A1

A1

A1

A1

Project Number 44130065

Page 200

A1

Corrosion inhibitors
held in appropriate
containment units,
operational
procedures in place.
Scale inhibitors held
in appropriate
containment units,
operational
procedures in place.
Engine oils held in
appropriate
containment units,
operational
procedures in place.
Sodium hypochlorite
held in appropriate
containment units,
operational
procedures in place.
HCl held in
appropriate ,
bunded containment
units, operational
procedures in place.

Mitigation/Recovery
Controls

Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Emergency response
team follow
emergency response
procedure, trained
first aider on site.
Appropriate spill/
splash kit equipment
on site, trained first
aider on site.
Appropriate spill/
splash kit equipment
on site, trained first
aider on site.
Appropriate spill/
splash kit equipment
on site, trained first
aider on site.
Appropriate spill/
splash kit equipment
on site, trained first
aider on site.
Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Risk Potential

Threats / Top Event

Damage to
environment,
chemical burns.

C2

General

H-23.04

Caustic soda

Breach of
containment
resulting in spillage
of caustic soda.

General

H-25.01

Manual
materials
handling

Misuse/ improper
handling.

Personnel injury.

General

H-25.04

Heat stress

Over exposure.

General

H-25.05

High humidity

General

H-30.01

Dangerous
goods in
transport
activities

Primary Brine
Section

Ref

Waste sludge

Secondary
Brine Section

Ref

Filter
backwash

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

A2

A2

A1

A1

A1

Dehydration,
personnel injury.

C2

A2

A2

Over exposure.

Dehydration,
personnel injury.

C2

A2

A2

Breach of
containment
resulting in spillage.

Environmental,
personnel injury.

B2

B2

A2

A2

Environmental
impact.

A1

A1

A1

A1

Environmental
impact.

A1

A1

A1

A1

Breach of
containment
resulting in spillage.
Breach of
containment
resulting in spillage.

A2

Reputation

Sources

Assets

Consequences

Environment

HAZid

People

Guideword/
Activity

Risk Controls

Project Number 44130065

Page 201

Prevention Controls

Caustic soda held in

appropriate bunded
containment units,
operational
procedures in place.
All personnel given
appropriate
training, operational
procedures up to
date.
Appropriate UAE
Health and Safety
laws implemented.
No working outdoor
during hottest part
of day.
Appropriate UAE
Health and Safety
laws implemented.
No working outdoor
during hottest part
of day.
All dangerous goods
in transit held in
appropriate
containment
tankers,
operational safety
procedures in place.
Sludge held in
appropriate
containment units.
Brine held in
appropriate
containment units.

Mitigation/Recovery
Controls

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.
Trained first aider on
site.

Trained first aider on

site.

Trained first aider on

site.

Trained first aider on

site. Appropriate
spill/ splash kits
available.
Appropriate spill/
splash kits available.
Appropriate spill/
splash kits available.

Risk Potential

Risk Controls

HAZid

Sources

Threats / Top Event

Environment

Assets

Reputation

Secondary
Brine Section

Ref

Ion exchange
regeneration
waste

Breach of
containment
resulting in spillage.

Environmental
impact.

A1

A1

A1

A1

Electrolysis of
Salt

Ref

Maintenance
activity

Misuse/ improper
handling.

Personnel injury.

B1

B1

C1

A1

Caustic Conc./
Flaking

H-25.01

Manual
materials
handling

Exposure to caustic,
Spill/ splash

Chemical burns.

C2

A2

A2

Hydrochloric
Acid

H-25.01

Manual
materials
handling

Exposure to HCl pill/

splash

Chemical burns.

C2

A2

A2

Consequences

People

Guideword/
Activity

A2

Maintenance, PPE,
safety procedures &
training

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Over pressure
receiver.

Equipment damage,
personnel injury.

C1

A1

A1

A1

Instrument Air
System

Ref

ER operations

Release of
compressor oil.

Damage to
environment.

A1

B1

A1

A1

Page 202

Trained first aider on

site.

A2

ER operations

Project Number 44130065

Appropriate spill/
splash kits available.

Appropriate spill/
splash kit equipment
on site, trained first
aider on site.

Ref

Al Ghaith Industries

Liquid must be held

in appropriate
containment units.
Maintenance
operator's manuals
followed and
updated regularly.
Appropriate PPE
provided. All
relevant safety
procedures &
training
implemented.

Mitigation/Recovery
Controls

Maintenance, PPE,
safety procedures &
training

Instrument Air
System

PEHSR Chlor-Alkali Plant

Prevention Controls

Safety valve controls

implemented.
Regular
maintenance and
checking of safety
valves.
Safety valve controls
implemented.
Regular
maintenance and
checking of safety
valves.

Trained first aider on

site.

Appropriate spill/
splash kit equipment
on site.

Risk Potential

Threats / Top Event

Reputation

Prevention Controls

Damage to
environment.

A1

A1

A1

A1

Appropriate
procedures for
informing regulator
in place.

Damage to
environment.

A1

A1

A1

A1

pH adjustment prior
to discharge.

Ref

ER operations

Waste water
exceeds
environmental
discharge limits.

Effluent
Neutralization
System

Ref

Neutralization
tank

Off spec discharge.

Al Ghaith Industries

Consequences

Assets

Sources

Waste Water
System

PEHSR Chlor-Alkali Plant

Environment

HAZid

People

Guideword/
Activity

Risk Controls

Project Number 44130065

Page 203

Mitigation/Recovery
Controls

None

Table 6-15 Occupational Health Hazards

Initiating
Events /
Causes

Exposure
Rating

Occupation
al Health
Risk

Site watering
PPE

Medium

National Legislation
Rest area provided with water / hydrolite provided

Medium

Noise emissions

PPE
Piling activities during daytime
Regular maintenance

Medium

Application of
waterproofing

Toxicity
Fire

PPE
Application method statement/procedures

Low

Application of
epoxy coatings

Toxicity

PPE

Low

PPE
Competent Personnel
Chemical handling procedures

Low

Consequence
s / Escalation

Hazard
Rating

Earthworks

Dust Generation

Weather and
environment

High temperatures

Heat Stress

2.7

Noise / Dust / Odour/

Light/ Radiation /
Electromagnetic
emissions

Piling Activities

2.10

Construction methods

4.2

Construction methods

No.

Keyword

2.1

Site preparation /
groundworks

2.3

6.6

Chemical Handling

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Application/use of
lube oils, resins,
paints.

Fumes

Safeguards/ Controls/ PCDM

Project Number 44130065

Page 204

As the hazard effect register above shows, most hazards either present a low risk, or will
be effectively managed by the safeguards and controls provided (Probability A Exposures are negligible, or B - Exposures are controlled and likely to remain so in
accordance with screening and performance criteria).
The exposure rating or one hazard has been assessed as Probability C (Exposures are
currently controlled to meet screening and performance criteria, but control cannot be
assured). This being the hazard of weather and environment. Obviously, the weather is
outside the direct control of the construction team. It is therefore necessary to mitigate
the effects of the weather to ensure that the risk is acceptable. It is considered that the
safeguards proposed meet good practice and are suitable and sufficient to reduce risk to
ALARP.
Table 7-16 Hazards Safeguards Rationale

No.

Hazard

Rationale

Construction Phase
2.3

Weather and Environment

National Legislation prevents working outside during the

hottest part of the day in the summer months.
A rest area is provided with water/hydrolite as required.

A discussion of the occupational health hazards and their management is presented in

the following sections. The health and safety hazards inventory tables given in the
sections below do not show risk ranking as they are generic.

6.5.

Physical Health Hazards

Physical health hazards refer to extraneous physical forces that can have an effect on the
health of the individual. They may be found in a specific work environment (e.g. working
beside a noisy generator or air compressor) or may be associated with equipment used
(e.g. vibration from impact wrench).
The main physical occupational health hazards likely to be involved during the
construction, pre-commissioning and commissioning phases of the Project are depicted
below. These include the potential hazards of: excessive levels of noise, inadequate
lighting, excessive levels of vibration from working with heavy moving equipment or
rotating equipment, exposure to non-ionizing radiation, exposure to thermal extremes,
electricity, and machinery hazards.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 205

6.5.1. Noise
Table 7-17 Health Hazard Inventory Physical Agents Noise

Hazard Title
Location of hazard

Noise
General in all the areas associated with the use of all rotating and moving
equipment, Use of compressed air / electric tools, portable generators etc.

Relevant Corporate
Standards
Excessive exposure to noise over a period of time may result in Noise
Induced Hearing Loss (NIHL). This is a progressive form of deafness
categorised largely by the loss of hearing response at a particular
frequency in the ear (4 KHz). This is clearly shown by a marked dip in
Health Effects of Hazard hearing response at the 4KHz band when audiometry is performed on an
affected individual.
Noise exposure may also result in Tinnitus. This is a constant ringing in
the ears that, in many cases, is highly distressing for the individual
affected.
It is not expected that any of the Construction areas will be subject to high
noise levels from existing plant since these are located away from noisy
plant areas.

Risk Control
Recommendations

Construction noise associated with near ground-level works should be

controlled using standard techniques such as the placement of stockpiled
materials to screen any adjacent noise sensitive areas. Regular equipment
maintenance, the use of silenced equipment where appropriate, together
with local enclosures for particularly noisy activities will help to reduce the
spread of construction noise.
Construction generators and air compressors will have full acoustic
protection (acoustic box).

