Propane Dehydrogenation and Polypropylene Plant ESIA VOLUME II_MAIN ASSESSMENT_RE… · 336144 TRD EFR 2 D ESIA Volume II October 2014 Propane Dehydrogenation and Polypropylene Plant

Propane Dehydrogenation and Polypropylene Plant

ESIA

Volume II - Main Assessment

October 2014

CB&I

336144 TRD EFR 2 D

ESIA Volume II

October 2014

Propane Dehydrogenation and Polypropylene Plant ESIA


Propane Dehydrogenation and Polypropylene Plant ESIA


October 2014

CB&I

Mott MacDonald, Victory House, Trafalgar Place, Brighton BN1 4FY, United Kingdom

T +44 (0)1273 365 000 F +44(0) 1273 365 100 W www.mottmac.com

Propane Dehydrogenation and Polypropylene Plant ESIA Volume II - Main Assessment

336144/TRD/EFR/2/D October 2014 ESIA Volume II

Revision Date Originator Checker Approver Description Standard

A 04/06/14 N.Court C.Mills

L. Morton L.Morton First Draft for Client Comments

B 01/07/14 C.Mills L.Morton L.Morton Second Draft for KPI and Lender Review

C 15/08/14 C.Mills L.Morton L.Morton Disclosure Draft

D 10/10/14 C Mills L Morton L Morton Final

Issue and revision record

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.



Chapter Title Page

1 Introduction 1 1.1 Introduction ________________________________________________________________________ 1 1.2 Project Overview ___________________________________________________________________ 1 1.3 Financing of the Project ______________________________________________________________ 2 1.4 Purpose of this Document ____________________________________________________________ 3 1.5 Structure of the Report _______________________________________________________________ 3

2 Project Description 5 2.1 Project Overview ___________________________________________________________________ 5 2.2 Project Location ____________________________________________________________________ 5 2.3 Project Configuration ________________________________________________________________ 9 2.4 Utilities and Associated Infrastructure __________________________________________________ 17 2.5 Construction Phase ________________________________________________________________ 23 2.6 Operational Phase _________________________________________________________________ 25 2.7 Decommissioning Phase ____________________________________________________________ 26

3 Need for the Project and Analysis of Alternatives 27 3.1 Introduction _______________________________________________________________________ 27 3.2 Project Need ______________________________________________________________________ 27 3.3 ‘No Project’ Alternative ______________________________________________________________ 29 3.4 Location for the Project ______________________________________________________________ 31 3.5 Analysis of Alternatives _____________________________________________________________ 34

4 Legal Requirements and Standards 37 4.1 Introduction _______________________________________________________________________ 37 4.2 National Requirements ______________________________________________________________ 37 4.3 International Requirements __________________________________________________________ 42

5 Assessment Scope and ESIA Process 49 5.1 Introduction _______________________________________________________________________ 49 5.2 Scoping Stage ____________________________________________________________________ 49 5.3 Impact Assessment Methodology ______________________________________________________ 55

6 Information Disclosure, Consultation and Participation 59 6.1 Overview ________________________________________________________________________ 59 6.2 Principles of Consultation ____________________________________________________________ 59 6.3 Consultation Requirements __________________________________________________________ 60 6.4 Stakeholder Identification ____________________________________________________________ 64 6.5 Project Consultation Activities and Outcomes ____________________________________________ 67 6.6 Project Grievance Redress Mechanism _________________________________________________ 72

Contents



7 Social Impact Assessment 75 7.1 Introduction _______________________________________________________________________ 75 7.2 Methodology and Assessment Criteria __________________________________________________ 78 7.3 Baseline Description ________________________________________________________________ 88 7.4 Assessments of Project Impacts and Risks ______________________________________________ 99 7.5 Mitigation and Enhancement Measures ________________________________________________ 105 7.6 Residual Impacts _________________________________________________________________ 111 7.7 Proposed Monitoring and Reporting ___________________________________________________ 113

8 Air Quality 115 8.1 Introduction ______________________________________________________________________ 115 8.2 Legislation and Guidance ___________________________________________________________ 117 8.3 Methodology and Assessment Criteria _________________________________________________ 122 8.4 Impact Assessment Criteria _________________________________________________________ 134 8.5 Baseline Description _______________________________________________________________ 136 8.6 Assessments of Project Impacts _____________________________________________________ 140 8.7 Cumulative Impacts _______________________________________________________________ 145 8.8 Mitigation Measures _______________________________________________________________ 145 8.9 Residual Impacts _________________________________________________________________ 147 8.10 References ______________________________________________________________________ 147