Main Activities / Tasks

Mechanical Maintenance in plant areas

Electrical Maintenance Activities
Instrument Maintenance Activities
Grit blasting
Power washing and brushing / hydrojetting
Use of powered tools (grinders, needle guns)
Diesel generator

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 206

Crane Operations
Floor cleaning
Workshop activities
Mechanical Technicians
Painting Operatives
Main Personnel Involved
Contractors
Inspection

According to the UK Health and Safety Executive Publications, work-related hearing

damage is one of the most serious and widespread industrial diseases. Construction
industry workers generally suffer significant loss of hearing after more than fifteen years
in the trade.
Occupational exposure to noise can result in fatigue and work-related stress, tinnitus,
hearing damage, and eventual deafness if not managed appropriately. Noise can also
prevent work from being conducted effectively, for example by making communication
difficult or by preventing alarms from being heard.
Temporary threshold shift occurs when hearing is temporarily affected by a short
exposure to high noise levels but returns on stopping the exposure. This may be typical of
exposure such as where a single shift is working at high noise levels with inadequate
controls. The threshold shift can become permanent due to long term damage to the
sensitive hairs in the ear which transmit sound to the auditory nerve.
Typically as stated above this may occur over a period of ten to fifteen years and typically,
due to the human ears response to sound frequencies, has the greatest effect in the
normal human speech range and can severely affect resultant quality of life. Physical
damage to the small bones in the middle ear and permanent damage to the sensitive
hairs in the cochlea can also result from a single high intensity sound impulse.
High levels of background noise when sleeping or carrying out daily activities outside the
workplace can result in stress, poor sleep and other psychological effects.
Construction noise may be controlled through a variety of measures, and application of
these should be based on the Source-Path-Receiver principle. Noise should be controlled
or eliminated at source where possible rather than by the use of PPE as a first resort. In
fact PPE should be used as a last resort where other measures are not sufficient or are
impracticable.

Control at Source

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 207

 Purchasing equipment with reduced noise specifications and noise attenuation

devices (e.g. low noise electric motors)
Use of baffles, silencers or acoustic enclosures on equipment
Profiling and stiffening of panels on equipment to prevent vibration and noise
conduction
Maintenance of equipment to prevent deterioration of controls designed to ensure
noise levels do not increase
Avoid parallel scheduling for noisy tasks
Minimization of drop heights for waste soils and other loads
Control of Noise Path
Construction of temporary screens or bunds, using waste soils, stock piled
materials or acoustic fencing, interrupts the path between the source and receiver
Provision of local enclosures around noisy working areas prevents the noise from
affecting those outside the area and is appropriate for static areas such as the ones
involved in the current work areas
Pointing vehicle exhausts away from noise receivers
As a general principle, impulsive methods such as impact piling should be avoided,
especially when in close proximity to services corridors or other vibration sensitive
receivers. When piling is required, bored or cast-in-situ methods should be
favoured.
Control of Noise at the Receiver
Use of PPE: Appropriate PPE should be used to supplement other noise
management measures on the construction site. The use of hearing protection is
mandatory in hearing protection zones. These zones are areas where an
individual would be exposed to a noise level greater than 85dB(A) LEP,d or the
peak action level. These zones must be clearly identified and marked with signs or
communicated to the workforce by suitable means
Work Rotation will reduce the overall daily noise dose experienced by an individual
and can be used to manage the overall LEP,d experienced by the workforce
involved in the noisy task of the work.
The time-weighed average dBLA eq level (or noise dosage) to which employees are
exposed depends upon the various noise levels and times spent at each noise
level. The 8-hour limit for unprotected hearing is set at no more than 85 dBLAeq, 8h,
although there are international pressures to reduce this limit to 80 dBLAeq, 8h.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 208

6.5.2. Lighting
Adequate natural or artificial lighting must be provided particularly in workshops and work
areas as well as in surrounding service areas.
Table 7-18 Occupational Health Hazard Inventory Physical Agents Lighting

Hazard Title

Lighting

Location of hazard

Offices areas, workshops, kitchens, storage areas

Relevant Corporate
Standards
Health Effects of Hazard
Risk Control
Recommendations

Eye strain, arc eye and cataracts

Comply with ADNOC recommended illumination levels depicted inTable 7
-19
Mechanical Maintenance in plant areas
Electrical Maintenance Activities

Main Activities / Tasks

Instrument Maintenance Activities
Office and workshop activities
Mechanical Technicians
Instrument Technicians
Main Personnel Involved
Electrical Technicians
Cooks and catering personnel

Lighting is often overlooked as an occupational health hazard and a hazardous situation.

The following conditions can severely impact sight or contribute to pain and discomfort.
Glare from computers and reflecting surfaces is often associated with eye strain and
subsequent discomfort and pain leading to fatigue and headaches. Poor lighting
conditions are very often observed in workshop areas and are rarely mitigated.
For the construction phase, most work will be outdoors. Suitable lighting will be provided
in all offices and work areas.
Table 7-19 ADNOC Recommended Illumination Levels

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 209

Area / Location

Illumination
(Lux)*

Area / Location

Illumination (Lux)*

Ablution Block

200

Office Area

500

Bakery

300

Recreation Room

300

Clinic

500

Room Desk Surface

300

Dining Room

300

Sleeping Rooms

150

Dormitory Living Room

200

Stairways (Interior)

150

Exterior Area (Compound)

50

Storage Areas

200

Galley

500

Toilets

200

Hallways

150

Walk In Freezers

100

Kitchens

500

Walkway (Exterior)

50

Laundry Room

250

Workshops

300

*Measurement taken 1.2 meters above floor

6.5.3. Vibration
Table 7-20 Occupational Health Hazard Inventory Physical Agents Hand- arm Vibration/Whole Body
Vibration

Hazard Title
Location of hazard

Relevant Corporate
Standards

Health Effects of
Hazard

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Hand-Arm Vibration (HAV) / Whole Body Vibration (WBV)

Use of hand-tools such as grinders, needle-guns and electrical drills,
jackhammers, compactor, drilling machine/lathe.
ADNOC-CoP-V3-01 ADNOC Manual of Codes of Practice Framework of
Occupational Health Risk Management and Underlying Codes of practice.
ADNOC CoP-V3-05 ADNOC Manual of Codes of Practice Physical
Agents.
Excessive exposure to hand-arm vibration over a period of time may result
in Hand-arm Vibration Syndrome (HAVS). This is a condition that affects
both the nervous system and the blood vessels of the hand particularly the

Project Number 44130065

Page 210

Hazard Title

Hand-Arm Vibration (HAV) / Whole Body Vibration (WBV)

fingers. Symptoms of this condition include pain, numbness, temperature
sensitivity (particularly to cold) and blanching of the fingers (also known as
Vibration White Finger). In addition to the pain inflicted by this condition, it
can seriously affect the quality of life for the person suffering from it.
Activities such as gardening, DIY or playing golf can be seriously restricted
particularly in cold weather.
Work using vibrating hand tools can also result in injuries to tendons and
ligaments of the hand and wrist.

Risk Control
Recommendations

Mapping of HAV /WBV sources. According to the ADNOC Codes of

Practice, where whole body vibration exceeds 0.5 m/s 2 per day (or 1.25 m/s2
1-hour average) control measures should be put in place, with vibration
exposure assessments and health surveillance of exposed workers. Above
0.7 m/s2, job rotation should be used to reduce exposure time. Where hand
arm vibration exceeds 2.5 m/s2 per day similar monitoring and control
measures must be implemented. Equipment rated as 10 m/s 2 for short
periods, and 20 m/s2 as a daily average must be marked and exposure time
reduced severely.
Use of power tools (grinders and needle guns)
Use of compactor

Activities / Tasks
Cutting
Drilling machine/lathe operations
Grinders and needle gunners
Personnel Involved
Mechanical Technicians (grinders).

The construction of the facilities will involve the use of percussive equipment (such as
jack hammers), hand-held power tools, powered equipment such as pneumatic drills and
air lances and non-powered work equipment such as hammer and bolster. This
equipment can cause hand arm vibration syndrome (HAVS). This is a painful condition
which represents a range of potentially permanent injuries affecting the circulation,
nerves, bones, and muscles in the hands and arms. It gives rise to the effect known as
vibration white finger (VWF). This aspect can be controlled by the adoption of hand arm
vibration exposure limits (ISO 53491).
Construction activities will also involve the deployment of earth-moving equipment,
dumper trucks, etc which can subject an operator to whole body vibration (WBV). This
1

ISO 5349-1:2001 - Mechanical vibration - Measurement and evaluation of human exposure to hand-transmitted vibration -Part 1: General requirements. ISO 5349-2:2001 - Mechanical vibration - Measurement and evaluation of human exposure to
hand-transmitted vibration -- Part 2: Practical guidance for measurement at the workplace.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 211

can cause lower back pain and spinal damage. This aspect can be controlled by the
adoption of the WBV limits given in ISO 2631 2. Practical control measures would include
responding to worker complaints and symptoms (e.g. of bad back), minimising exposure
periods by rotating work activities, and improved vehicle seating.
WBV can cause serious musculoskeletal disorders affecting the spine and is associated
with back pain. Other work factors such as posture and heavy lifting activities are also
known to contribute to back problems. Whole body vibration symptoms range from a
general feeling of discomfort and motion sickness to lower jaw symptoms, chest and
abdominal pains, urge to urinate and influence on breathing movements.
Engineering Controls
Examining alternative methods of working that do not require use of high vibration
tools
Purchasing equipment with improved axle and/or cab suspension for heavy
machinery.
Fitting anti-vibration mounts where possible
Routing of the exhaust of hand held engine powered equipment through the
handles reduces the effect of vibration in cold climates, but is not expected to be of
significant benefit in this climate
Management Practices
Means to reduce hand-arm vibration include:

Reducing exposure time of machinery operators though work breaks and job
rotation and allocation

Ensuring the right tool is used for the right job under adequate supervision

Advising workers on exercises for their fingers to improve blood flow

Labelling all equipment and tools (new tools if acceleration exceeds 2.5 m/s 2 as
required by CoP V3-05)

Ensuring the use of anti vibration or low vibration tools, hand tools, grips and
gloves

Constructing jigs to hold materials or tools

ISO 2631-1:1997 - Mechanical vibration and shock - Evaluation of human exposure to whole-body vibration -- Part 1: General
requirements.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 212

Designing the job so that poor posture (which may cause strain on hands and
arms) is avoided

Maintaining tools to the manufacturers specifications to avoid worsening

vibration e.g.:

Replace vibration mounts before they are worn out;

Ensure rotating parts are checked for balance and replaced if necessary;

Keep tools sharp.