9 Ground Conditions 149 9.1 Introduction ______________________________________________________________________ 149 9.2 Legislation and Guidance ___________________________________________________________ 150 9.3 Methodology and Assessment Criteria _________________________________________________ 151 9.4 Baseline Description _______________________________________________________________ 161 9.5 Assessments of Project Impacts _____________________________________________________ 176 9.6 Cumulative Impacts _______________________________________________________________ 184 9.7 Mitigation Measures _______________________________________________________________ 184 9.8 Residual Impacts _________________________________________________________________ 187 9.9 Additional References _____________________________________________________________ 187

10 Water Resources and Water Quality 192 10.1 Introduction ______________________________________________________________________ 192 10.2 Legislation and Guidance ___________________________________________________________ 192 10.3 Methodology and Assessment Criteria _________________________________________________ 195 10.4 Baseline Description _______________________________________________________________ 197 10.5 Assessment of Project Impacts ______________________________________________________ 201 10.6 Cumulative Impacts _______________________________________________________________ 205 10.7 Mitigation Measures _______________________________________________________________ 205 10.8 Residual Impacts _________________________________________________________________ 206

11 Ecology 208 11.1 Introduction ______________________________________________________________________ 208



11.2 Legislation and Guidance ___________________________________________________________ 208 11.3 Methodology and Assessment Criteria _________________________________________________ 212 11.4 Baseline Description _______________________________________________________________ 221 11.5 Assessments of Project Impacts _____________________________________________________ 233 11.6 Cumulative Impacts _______________________________________________________________ 238 11.7 Mitigation Measures _______________________________________________________________ 238 11.8 Residual Impacts _________________________________________________________________ 242 11.9 References ______________________________________________________________________ 245

12 Waste and Materials Handling 248 12.1 Introduction ______________________________________________________________________ 248 12.2 Legislation and Guidance ___________________________________________________________ 248 12.3 Methodology and Assessment Criteria _________________________________________________ 250 12.4 Baseline Description _______________________________________________________________ 251 12.5 Assessments of Project Impacts _____________________________________________________ 252 12.6 Cumulative Impacts _______________________________________________________________ 266 12.7 Mitigation Measures _______________________________________________________________ 266 12.8 Residual Impacts _________________________________________________________________ 269

13 Traffic and Transport 272 13.1 Introduction ______________________________________________________________________ 272 13.2 Legislation and Guidance ___________________________________________________________ 273 13.3 Methodology and Assessment Criteria _________________________________________________ 274 13.4 Baseline Description _______________________________________________________________ 275 13.5 Assessment of Project Impacts ______________________________________________________ 279 13.6 Cumulative Impacts _______________________________________________________________ 285 13.7 Mitigation Measures _______________________________________________________________ 285 13.8 Residual Impacts _________________________________________________________________ 286

14 Noise and Vibration 289 14.1 Introduction ______________________________________________________________________ 289 14.2 Legislation and Guidance ___________________________________________________________ 289 14.3 Methodology and Assessment Criteria _________________________________________________ 292 14.4 Baseline Description _______________________________________________________________ 295 14.5 Assessments of Project Impacts _____________________________________________________ 298 14.6 Cumulative Impacts _______________________________________________________________ 303 14.7 Mitigation Measures _______________________________________________________________ 304 14.8 Residual Impacts _________________________________________________________________ 305

15 Greenhouse Gas 308 15.1 Introduction ______________________________________________________________________ 308 15.2 Legislation and Guidance ___________________________________________________________ 310 15.3 Methodology and Assessment Criteria _________________________________________________ 314 15.4 Baseline Description _______________________________________________________________ 319 15.5 Assessments of Project Impacts _____________________________________________________ 320 15.6 Cumulative Impacts _______________________________________________________________ 321



15.7 Mitigation Measures _______________________________________________________________ 321 15.8 Summary _______________________________________________________________________ 322

16 Cultural Heritage 323 16.1 Introduction ______________________________________________________________________ 323 16.2 Legislation and Guidance ___________________________________________________________ 323 16.3 Methodology and Assessment Criteria _________________________________________________ 324 16.4 Baseline Description _______________________________________________________________ 326 16.5 Assessments of Project Impacts _____________________________________________________ 330 16.6 Cumulative Impacts _______________________________________________________________ 331 16.7 Mitigation Measures _______________________________________________________________ 331 16.8 Residual Impacts _________________________________________________________________ 331



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1.1 Introduction

Kazakhstan Petrochemical Industries Inc (hereafter referred to as “KPI”) are developing a propane dehydrogenation (PDH) plant and a polypropylene (PP) plant (the ‘Project’) located approximately 45 km north east of Atyrau in the Republic of Kazakhstan. KPI was established following a Government Decree in the Republic of Kazakhstan in 2004 and is a limited liability partnership between the United Chemical Company (UCC), who have a 51% share, and the privately owned Almex Plus, who has a 49% share. The UCC was set up following the request of the President of the Republic of Kazakhstan to establish a special company to deal with projects in the chemical industry.