Taking advice from the equipment manufacturer on safe use of the

equipment

Providing tool support to take the weight of the tool (e.g. tensioners or
balancers),so:
o

Allowing the operator to reduce grip and feed force;

Letting the tool do the work;

Medical Surveillance Programmes, Employee Awareness

Employee self-checks: For example, tingling of the fingers lasting more than 20 minutes
after using vibrating equipment, waking at night with pain, tingling, or numbness in hand
or wrist, numb fingers, blanching of the fingers i.e. turning visibly white from the tips with a
clear margin.
Before using vibrating tools, medical screening and on-going medical checks should be
undertaken.

6.5.4. Non Ionising Radiation

Non-ionizing electromagnetic radiation (NIEMR) includes optical radiation (UV, visible and
infrared) and longer wavelength electromagnetic fields (such as those associated with
electrical power, mobile telecommunications, microwaves and radio). A range of industrial
processes generate NIEMR, but the more commonly known sources and the ones of
relevance to the project include the sun, electrical equipment (photocopiers, welding
equipment, television, microwaves, and visual display units), telecommunications and
electricity supply.
ADNOC does not currently publish limits for exposure to NIEMR. In its absence, guidance
from international sources was sought and is presented in the following summary tables.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 213

Table 6-21 Occupational Health Effects of Non-ionizing Electromagnetic Radiation

NIEMR

Source

Occupational Health Effects

Welders flash or arc eye: inflammation of superficial

membranes of the cornea and the eyelids (sunburn of
Arc welding
the eyes) caused by sunlight or intense reflection from
sand or the sea Cataracts: clouding of the eye lens:
UV sources in
Sunburn, with blistering and swelling if severe, skin
photocopiers and
spots, which can turn into cancers such as basal cell
laser printers.
carcinomas, the most common type of skin cancer, and
melanomas, the most dangerous form of skin cancer,
Lasers.
which can be fatal if not detected and treated in the early
Welding.
stages
The sun

Ultraviolet (UV)

The sun
Spotlights
Visible light

Arc welding
Laser devices
such as laser

Visible light is not normally a problem, but where intense

(e.g. in lasers) can potentially cause damage to the
cornea and retina of the eye. It can also cause cataracts

levels

Very Low
Frequency (VLF)
and Extra Low
Frequency (ELF)

Power lines &

cables, wiring,
electric
equipment

VLF and ELF have been linked to potentially increased

likelihood of a number of cancers, including leukaemia
(such as motors)
and brain tumours
Electronic
equipment (e.g.
computers,
televisions)

Infrared (IR)

The sun

Burns to the eye, including the retina, Cataracts

Flares

Heat stress, including heat stroke

Hot surfaces
Lasers.

Skin burns

Molten glass.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 214

NIEMR

Source

Occupational Health Effects

Infrared lamps.

Radiofrequency fields can have thermal and non-thermal

effects
Thermal effects

Mobile
communications
Radiofrequency
Fields

(phones, CB
radios, walkie
talkies)

Exposure to radiofrequencies can cause a rise in body

temperature. An increase of more than 6C can lead to
death. Lower increases can cause heat stroke, brain
damage, infertility in men and birth defects. Other
possible thermal effects are cataracts and localised burns
Non-thermal effects

Dielectric heaters The non-thermal effects can include headaches,

eyestrain, fatigue, loss of appetite, sleep disturbance, and
Induction heaters interference with pacemakers and other medical implants.
Radiofrequency fields may also cause changes in cells.
Radiofrequencies lower than 100 MHz can charge metal
and poorly grounded objects. The potential effects include
sparking on metal structures, activation of electrical
devices and ignition of flammable substances

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 215

Table 7-22 Health Hazard Inventory Physical Agents Non-Ionising Radiation Ultraviolet light

Hazard Title

Non-ionising radiation Ultraviolet Light

Welding operations have the potential to cause arc-eye an acute
condition caused by exposure to UV light generated from the welding arc.

Location of hazard

Relevant Corporate
Standards

During outdoor activities personnel are exposed to high levels of UV light

from the sun, this is particularly of importance in the UAE where there is an
average of 357 sunny days per year.
ADNOC-CoP-V3-01 ADNOC Manual of Codes of Practice Framework
of Occupational Health Risk Management and Underlying Codes of
practice.
ADNOC CoP-V3-05 ADNOC Manual of Codes of Practice Physical
Agents.

Health Effects of Hazard Welding operations / gas cutting arc-eye. This is a painful, acute condition
caused by the exposure of the cornea to the intensive UV light derived from
the electric arc that is used during welding procedures. When unprotected
eyes are exposed to strong ultraviolet rays, such as an electrical arc, they
will become inflamed and sore and exposure can result in a temporary loss
of sight
Using evidence systematically collected from the scientific literature, nine
adverse health outcomes have been identified that are clearly caused by
UV exposure. The nine diseases assessed were:
Cutaneous malignant melanoma (CMM): Melanoma of the skin is a
malignant cancer of great severity. Although treatment is improving,
melanoma still carries a significant risk of death. Between 50% and 90% of
the burden of disease from melanoma is due to UV exposure.
Squamous cell carcinoma of the skin (SCC): This is another type of
malignant skin cancer which generally progresses less rapidly than
melanoma and is less likely to cause death or ongoing disability. Of the
total SCC disease burden, 50-70% is attributable to UV exposure.
Basal cell carcinoma of the skin (BCC): This skin cancer appears
predominantly in older people and grows slowly by local spread. The
incidence and mortality of BCC were estimated to be 50-90% attributable to
UV exposure.
Squamous cell carcinoma of the cornea or conjunctiva (SCCC): This is a
rare tumour of the surface of the eye. Some 50-70% of the disease burden
due to SCCC is attributable to UV exposure.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 216

Hazard Title

Non-ionising radiation Ultraviolet Light

The following conditions are also the consequence of excess UV, but there
is considerable uncertainty about the overall burden of disease estimates,
since few data are available on incidence and/or UV-attributable fraction:
Photoageing: Chronic sun damage is associated with the development of
skin conditions called solar keratoses. On rare occasions, these are premalignant conditions. The burden of disease due to solar keratoses is
100% attributable to UV exposure.
Sunburn: Sunburns may be severe and blistering, and the resulting disease
burden is 100% attributable to UV exposure.
Cortical cataract: Cataract is an eye disease where the lens becomes
increasingly opaque, resulting in impaired vision and eventual blindness.
Long term sun exposure to the eye increases the risk of developing a
specific cataract type called cortical cataract. Five percent of all cataractrelated disease burden is directly attributable to UV exposure.
Pterygium: This is a wing-shaped fleshy growth on the surface of the eye.
40-70% of the disease burden is attributable to UV exposure.
Reactivation of herpes of the lip (RHL): Excessive UV exposure causes
immunosuppression and reactivation of the herpes simplex virus (cold
sores). 25-50% of the disease burden is attributable to UV exposure.
Personnel wear coveralls and hard hats
Mitigation from eye-damage UV protective safety goggles
Welders shield

Risk Control
Recommendations

Burners goggles
Labourers wear protective clothing during daily work
Protective shelters. Suitable protective clothing and administrative controls,
including job rotation and rest breaks, should be provided where
engineering controls are unavailable or ineffective to reduce exposure
levels.
Welding.

Activities / Tasks
Work outside during summer.
Maintenance Technicians
Personnel Involved

Operators
Labourers

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 217

The UV region covers the wavelength range 100-400 nm and is divided into three bands:

UVA (315-400 nm)

UVB (280-315 nm)

UVC (100-280 nm).

Worldwide some 12 to 15 million people become blind from cataracts annually, of which
up to 20% may be caused or enhanced by sun exposure according to WHO estimates.
Furthermore, a growing body of evidence suggests that environmental levels of UV
radiation may suppress cell-mediated immunity and thereby enhance the risk of infectious
diseases and limit the efficacy of vaccinations. UAE is located close to the equator and
hence, people are exposed to the very high levels of UV radiation that occur in these
regions.
It is a popular misconception that only fair skinned people need to be concerned about
overexposure to the sun. Although darker skin has more protective melanin pigment and
the incidence of skin cancer is lower in dark skinned people, skin cancers do occur within
this group and unfortunately they are often detected at a later, more dangerous stage.
The risk of UV radiation-related health effects on the eye and immune system is
independent of skin type.
UV reaching the earths surface is largely composed of long-wavelength UVA with a small
amount of the shorter wavelength UVB. Most UVB and the very short wavelength UVC is
filtered out by the atmosphere. UV radiation levels are influenced by:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Sun elevation: the higher the sun in the sky, the higher the UV level, with an
increase in UVB relative to UVA. Thus UV levels vary with time of day and time of
year.

Latitude: the closer to equatorial regions, the higher the UV levels.

Cloud cover: UV levels are highest under cloudless skies. However, even with
cloud cover, UV levels can be high due to scattering within the atmosphere.

Altitude: at higher altitudes, the atmosphere is thinner and the air mass is
decreased; less UV is absorbed.

Ozone: ozone present in the atmosphere absorbs some of the UV that would
otherwise reach the earths surface. Ozone depletion leads to increased UVB
levels with little impact on UVA levels.

Ground reflection: grass, soil and water reflect less than 10% of UV; fresh snow
reflects as much as 80%; dry beach sand about 15% and sea foam about 25%.

Project Number 44130065

Page 218

UV can neither be seen nor felt. Therefore UV measurements are necessary to determine
precisely the extent of ground level (ambient) UV. UV measurements such as the global
solar UV index add up all the solar UV, taking account of its ability to cause skin damage.
If measurements are not available, an approximation of ambient UV levels can be based
on geographic latitude.
For individuals, the UV exposure additionally depends on factors such as behaviour and
use of sun protectants, e.g., clothing, hats, sunscreen and sunglasses, during outdoor
(including occupational) activities. A persons skin type is also important. Fair skinned
people suffer from sunburn much more readily than dark-skinned people.
Prevention of UV overexposure:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Limit time in the midday sun: The suns UV rays are the strongest between 10
a.m. and 2 p.m ( = 2 hours each side of the solar noon). To the extent possible,
limit exposure to the sun during these hours.