Chicago Bridge and Iron (hereafter referred to as CB&I) have been awarded an engineering package in support of the development of the Project which includes the Front End Engineering Design (FEED) verification and the development of an International Environment and Social Impact Assessment (ESIA). CB&I has commissioned Mott MacDonald Ltd to act as the International Environmental Consultant (IEC) to conduct the ESIA and associated Environmental and Social Action Plan (ESAP) and Environmental and Social Management Plan (ESMP) of the Project to support obtaining international finance for the Project.

The proposed Project has had a national Environmental Impact Assessment (known as OVOS) undertaken by LLP Tetrakon Engineering on behalf of Sinopec Engineering received all the appropriate approvals from the State Environmental Expertise issued by the Republic of Kazakhstan Environment Ministry. However subsequently there have been some modifications to the design of the Project and the OVOS will be updated and resubmitted to the relevant authorities towards the end of 2014.

1.2 Project Overview

The Project is being developed as part of the Republic of Kazakhstan’s desire to expand the country’s

petrochemical industry. Kazakhstan has large oil reserves, particularly in the west of the country close to the proposed Project’s location. During the extraction and refining of oil large quantities of propane are produced and therefore the area has sufficient quantities of the feedstock for this Project.

The Project will consist of two main production facilities, a propane dehydrogenation (PDH) plant and a polypropylene (PP) plant, and a large packing and storage area. The PDH plant will convert the raw propane feedstock into propylene, which will then be utilised within the PP plant and converted to polypropylene pellets. Following production the polypropylene pellets will be packed into different sized bags or containers and stored within the storage warehouse ready for transport to market.

The Project is being constructed as part of an Integrated Petrochemical Complex (IPC). When complete the IPC will consist of an ethylene and polyethylene production plants, a butadiene production plant and a polymer plant which will mainly produce plastic bags. Currently the ethylene and polyethylene plants are at a similar stage in the design as this Project and are understood to also be seeking international finance. It is understood that the design work for the butadiene plant has not yet been awarded and therefore will not be operational for a number of years. The plastic bag production plant is in the initial stages of construction.

1 Introduction



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The Project is being developed on a greenfield site approximately 45 km to the north east of Atyrau and will make use of supporting infrastructure and utility provision that are being constructed and developed for the whole IPC. The key supporting infrastructure for the whole IPC will include power generation, water supply and treatment and gas supply.

A new road connecting the IPC to the existing A27 highway from Atyrau to Makat and a new rail spur and station within the IPC are in the final phases of construction and are due to be completed soon. Some other early construction works have already taken place; these include the laying of a new natural gas pipeline to connect the IPC to the existing central Asia gas pipeline as well as clearing and levelling of the Project site for the PDH and PP plants ready for the construction phase. An electrical substation is also in the final stages of construction and will be used to supply electricity from the Kazakh national grid during the construction phase. It is expected that major construction works for the Project will commence in the spring of 2015 with the peak construction period likely to be in the summer of 2017. The current plan is that the Project will be operational during 2019 following completion of performance tests which are due to take place at the beginning of 2019.

The closest settlement to the IPC is at Karabatan Station which is located approximately 7 km to the south east and the next closest (Railway Siding 496) being approximately 15 km to the south west.

This ESIA includes the construction, operational and decommissioning activities for all the process units and utilities associated with the Project. A detailed description of the Project is provided in Section 2 which includes an overview of the entire supporting infrastructure which the Project will utilise during its operational phase.

1.3 Financing of the Project

KPI will be seeking financing for the Project through the international finance market. Obtaining international finance is contingent on a range of international environmental standards being met during both the construction and operation of a Project. Currently the international lenders for the Project have not been confirmed however the Bank of Tokyo-Mitsubishi UFJ has been contracted to assist in raising financing for the Project. Atradius, the Export Credit Agency of the Netherlands, is also involved in the Project finance arrangements for providing reinsurance.