Use shade wisely: Seeking shade when UV rays are the most intense is
recommended, however, shade structures such as trees, umbrellas or canopies
do not offer complete sun protection.

Wear protective clothing: A hat with a wide brim offers good sun protection for
eyes, ears, face, and the back of your neck. Sunglasses, with adequate side
protection that provide 99 to 100 percent UV-A and UV-B protection will greatly
reduce eye damage from sun exposure. Tightly woven, loose fitting clothes will
provide additional protection from the sun.

Use sunscreen: Liberal application of a broad-spectrum sunscreen of SPF 15+

and re-application every two hours, or after working outdoors, can help protect
the skin from UV. Sunscreen should be used to protect the skin when exposure is
unavoidable.

It is noted that experience from previous projects in Abu Dhabi that most workers
cover their body and head to prevent sun exposure. A policy of wearing long
sleeves at all times should be in place.

Project Number 44130065

Page 219

6.5.5. Thermal Extremes

Table 7-23 Occupational Health Hazard Inventory Physical Agents Thermal Extremes

Hazard Title
Location of hazard

Thermal Extremes
Heat stress is an issue during manual work outdoors during the construction
phase.
Heat stress: Heat stroke may occur when core body temperature rises
above 40 degrees. Likely to only become an issue where personal are
exposed to high temperatures, combined with a high workload. Can be fatal
if untreated. Other heat-related conditions include:
Heat Syncope heat induced fainting.
Heat Stroke, which occurs when the bodys temperature regulatory
system fails and sweating, becomes inadequate. The victim is mentally
confused, delirious, perhaps in convulsions, or unconscious. Unless the
victim receives quick and appropriate treatment, death can occur

Health Effects of
Hazard

Heat Exhaustion occurs when large quantities of fluids and salts are lost
through copious sweating. The victim may vomit or lose consciousness
Fainting may occur when a worker unaccustomed to hot environments
stands erect and immobile. Vasodilation causes the blood to pool rather
than return to the heart for recirculation
Heat Rash or prickly heat occurs in hot, humid environments where sweat
does not evaporate easily
Transient Heat Fatigue refers to the temporary discomfort and mental or
psychological strain arising from prolonged heat exposure. Heat
acclimatization should reduce the severity of this disorder

Relevant Corporate
Standards

ADNOC-CoP-V3-01 ADNOC Manual of Codes of Practice Framework of

Occupational Health Risk Management and Underlying Codes of practice.
ADNOC CoP-V3-05 ADNOC Manual of Codes of Practice Physical
Agents.

Risk Control
Recommendations

Heat stress workshops or awareness campaign

Activities / Tasks

All outdoors activities

Personnel Involved

Various

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Access to drinking water on site. See below

Project Number 44130065

Page 220

The construction workers on the Project are, potentially at risk of heat stress. Heatinduced disorders range in their severity according to a number of factors including
duration of exposure, individual fitness, ambient temperature, fluid intake and work rate.
Four environmental factors affect the amount of stress a worker faces: temperature,
humidity, radiant heat (sun-shine) and air velocity. Perhaps most important to the level of
Heat stress an individual faces are personal characteristics such as age, weight, fitness,
medical condition and acclimatization to the heat.
Remediation methods are:
Acclimatisation: The human body can adapt over time to heat exposure. As
cardiovascular demand is reduced, the worker will sweat more efficiently and maintain
body temperature more easily. For many workers already adapted to UAE working
conditions this is already the case.
Fluid Replacement Provide workers with large and easily available amounts of water
and recommend drinking regime of one cup every 20 minutes. Provide adequate supplies
of water and other drinking liquids in all working areas.
Engineering Controls Provide air ventilation and local air cooling using fans, air
conditioning where feasible, shielding (carefully placed to avoid loss of air flow and
regularly cleaned to maintain effectiveness). Dead mans switch or other safeguards to
avoid loss of equipment control in the event of fainting.
Worker Monitoring Programmes Personal monitoring is required for all workers
exposed to the risk of heat stress. Training in heat management should include guidance
on measuring workmates heart rate and anticipating signs of heat stress in fellow
workers.
Other Administrative Controls should include reducing the physical demands of the
work where possible (e.g. using mechanical aids to avoid manual handling); providing
recovery areas (e.g. shaded with good air circulation); implementing shift work regimes
(early morning, night work) and intermittent rest periods with water breaks; using relief
workers; pacing workers to a specific job; assigning extra workers; limiting worker
occupancy and providing air conditioning and adequate ventilation for worker (CoPV305).
The EPC Contractor will implement a plan to control Heat Stress risk, by having in place
appropriate preventative measures, recognising the symptoms of heat stress, monitoring
the ambient temperature and having suitable medical aid on hand.
Heat stress occurs when the body cannot dispose of excess heat. When this happens,
the bodys core temperature rises and the heart rate increases. As the body continues to
store heat, the individual begins to lose concentration and has difficulty focusing on a
task; they may become irritable or sick and often lose the desire to drink. The next stage
is most often fainting, and death is possible if the person is not removed from the heat
stress.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 221

6.5.6. Electricity
Table 7-24 Occupational Health Hazard Inventory Physical Agents Electricity

Hazard Title
Location of hazard

Electricity
Electrical supplies, cables

Relevant Corporate
Standards
Spasms, burns, muscle paralysis, or death can result depending on the
amount of the current flowing through the body, the route it takes, and the
Health Effects of Hazard duration of exposure
Injury to persons, even small electric shock can result in loss of balance
and resulting falls, from ladders, scaffold or other work platforms
Risk Control
recommendations

See below

Activities / Tasks

All involving electrical supply

Personnel Involved

The particular groups at risk from electrocution would include electrical and
control system workers and those carrying out general construction works
where this is a possibility of striking cables during excavation

For most people contact with an electrical current will have the following health effects.
Table 7-25 Health Effects of Electricity

Effect
Death from disturbed heart action

Current (mA)

Voltage (V)

1000

Above 230

Can cause serious burns, shock, stopped breathing

Ventricular fibrillation
Paralysis of diaphragm

200 240
50

Above 50

30-40

Above 50

In extreme cases can cause serious burns

Makes hands clamp-on Muscular contraction, burns
Involuntary reflex Current can be felt as a pain
Perception Current can be felt as a tingle

70 or more
15-20

25 or more

20 25

Below 1

15

Health effects could result if:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 222

Individual is in direct contact with the electrical energy

The electricity arcs (jumps) through a gas (such as air) to a person who is
grounded (that would provide an alternative route to the ground for the electricity)

The heat generated by the electric arc causes thermal burns including flash burns
from heat generated by an electric arc

Materials that catch on fire from heating or ignition by electrical currents causing
flame burns. High voltage contact burns can cause severe internal burns while
leaving only very small injuries on the outside of the skin

Muscle contractions, or a startle reaction cause a person to fall from a ladder,

scaffold or aerial bucket

Risk Control recommendations: Control and Mitigation measures against accidental

electrocution include:

Employing only trained competent electrical and control engineers and

technicians. Competence should be tested and verified against a training and
skills matrix.

The use of service plans and cable locating devices will reduce the likelihood of
penetration of high-voltage cables.

Electrical tools, where possible should be run from 110V centre tapped earth
systems. This will limit the potential voltage to which a person can be exposed to
55V. Portable electrical appliances shall be earthed or double insulated and shall
be inspected at least weekly. The Permit to Work System controls the use of
portable electrical equipment.

All electrical tools must be individually identified and registered. This register
should include details of:
o

The type of tool,

The age of the tool

The date and results of the last detailed examination and maintenance

Any remedial action taken at that date

The date of the next required detailed examination.

This register must be kept up to date and used to record the maintenance and
examination history of all electrical tools. All tools must be inspected before use every day
that they are used. Users must be trained to carry out these inspections and be aware of
the pass/fail criteria and means of rectifying the defects.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 223

All portable tools must undergo regular appliance testing. For 110V equipment, in a
construction environment, the recommended interval is every three months. For 240V
tools, the recommended interval is every month.
All electrical installations shall conform to the relevant safety and design standards, and
all machinery and equipment shall be effectively earthed.
In Hazardous areas all electrical apparatus shall be intrinsically safe or explosion proof.
To ensure the safety of personnel working on or in the vicinity of electrical equipment, all
such electrical equipment shall be electrically isolated prior to the work being carried out,
and de-isolated when the work is completed.

6.5.7.

Machinery Hazards

Table 7-26 Occupational Health Hazard Inventory Physical Agents Machinery Hazards

Hazard Title
Location of hazard

Machinery Hazards
For any activity involving close proximity to a potential machinery hazard,
including e.g. rotating machinery, abrasive wheels, hydraulic systems, or
portable power operated tools

Health Effects of Hazard See below

Relevant Corporate
Standards
Risk Control
Recommendations

See below

Activities / Tasks

Using Electrical Power Tools, Rotating Machinery, Abrasive Wheels,

Hydraulic Jacks, Pneumatic Tools

Personnel Involved

Various

All machinery, which has moving parts, shall be considered as hazardous.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 224

A person may be in danger of being injured by coming into contact with machinery, by
being trapped between the machinery and any material or fixed structure, by becoming
entangled with moving parts of the machinery, by being struck by parts of the machinery
or any material ejected from it.
For any activity involving close proximity to a potential machinery hazard, including e.g.
rotating machinery, abrasive wheels, hydraulic systems, or portable power operated tools,
a risk assessment shall be carried out and a specific procedure should be prepared.
Rotating Machinery Machine Guards
Every dangerous part of all machinery shall be securely guarded, as follows:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Guards shall automatically prevent the machine operator coming into contact with
a moving dangerous part of a machine.

All guards, whether fixed or automatic, shall be constantly maintained and kept in
position while the machinery is in service or on standby. All guards shall be of
sound design and of adequate strength, sufficient to withstand the stresses of the
process and environmental conditions.

Guards shall not only provide protection but be so constructed and in such
condition that they do not create any hazard themselves.

Guards shall be systematically maintained by competent persons and defects

shall be repaired immediately.

Fixed guards shall be checked to ensure that they are securely fastened in place
that no access is possible from any point into the trapping area, and no

Project Number 44130065

Page 225

secondary trap has been formed between the guard itself and any moving part of
the machine.

Adjustable guards shall be checked daily to ensure that the adjustable element of
the guard remains firmly in place once positioned.

Abrasive Wheels
All persons handling, or using, grinding machines or abrasive wheels shall be familiar with
the hazards involved. Sufficient heat may be generated by the operation in the form of
sparks, or by friction, to ignite a flammable mixture; heavy hydrocarbons can also be
vaporised by the heat of grinding.
A hot work permit shall be obtained before using grinders, or abrasive cutters, in
hazardous areas, or on equipment, which is not completely free of oil residue.
The permit must state the conditions for carrying out the operation safely.
All persons handling, or using, this equipment, shall ensure that:

Abrasive wheels are maintained properly and only by persons trained in

accordance with the schedule to the regulations.

Every abrasive wheel, in excess of 55 mm diameter, shall be marked with the

maximum permissible speed. Maximum speeds of small wheels shall be stated
on a notice attached to the machine.

The maximum permissible peripheral speed of an abrasive wheel shall never be

exceeded.

The spindle shall not be operated at a speed in excess of the maximum

permissible speed of the wheel.

The maximum working speed of spindles on grinding machines shall be marked

on the spindle.

A guard shall be provided to enclose the wheel to the greatest possible extent,
with the opening as small as possible consistent with the nature of the work.

Do not use grinding machines and abrasive wheels unless you are competent to
do so.

Hydraulic Jacks
The following precautions are to be observed when using hydraulic jacks to raise
equipment:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Jacks are to be inspected before use to ensure that they are in a sound condition
and that the oil in the reservoir reaches the minimum recommended level.

Project Number 44130065

Page 226

Before a jack is operated, care is to be taken to ensure that it has an adequate

lifting capability for the work for which it is to be used and that its foundation is
level and of adequate strength.

Jacks are to be applied only to the recommended or safe jacking points on

equipment.

Equipment under which personnel are required to work are to be properly

supported with chocks, wedges or by other safe means, never by jacks alone.

Jack-operating handles are to be removed, if possible, when not required to be in

position for raising or lowering the jack.

Electrical Power Tools

A permit to work is required before any work is carried out in a hazardous area using
electrically operated tools. The only electrical equipment, which can safely be used in
hazardous areas, is equipment, which has been approved by the appropriate authority.
Portable power tools shall not be used if any defect is suspected or any damage
apparent. Care shall be taken to avoid damage to flexible cables and connectors. Kinking
and the tying of knots in cables can cause serious damage, which may not be apparent
on the outside. Crushing and damage to the outer sheath shall be treated as damage
necessitating repair. Portable electrically powered tools shall not be used in potentially
hazardous or explosive environments. In addition, extreme care shall be taken in working
areas containing oil, water, caustic, corrosive or conductive fluids, particularly with regard
to routing of power leads.
Where applicable, protective guards shall be securely fitted, and correctly adjusted. In
order to minimise the effects of electric shock, the power requirements for portable
equipment, e.g. Hand lamps, should be a maximum of 25 volts.
Electrical power tools shall be double insulated or properly earthed. All plugs, joints,
extension leads etc. shall be checked and be in good condition before using the
equipment. Electric cables are not to be used for hoisting or lowering the equipment. The
cable is to be routed to avoid any hazard that may cause damage to the cable. Should
any fault occur in the equipment it is to be replaced immediately and not used again until
properly repaired.
Portable equipment shall be connected to an electrical supply only through the correct
connectors and preferably via a residual current device. Temporary or locally made
connectors shall not be used. Portable equipment shall be suitable for the hazards in the
area where it is to be used. In use or storage, the connectors to any part of portable
equipment shall not be subjected to undue strain.
Portable electrical equipment shall not be left unattended or stowed in hazardous or
dangerous areas. Portable equipment such as torches, test lamps, inspection lamps, etc.
shall be issued against a signature and the user is responsible for it until its return within
a specified period when its condition shall be checked.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 227

Pneumatic Tools
Operators shall ensure that the air pressure is properly regulated and is no higher than
necessary to undertake the work satisfactorily.
Only hoses and couplings of the recommended size and in good condition shall be used.
Caution: Under no circumstances shall compressed air be directed at any part of a
persons body.
The air supply shall be disconnected from pneumatic tools before changing attachments
or carrying out any adjustment or dismantling. The air hose to the equipment shall be
safely routed to prevent damage due to heat, chemical or machinery means. Tools shall
not be modified or the labels and inscriptions defaced or removed. Pneumatic drills are
designed for use with drilling bits, which can be held by chuck or collet adaptors. These
drills shall not be used for any other purpose without consulting the manufacturer. Drill
bits shall not be larger than the rated capacity of the chuck or collet. Similarly, drill bits
used with collets shall be designed for one specific size or range of collet. The drill bit
shall be inserted as far as possible into the chuck or collet and clamped securely and
centrally (with the air supply isolated). Chuck keys shall always be removed after use.
The work piece shall be sufficiently secure to accept the drilling operation without moving
or turning, particularly when sharp edged sheet material is being worked on. Care shall
be taken to avoid jamming (seizing) of the drill. Thrust shall be applied in the direction of
drilling particularly with angle drills. If a side handle or additional grip handle is used, it
shall be securely fixed.
Seizure or jamming of the drill bit causes a reaction torque, which may be dangerous with
hand held drills. Lubrication and/or a reduction in feed pressure should reduce the
likelihood of the drill bit jamming.

6.5.8. Dust
Construction activities such as abrasive blasting of structures, excavation, earth moving
and digging, masonry, concrete work, demolition, pressurized air blowing, jack
hammering, removing rust or paint, sanding and scaling, hauling, pouring, mixing, or
dumping silica-containing materials generates high levels of respirable dust which often
contains a high crystalline silica content.
Furthermore the project location is in a sandy area that will likely expose employees to
high levels of ambient dust and respirable particles.
Breathing in this dust can lead to the development of respiratory ill health, in particular
scarring of the lung tissue (silicosis) which can result in serious breathing difficulties,
depending on the extent of exposure. Chronic obstructive pulmonary disease including
airways diseases such as asthma, chronic bronchitis, and emphysema is characterized
by airways dysfunction and is often associated with occupational exposure to airborne
respirable particles.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 228

From an occupational health perspective, clay, sand, brick dust and ash are all respiratory
sensitisers. They usually contain silica or silica dust, and are known as Respirable
Crystalline Silica (RCS). Control of Substances Hazardous to Health Regulations 2002
(COSHH) has been amended in 2004 to include the control of the exposure to RCS and
to further protect workers health.
Respiratory sensitisers are substances which when breathed in can trigger an irreversible
allergic reaction in the respiratory system. Once this sensitisation reaction has taken
place, further exposure to the substance, even to the tiniest trace, will produce symptoms.
Sensitisation does not usually take place right away. It generally happens after several
months or even years of breathing in the sensitiser.
In addition to being able to trigger allergic response, occupational exposure to dust
arising from sand or from work-related respiratory symptoms, can typically results in chest
tightness/wheeze, nasal and eye irritation.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 229

Table 7-27 Occupational Health Hazard Inventory Physical Agents Dust

Hazard Title
Location of hazard

Dust
Work areas associated with grinding, cement handling and outdoor areas
exposed to sand dust

Relevant Corporate
Standards
Respiratory tract irritation possibly leading to silicosis or other chronic
Health Effects of Hazard pulmonary impairment. Dust can also irritate eyes and cement can also
irritate the skin.
Use of guards for cutting and grinding, and wetting where applicable. Use
of extract ventilation where available. Use of suitable PPE e.g. dust mask
or face mask

Risk Control
recommendations

Wearing of suitable PPE when handling or working with cement and other
dusty materials. Use of handling operations to minimise dust generation,
including good housekeeping
For sand dust traffic management plans to minimise dust generation in
areas where people maybe working, monitoring of dust conditions and
damping down of dusty areas, wearing of PPE where dust levels area
problem.

Activities / Tasks

Cement working, cutting and grinding, working outdoors in dusty locations,

blasting

Personnel Involved

The particular groups at risk would be those involved in grinding

operations, those mixing or handling cements, and personnel working near
vehicles etc where sand dust may be generated

The major airborne particles identified in the scope of this project are:
Cement Dust
Cement dust is a particularly alkaline and irritant dust, and might therefore be considered
to pose a greater risk of respiratory tract damage than many other poorly soluble dusts
(generically often referred to as low toxicity dusts). International data describes
evidence for an increased risk of chronic bronchitis and impairment of pulmonary function
in cement dust exposed workers, but there is a lack of data on dose-response
relationships. Some studies have been published suggesting that exposure to cement
dust may be a cause of laryngeal and pharyngeal cancer and other evidences reports
that repeated exposure to cement has produced chronic bronchitis and impaired
pulmonary function.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 230

Furthermore, Hexavalent chromium (Cr (VI)) can be present in cement raw materials,
Hexavalent chromium being a highly toxic form of chromium.
Sand
Inhaling Respirable Crystalline Silica (RCS) can lead to silicosis. Silicosis is a serious and
irreversible lung disease that causes permanent disablement and early death, and it is
made worse by smoking.
In order to minimize the amount of RCS and to minimize nuisance to construction
workers, the following recommendations could be applied:

Restrict vehicle speeds

Damp down surface of main critical areas generating high levels of airborne dust

Avoid breathing in dust;

Do the job in the correct way and minimise dust clouds;

Always use the dust suppression and extraction equipment properly;

Keep all equipment clean and working properly;

Keep protective equipment clean, and wear it properly.

Occupational exposure to respirable crystalline silica is a serious but preventable health

hazard.
As an indication, prevention and elimination of silicosis and silica-related disease in the
United States are priorities of the National Institute for Occupational Safety and Health
(NIOSH), the Occupational Safety and Health Administration (OSHA).

6.6.

Chemical Health Hazards

6.6.1. Accidental Release of Chlorine Gas

Accidental chlorine gas release impacts generally associated with Caustic / Chlorine
industrial facilities are unlikely to occur during the operation of the plant based on the
proposed preventive and control measures.
The common causes of chlorine gas release at similar facilities are listed below. These
causes are ranked in the order of severity of the leak and the hazard posed by its
occurrence.
1. Fire;
2. Flexible connection failure;
3. Fusible plug corrosion;

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 231

4. Accidents caused by carelessness and ignorance;

5. Valve packing failure;
6. Gasket failure;
7. Piping failure;
8. Equipment failure;
9. Physical damage of containers in collision accidents;
10. Container failure; and
11. Chlorine pressure gauge failure.
Chorine Gas Health Effects:
The USEPA has determined that chlorine is not a persistent pollutant, in that it photolyzes
rapidly to hydrochloric acid (HCl), a much less toxic substance, following the release.
Chlorine, as a powerful oxidizer, attacks the lungs, causing inflammation (pneumonitis)
and fluid accumulation (pulmonary edema), and is intensely irritating to the eyes.
Prolonged and/or acute exposure may be fatal. Table 6 -28 below summarizes typical
symptoms of exposure to various concentrations of chlorine.
Table 6-28:

Summary of Chlorine Health Effects

Concentration (ppm in air)

Health Effects

1-3 ppm

Mild mucous membrane irritation

5-15 ppm

Upper respiratory tract irritation

30 ppm

Immediate chest pain, vomiting, shortness of breath

(dsypnea) and cough

40-60 ppm

Inflammation of lung tissues (toxic pneumonitis) and

fluid accumulation (pulmonary edema)

430 ppm

Death within 30 minutes

1,000 ppm

Death within a few minutes

Chlorine Exposure Limits

The Emergency Response Planning Guideline Level 2 (ERPG-2) value for chlorine gas is
3 ppm, which is set as end point concentrations for chlorine gas plume during emergency
response.
ERPG-2 is the maximum airborne concentration below which it is believed that nearly all
individuals could be exposed for up to one hour without experiencing or developing
irreversible or other serious health effects or symptoms which could impair an individuals
ability to take protective action.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 232

The American Industrial Hygiene Association (AIHA) publishes ERPG levels for various
chemicals (http://www.aiha.org/Committees/documents/erpglevels.pdf.). If an EPRG-2
value has been published, the Emergency Response Guideline uses this number for
setting the Protective Action Distance (PAD). If an ERPG-2 value has not been
established, the PAD is set at 0.01 x Lethal Concentration (LC) 50.
The other useful exposure limits for chlorine are presented below in Table XXX)
Table 6-29:

Other Useful Exposure Limits for Chlorine

Standard Setting Body

National Institute of
Occupational Safety and
Health (NIOSH)

Description

0.5

Recommended Exposure
Limit (REL)

American Conference of
Governmental Industrial
Hygienist (ACGIH)

0.5

Threshold Limit Value (TLV)

Time Weighted Average
(TWA)

UK Health and Safety

Executive (HSE)

0.5

Long-term exposure limit (8

hour), OEL

USEPA

0.5

Environmental air limit

Occupational Safety and

Health Administration
(OSHA)

1.0

Permissible Exposure Limit

(PEL)

NIOSH

1.0

Short Term Exposure Limit

(STEL)

ACGIH

1.0

STEL

UK HSE

1.0

STEL, OEL

NIOSH

10

Immediately Dangerous to
Life or Health (IDLH)

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Permissible Exposure,
(ppm)

Project Number 44130065

Page 233

6.6.2. Lubricants and Used Oils

Table 7-30 Occupational Health Hazard Inventory Chemical Agents Lubricants and Used Oils

Hazard Title
Location of hazard

Lubricants and Used Oils

Widespread use mechanical equipment.
Use of oils may lead to irritation and contact dermatitis.

Health Effects of Hazard Long-term contact with used oils (which contain polycyclic aromatic
hydrocarbons) may result in increased risk of skin cancer.
Relevant Corporate
Standards
Use Impervious gloves
Risk Control Status

Inspect quality of current gloves

Implement Skin Health Programme or awareness campaign
lubrication activities

Activities / Tasks

Mechanical maintenance activities (general)

Instrument maintenance activities
Mechanical Maintenance Technicians

Personnel Involved

Electrical Technicians
Instrument Technicians

6.6.3. Maintenance Chemicals

Substances in the category of maintenance chemicals, covers substances as diverse as:
adhesives, sealants, WD40 type sprays and degreasing agents. These chemicals are
typically packaged in small cans, tubes or aerosol sprays. They are only used in small
quantities as required by the job.
Table 7-31 Occupational Health Hazard Inventory Chemical Agents Maintenance Chemicals

Hazard Title
Location of hazard

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Maintenance and Inspection Chemicals

Wide-spread use mechanical and electrical equipment.

Project Number 44130065

Page 234

Hazard Title

Maintenance and Inspection Chemicals

Range of toxicity (normally low hazard to irritant/harmful range)

Health Effects of Hazard depending upon the substance used. In actuality, toxic effects are normally
limited by small quantities used and the short duration of use.
Relevant Corporate
Standards
Maintenance chemicals cover such substances as release sprays, silicone
sealants, corrosion protection sprays and greases, degreasing agents and
adhesives.
Risk Control Status
The use of these chemicals is typically of short duration and low quantity.
Personnel are required to wear appropriate PPE during use as directed
by manufacturers data.
Mechanical Maintenance Activities.
Activities / Tasks

Electrical Maintenance Activities.

Instrument Maintenance Activities.
Mechanical Maintenance Technicians.

Personnel Involved

Electrical Technicians.
Instrument Technicians.

6.6.4. Welding Fumes

Table 7-32 Occupational Health Hazard Inventory Chemical Agents Welding Fume

Hazard Title
Location of hazard

Welding Fume
During welding operations

Health Effects of Hazard Welding fumes are irritating by inhalation. Long-term exposure to welding
fumes containing nickel and chromium may give rise to an enhanced risk of
personnel developing cancers of the respiratory tract. Welding fumes can
have acute effects on the respiratory system. For example, welding on
galvanized steel can cause a condition known as Fume Fever, which is
caused by the inhalation of cadmium and zinc particles.
A welding process generates a tremendous amount of heat. A welder may
be exposed to a heat stress situation as a result of the process and it is
essential that a protocol be developed to address the potential for worker
distress.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 235

Hazard Title

Welding Fume
The welding area should always be equipped with a fire blanket and a wellstocked first aid kit.

Relevant Corporate
Standards
Risk Control
Recommendations

See below
Welding activities.

Activities / Tasks
Metal fabrication/reparation activities
Personnel Involved

Worker groups exposed to welding and solder fumes will be predominantly

welders and electricians respectively, both groups being exposed as part of
their routine work. Mechanical Maintenance Technicians.

The potential hazards from solder fumes depend on the flux material (typically tungsten or
silver). Silver solder may contain cadmium, a heavy metal which can cause rapid fatality
(within 20 minutes), zinc fumes can cause metal fume fever, a temporary condition like
flu, but which can have severe effects from high enough exposure. Long-term exposure
can result in siderosis (CoP). Coatings and insulation materials may result in exposure to
other harmful chemical agents (e.g. carbon monoxide from epoxy-coatings).
Arc welding produces fumes of metallic oxides, amorphous silica, silicates and fluorides.
Polyurethane coatings on the welding materials may produce hydro-cyanide,
formaldehydes and isocyanates (Carcinogenic). Chromium, nickel and lead may also be
present. These heavy metals have long-term potentially fatal occupational health effects.
Al Ghaith HSE Management should ensure arc welding follows best management
practice:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Purchasing and selection of materials

Select solder flux without zinc, cadmium, and other toxic chemical agents

Select metals, coatings and fuels without adverse health effects

Ensure manufacturers instructions, MSDSs, and safety procedures are followed

to minimise the hazards of welding gases

Use substitute materials such as water-based cleaners or high flash point

solvents when preparing welding surfaces. Avoid chlorinated hydrocarbon
degreasers. Cover the degreaser baths or containers to avoid solvent exposure

Project Number 44130065

Page 236

Avoid welding on surfaces that are still wet with a degreasing solvent

Avoid welding near degreasing baths

Avoid welding in confined spaces: adequate ventilation in a workplace will

prevent the displacement or enrichment of oxygen and prevent the accumulation
of flammable atmospheres

Use of PPE: Full-face masks, eye protection (for UV radiation and projectiles),
aprons, gloves, etc.

To control or eliminate fire hazards, good housekeeping should be maintained in and

around areas of welding, cutting or grinding.
In the event that the work area is located in a confined space, ventilation and other safety
systems should be provided to ensure the area is safe.
Welding or burning will require assessment and approval via the Permit to Work System
and Hot Work Permit.
Fire prevention equipment should be located in the proximity of the welding and cutting
operating area. An employee trained as a Fire Watch should be present and be ready to
use the extinguisher if needed.
Welding machinery and equipment should be maintained in accordance with
manufacturers specifications and be inspected on a regular basis. Check the cables,
ground clamp, electrode holder, gauges and switches to make sure that all are working
properly before proceeding to weld.
Workmen in charge of the oxygen or fuel-gas supply equipment, including generators,
and oxygen or fuel-gas distribution piping systems shall be instructed and judged
competent by their employers for this important work before being left in charge. Rules
and instructions covering the operation and maintenance of oxygen or fuel-gas supply
equipment including generators, and oxygen or fuel-gas distribution piping systems shall
be readily available.

6.6.5. Paints and Thinners

Table 7-33 Occupational Health Hazard Inventory Chemical Agents Paints and Thinners

Hazard Title

Paints and Thinners

Location of hazard

Various application where required.

Health Effects of
Hazard

Irritant and narcotic (may cause drowsiness, lassitude etc. during the
inhalation of high concentrations). Thinners may be absorbed through the
skin. Long-term use has been implicated in increased risk of damage to the
nervous system.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 237

Uncontrolled use of polyurethane and epoxy-based paints may result in lung

and skin sensitisation respectively.
Relevant Corporate
Standards
Polyurethane / isocyanate paints
Some spray-painting of polyurethanes
Epoxies
Substitution with a safer product
Risk Control Status

Work prohibited in confined spaces, permitted only in well-ventilated

workplaces and upwind from source. All paint handling will be carried out
outdoors to ensure good ventilation.
PPE: Use of a suitable respirator where TLVs or PELs dictate, gloves and
eye protection to avoid skin contact
Training and awareness for employees to minimise the exposure and
recognise signs of intoxication. Induction in first aid and medical emergency
procedures

Activities / Tasks

Painting activities

Personnel Involved

Painters and also nearby employees due to the probable diffusion of

vapours. Exposed worker groups include those engaged in surface
preparation prior to welding, painters and those using and handling sealants
and adhesives.

Paints, primers and thinners can contain organic solvents, epoxy resins, isocyantes and
potentially Hexavalent chromium compounds (primers for anti-corrosive purposes).
Solvents may be used as degreasers and be present in paints, adhesives and sealants.
Exposure to other worker groups would be insignificant in comparison unless working in
confined or poorly ventilated spaces with the identified groups.
Hexavalent chromium (zinc chromate, strontium chromate etc found in anti-corrosion
paints and pigments) can induce occupational health effects such as carcinogenic effects
or chrome ulcers.
Epoxy resins found in paints sealants and coatings can cause skin and respiratory
sensitisation and can also cause dermatitis and asthma.
Table 7-34 Health Effects of main Chemicals found in Paints and Thinners

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 238

Chemical group

Organic solvents

Found in

Paints, thinners, degreasing

agent

Health Effects
Skin, eye and respiratory tract
irritant, causes dermatitis and
asthma. Exposure to extremely
high concentration can result in
fatality
Contributes to negative ozone
depletion

Isocyanates

Paint additive

Respiratory sensitiser,
carcinogenic

Aromatic amines (benzene,

toluene etc)

Paint additive

Carcinogenic (bladder and

kidney)

Lead and lead compounds

Paints ( no longer available) but

might be in use on existing
equipment

Neurological damage and death

6.6.6. Carbon Monoxide

Carbon Monoxide (CO) is a colourless, odourless gas, which bonds strongly to
haemoglobin in the blood, preventing the body from absorbing and transporting oxygen
effectively. The effects of carbon monoxide exposure are related to the level of CO that
has accumulated in the blood. Table 7 -35 shows the physiological effects of exposure to
increasing concentrations of CO.
Carbon monoxide is produced as a result of incomplete combustion of carbon containing
materials and can be produced during welding operations with insufficient ventilation. CO
is also produced as an exhaust product of internal combustion engines.
As CO is a light gas, it will not tend to accumulate in high concentrations in open, well
ventilated areas, but conversely may accumulate in poorly ventilated confined spaces
such as welding booths and inside vessels.
Welding booths should be adequately ventilated.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 239

Table 7-35 Health Effects of Carbon Monoxide

CO
Concentration
(ppm)

Exposure
Time

50

8 hours

25

8 hours

Observed Health Effects

Maximum occupational exposure allowed by OSHA as a permissible
exposure. Maximum occupational exposure allowed by ACGIH as a
threshold limit value (source ACGIH

200

2-3 hours Mild headache, fatigue, nausea and dizziness

400

1-2 hours

800

45 min.

Dizziness, nausea and convulsions. Unconscious within 2 hours.

Death within 2-3 hours

1600

20 min.

Headache, dizziness and nausea. Death within 1 hour

Serious headache other symptoms intensify. Life threatening after 3

hours

The local exhaust ventilation must be maintained and inspected as per the legal
requirements. Users should be trained in its positioning and pre-use checks to ensure
that it has no obvious defects.
In no circumstances should personnel consider enriching the atmosphere inside a
confined space with additional oxygen to counter the effects of CO. This presents
significant hazards itself, specifically a greatly increase fire and explosion risk.

6.7.

Biological Health Hazards

Biological hazards include viruses, bacteria, fungi, protozoa, insects, or other living
organisms that can cause disease in humans. Biological agents are classified into the
following hazard banding groups (CoPV3-04):

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Group 1 unlikely to cause human disease.

Group 2 can cause human disease and may be a hazard to employees; it is

unlikely to spread to the community and there is usually effective prophylaxis or
treatment available.

Group 3 can cause severe human disease and may be a serious hazard to
employees; it may spread to the community, but there is usually effective
prophylaxis or treatment available.

Group 4 causes severe human disease and is a serious hazard to employees;

it is likely to spread to the community and there is usually no effective prophylaxis
or treatment available

Project Number 44130065

Page 240

6.7.1. Bioaerosols
Table 7-36 Occupational Health Hazard Inventory Biological Agents Bioaerosols

Hazard Title
Location of hazard

Bioaerosols
Air conditioning systems at the sanitaries

Bioaerosols Bacteria and viruses are the most likely agents to affect the
workforce, particularly if suspended in liquid droplets and spread though
Health Effects of Hazard
close body contact or the air conditioning systems at the sanitaries and or
washing facilities. Agents include influenza, tuberculosis and Hepatitis A.
Relevant Corporate
Standards
Risk Control
Recommendations

See below

Activities / Tasks
Personnel Involved

Various / potentially all.

Other bioaerosols such as fungi (where fungi spores or mycotoxins blown into the air
during extensive renovation demolishing works) and antigens are unlikely to create a
significant risk to occupational health. Control measures should include:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Moisture control through dehumidification, ventilation and increased temperature

on the building surfaces to prevent condensation

Maintenance of air conditioning systems including drainage pans, coils, cooling

towers, ductwork and humidifiers

Filter checking and replacement to avoid fungal spores and other biological
particles

Keeping drainage pans and the rest of the system clear of sediments which may
provide nutrients or harbourage

Ensuring water treatment programmes disinfect and maintain the system

Design of sanitary hot water provisions to showers etc to minimise the incidence
of dead legs

Maintenance of hot water systems at 55C to prevent the growth of legionella

Monitoring of circulating water systems in air conditioning and sanitary systems to

detect the presence of legionella and to monitor the level of biocides present

Project Number 44130065

Page 241

Promotion of health and hygiene issues and education to the workforce

6.7.2. Legionella
Table 7-37 Occupational Health Hazard Inventory Biological Agents Legionella and Legionnaires
Disease and Sick Building Syndrome

Hazard Title
Location of hazard

Legionella and Legionnaires Disease and Sick Building Syndrome

Freshwater pipe-work, heating and humidification systems.

Growth of legionella pneumophila within susceptible freshwater systems

and their subsequent introduction into the workplace can result in a serious
Health Effects of Hazard respiratory infection (Legionnaires disease). This condition has been
known to be fatal especially in elderly or those with compromised
immune systems.
Relevant Corporate
Standards
Risk Control
Recommendations

Identify any hazardous water systems.

Activities / Tasks

Exposure to water systems containing legionella pneumophila.

Personnel Involved

Various / potentially all.

Legionella and Legionnaires Disease: Legionella is a waterborne bacterial agent,

which may colonise man-made recirculating water systems such as air conditioning
systems and dead legs in sanitary hot water systems at worker camps. It proliferates in
water at 20-45 C. Legionellosis has a fatality rate of approximately 12%.

6.7.3. Sanitation
Sanitation generally refers to the provision of facilities and services for the safe disposal
of human urine and faeces. Inadequate sanitation is a major cause of disease world-wide
and improving sanitation is known to have a significant beneficial impact on health both in
households and across communities (WHO 1993, WHO 1999, ADNOC 2000). The word
sanitation also refers to the maintenance of hygienic conditions, through services such
as garbage collection and wastewater disposal.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 242

Table 7-38 Occupational Health Hazard Inventory Biological Agents Infectious Diseases

Hazard Title
Location of hazard

Infectious Diseases
Personnel Hygiene Facilities and Toilets

Health Effects of Hazard See below

Relevant Corporate
Standards
Risk Control
Recommendations

See below

Activities / Tasks

Personnel hygiene

Personnel Involved

Various / Potentially all.

Personnel hygiene facilities such as wash basins with a supply of soap, hot and cold
water, hygienic means for drying hands, lavatories and changing facilities must be
available to ensure that an appropriate degree of personal hygiene can be maintained
and to avoid contaminating or spreading contamination (OSHA 1998, ADNOC May 2000).
Toilets/lavatories must be located such that they do not open directly into any food
preparation, cooking or eating area. Storage lockers must be provided in changing rooms.
Control of infectious diseases in the workplace should be performed by:

Educating personnel about the principles of infection transmission and stressing

individual responsibility for infection control.

Collaborating with medical authorities in monitoring and investigating potentially

harmful infectious exposures and outbreaks amongst personnel.

Providing care to personnel for work-related illnesses or exposures.

Identifying work-related infection risks and instituting appropriate preventive

measures (CDCP, 1998).

Standard precautions must also be instituted for other infectious diseases of significance
in the workplace (HMSO, 1981). These include, but are not limited to:

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Respiratory diseases including tuberculosis, influenza, pertussis, pneumonia and

the common colds.

Viral disease such as measles, mumps, rubella, chickenpox and epidemic

conjunctivitis.

Project Number 44130065

Page 243

Skin disease such as herpes simplex, impetigo, cellulites, pediculosis, and

scabies.

6.7.4. Ergonomic Health Hazards

Ergonomic hazards cause various health effects through repeated or single trauma.
These may be present in the work environment (e.g. uncomfortable furniture, inadequate
lighting), in the equipment/tool used (e.g. vibration from mechanical tools), or in a specific
activity (e.g. manual handling, awkward positions, heavy load handling, prolonged typing
etc).
Manual handling involves lifting, lowering, carrying, pushing, pulling, handling Hot / Cold
loads and handling rough loads. These can result in back injury, hernia, etc. and other
health ergonomic related health effects (CoPV3-06).
Repetitive movements such as those involved in keyboard work, repeated screwdriver
use, hammer and chisel use, and bricklaying can result in work related upper limb
disorders.
Posture is also important in ergonomic hazards such as prolonged seated work, work
above head height and work at floor level, as these can also result in work related upper
limb disorders, stress, pain and general discomfort.

6.7.5. Confined Space / Trenches

Table 7-39 Occupational Health Hazard Inventory Ergonomic Factors Confined Space / Trenches

Hazard Title
Location of hazard

Confined Space / Trenches

Work in: tanks, pits, unventilated rooms, excavations, vessels

Health Effects of Hazard Asphyxiation, explosion, fumes poisoning, claustrophobia

Relevant Corporate
Standards

Risk Control
recommendations

Design and definition of workplace and confined spaces, ensuring

adequate ventilation/lighting and access/ egress, avoiding other activities
or ensuring isolations so person in confined space not put at extra risk,
electrical safety for power tools. emission monitoring
Recommendation to carry out an awareness raising programme.

Activities / Tasks

Valve removal and maintenance.

Mechanical Maintenance Activities.
Instrumentation Maintenance Activities.
Electrical Maintenance Activities.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 244

Grit-blasting activities.
Production Operators.
Mechanical Maintenance Technicians.
Welding Operations.
Personnel Involved
Electrical Technicians.
Instrument Technicians.
Service Company Crew.

While the principles of confined space entry are generally universal, local regulatory
requirements may impose specific additional responsibilities or may specify standards
that differ from those usually stated elsewhere.
Many incidents occur because victims do not fully understand the threat of airborne
hazards that they cannot see, smell, or feel. Additional incidents occur when untrained
persons enter unknown atmospheres to rescue fallen co-workers. Common causes of
confined space related incidents are:
1. Unsafe Acts and Omissions
a. Failure to test the atmosphere in a confined space before entry.
b. Failure to continuously monitor the atmosphere in a permit-required confined
space.
c.

Failure to lock out hazardous fluids, mechanical equipment, and electrical

power to equipment inside the confined space.

d. Failure to follow approved entry procedures.

e. Failure to pre-plan rescue and retrieval efforts.
f.

Failure to use adequate respirators.

2. Unsafe Conditions
a. Lack of training.
b. Fall hazards.
c.

Oxygen deficient atmosphere.

d. Oxygen enriched atmosphere.

e. Poor or improper lighting

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 245

f.

Flammable atmosphere.

g. Lack of a communication system when entrants are out of sight.

h. Toxic or narcotic atmosphere.
i.

Electrical shock hazards.

j.

Presence of an engulfing or drowning medium.

k.

Entrapping mechanisms.

l.

Grinding, crushing, or mixing mechanisms.

m. Contact with hazardous chemicals.

Excavations can result in: head injuries from falling material, impact from moving
machinery, rupture of high pressure hydraulic hoses, excessive noise, collapse of
excavation walls and piles due to poorly secured soil, heavy rain and nearby poor soil
drainage capacity, heavy traffic nearby, etc. No deep excavations are planned for the
construction phase.

6.7.6. Manual Handling

Table 7-40 Occupational Health Hazard Inventory Ergonomic Factors Manual handling

Hazard Title
Location of hazard

Manual Handling
Widespread various locations

Manual handling can result in a range of different injuries and health

Health Effects of Hazard effects, from muscle pulls, through soft tissue injuries to lower back trauma.
In the case of lower back trauma, this can cause severe lower back pain
and/or sciatica.
Relevant Corporate
Standards
Control at source Forklift use or trolley
Risk Control Status
Recommendation to carry out an awareness raising programme in lifting
Valve removal and maintenance
Mechanical Maintenance Activities
Activities / Tasks

Instrumentation Maintenance Activities

Electrical Maintenance Activities
Grit-blasting activities

Personnel Involved

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Production Operators

Project Number 44130065

Page 246

Mechanical Maintenance Technicians

Welding Operations
Electrical Technicians
Instrument Technicians
Service Company Crew

Manual handling covers a wide range of activities including lifting, lowering, pushing,
pulling or carrying. Manual handling incidents often cause musculoskeletal disorders
(MSDs), i.e. disorders relating to, or involving, the muscles and the skeleton (COPV306). These types of disorders are one of the largest contributors to work-related illness,
e.g. muscular back pain, slipped disk, and fractured arm.

6.7.7. Work-related Upper Limb Disorders

Table 7-41 Occupational Health Hazard Inventory Ergonomic Factors Work-related Upper Limb
Disorders (WRULDs)

Hazard Title
Location of hazard

Work-related Upper Limb Disorders (WRULDs)

Widespread various locations (possibly)

Health Effects of Hazard Work-related soft-tissue injuries of the hand, wrist, elbow and neck.
Relevant Corporate
Standards
Risk Control Status

WRULD risk at the site will mostly come from repetitive movements and
some awkward positions that may cause sprains and strains.

Activities / Tasks

Process Operation Activities (general).

Personnel Involved

All performing manual handling activities

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 247

Many chronically disabling muscular skeletal disorders (like tendonitis, carpal tunnel
syndrome and low-back pain) occur as a result of traumatic injury, repetitive forceful
movements, and awkward postures or over exertion.
Studying the ergonomics of a workers environment may help reduce the risk. Employees
particularly at risk include:

Masons, electricians, welders, structural metal installers and scaffolders for

awkward working positions

Masons, carpenters, and others involved in repetitive motion and carrying heavy
loads

Where feasible, equipment should be selected with ergonomic design

considerations and ensure equipment has adjustable mechanisms (e.g. for handgrip, height, seat position, etc.)

Mechanical equipment should be used where possible, in order to avoid manual

handling

Task risk analysis/assessment should include an element of manual handling risk

assessment where appropriate.

Job allocation and rotation should be used to avoid prolonged work in awkward
positions or repetitive heavy loads

Medical facilities will be available for workers who suffer symptoms of MSDs

Medical surveillance based on reported cases can be used to monitor the

prevalence of MSDs amongst the workforce and as an indicator of potential
problems

6.7.8. Slips and Trips

Table 7-42 Occupational Health Hazard Inventory Ergonomic Factors Slips and Trips

Hazard Title
Location of hazard

Slipping and Tripping Hazards

All areas, wet floors or surfaces

Health Effects of Hazard Injury, broken bone

Relevant Corporate
Standards
Risk Control
Recommendations

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Floors, platforms, ramps, stairs and walkways available for use by workers
shall be maintained in a state of good repair and kept free of slipping and
tripping hazards.

Project Number 44130065

Page 248

Activities / Tasks

All

Personnel Involved

Various

Slips and trips are the most common cause of major injuries at work. They occur in
almost all workplaces, 95% of major slips result in broken bones.
Most slips occur in wet or contaminated conditions. Most trips are due to poor
housekeeping.
Al Masaood need to assess the risks to identify the necessary preventative measures.
These shall include (in no particular order):

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Prevention of contamination.

Management of spillages and cleaning regimes.

Choice of suitable footwear.

Design of workplace and work activities.

Maintenance of plant and the work environment.

Specification of appropriate flooring.

Housekeeping.

Effective training and supervision.

Project Number 44130065

Page 249

7.

PROJECT ALTERNATIVES

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 250

8.

STATEMENT OF COMMITMENTS

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 251

9.

SUMMARY OF FINDINGS
This Preliminary Environment, Health and Safety Review for the Al Ghaith Industries
Caustic / Chlorine Project covers the various environmental, health and safety aspects
and related impacts due to this project. Al Ghaith Industries has used one of the best
available technologies (BAT) for their Project and has taken reasonable measures in its
design philosophy to tie-in to existing facilities and utilities thus helping to eliminate and
mitigate potential impacts on the people, the environment, company assets and company
reputation. The entire plant has been designed on the principle of Best Available
Technology Not Entailing Excessive Cost (BATNEEC) and where residual impacts
remained, BAT was applied.
The selection of membrane cell technology itself for the production of caustic and chlorine
at the plant is considered to be BAT. Reasons for selection of this technology are:

Membrane cell technology does not use toxic chemicals such as mercury and
asbestos; therefore, it is the most environmentally-friendly process in comparison
to other popular technologies (Diaphragm cell and Mercury cell) for the
production of chlorine and caustic; and

Membrane cell technology is the most energy-efficient option, and the power
consumption is only 60 to 65 % when compared to other available technologies.

The following are other BAT options considered by Al Ghaith Industries.

Installation of chlorine absorption unit designed to be able to absorb the full cellroom chlorine production in the event of process upset until the plant can be shut
down;

Use of entire hydrogen gas as fuel in the hydrochloric acid (HCl) synthesis in
order to conserve energy;

Hydrogen gas venting may be required at times of start-up, shutdown and

process upsets from the plant through process safety relief valves to a safe
location in order to maintain the safe operation of the plant. The vent system will
include flame sensors, nitrogen and steam purging;

Installation of Vapor Absorption System in the chilled water unit to avoid use of
ozone-depleting substances;

Installation of low NOx burners with the steam boiler and flaking unit to reduce
NOx emissions; and

Recycling of water, wherever possible, utilizing Reverse Osmosis (RO) Unit.

There were no potential impacts found to be of extreme to high risk as per Zonescorp
CoP EHS04.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 252

From the information gathered from the baseline studies, and after review of the potential
impacts and proposed mitigation and monitoring requirements set forth in this PEHSR, it
is believed that potential project impacts have been adequately identified and addressed
through the effective use of mitigation and control measures, and/or monitoring
requirements.
The proposed expansion being located within ICAD-1 is also an advantage and helps
lower environmental impact due to the use of existing infrastructure and resources and
the synergies that can be optimally used at various stages of the project. The location for
proposed plant was selected in ICAD-1 based on the following reasons.

The existence of Musaffah Industrical City as a well-organized industrial city;

Availability of continuous power supply; and

No adequate caustic / chlorine production facilities in Abu Dhabi region in general

to meet the growing demand for the HCl, caustic soda and sodium hypochlorite
chemicals.

Taking into consideration the information documented in this PEHSR, it can be stated that
the Al Ghaith Industries Caustic / Chlorine project can avoid environmental, health and
safety concerns during its construction and operation phase by implementing the
mitigation, control and monitoring measures provided.

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 253

Appendix A -

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 1

PEHSR Chlor-Alkali Plant

Al Ghaith Industries

Project Number 44130065

Page 2