To address the potential environmental and social requirements of a range of banks that may wish to finance the Project this ESIA has been undertaken in line with the following international standards; The Equator Principles III (2013) International Finance Corporation Performance Standards (2012) and relevant Environmental Health

and Safety Guidelines Japan Bank for International Cooperation (JBIC) Guidelines for Environmental and Social

Considerations The European Bank of Reconstruction and Development Environmental and Social Policy (ESP) and

related Performance Requirements (2008) OECD Common Approaches (2012)



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1.4 Purpose of this Document

The purpose of this ESIA, and the ESMP and ESAP that accompany it, are to assess the Project’s

potential environmental and social impacts and to define appropriate mitigation and management measures in accordance with international standards.

The ESIA addresses the following; identifies and assesses the potential environmental and social impacts that the Project may have on

the environment and communities1 within its area of influence recommends measures to avoid, or where avoidance is not possible, minimise, mitigate or compensate

for adverse impacts on the environment and communities sets out ways to ensure that affected communities are appropriately engaged on issues that could

potentially affect them and promotes improved social and environmental performance through the effective use of management

systems

Other documents produced in support of the financing requirements of the Project, and that should be read in conjunction with this ESIA are also all produced by Mott MacDonald Ltd and include: Stakeholder Engagement Plan, June 2014 ESIA Scoping Report, June 2014 Environmental and Social Management Plan (ESMP) Environmental and Social Action Plan (ESAP) and Non-Technical Summary (NTS)

1.5 Structure of the Report

The ESIA is comprised of four volumes organised as follows:

Volume I: Non-Technical Summary; Volume II: Environmental and Social Impact Assessment (this volume);

Section 1 – Introduction Section 2 – Project Description Section 3 – Need for the Project and Analysis of Alternatives Section 4 – Policy, Legal and Institutional Framework Section 5 – Assessment Scope and EIA Process Section 6 – Information Disclosure, Consultation, and Participation Section 7 – Social Impact Assessment Section 8 – Air quality Section 9 – Ground Conditions Section 10 – Water Resources and Water Quality Section 11 – Ecology and Biodiversity Section 12 – Materials and Waste Management

1 Reference to communities includes consideration of impacts on labourers.



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Section 13 – Traffic and Transportation Section 14 - Noise and Vibration Section 15 – Greenhouse Gas Assessment Section 16 – Cultural Heritage

Volume III: Appendices / Supporting Documents Volume IV: Environmental and Social Management Plan and Environmental and Social Action Plan

Contact details for enquires on this ESIA are given below:

Project Proponent Information

Name of Company Kazakhstan Petrochemical Industries inc

For attention of Ms Balzhan Mukhambetaliyeva

Address 5 Dossorskaya Str, Atyrau, Republic of Kazakhstan, 060002

Telephone +7 (7122) 30-65-00

E-mail [email protected]

Website www.kpi.kz

mailto:[email protected]



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2.1 Project Overview

This section provides a description of the proposed Project. Once operational the Project will produce 500,000 tonnes per annum of polypropylene pellets for use within the Republic of Kazakhstan and for export internationally.

The Project is being developed as part of an Integrated Petrochemical Complex (IPC) in an area of land which has been designated as a special economic zone (SEZ) for the development of a “National Industry

Petrochemical Technology Park” in accordance with a number of Government decrees for economic growth. When complete the IPC will consist of propane dehydrogenation (PDH) plant and a polypropylene (PP) plant ethylene and polyethylene production plant (located to the north) butadiene production plant (located to the south) plastic bag production plant (located to the south)

This section provides a description of all the Project components as well as the infrastructure and utilities that are being constructed as part of the IPC.

2.2 Project Location

The IPC is located within the Atyrau Region in western Kazakhstan and is situated approximately 45km north east of Atyrau on the Kazakhstan steppe2. Figure 2.1 presents the Project location in relation to the wider area and countries.

The overall area of the IPC is approximately 600 ha, of which 165 ha is required for the Project. The whole Project site is 20 metres below sea level and historically formed the bed of the Caspian Sea.

The area is characterised by a flat, arid landscape with predominately low lying desert vegetation. A distinctive feature of the area is the presence of “sors”. Sors are natural, relict relief depressions and low-lying areas where water collects when it rains, and then evaporates, leaving mud plains, saline or saline areas.

2 The Kazakhstan Steppe is a large area of open grassland and extends to the east of the Caspian depression and the north of the

Aral Sea to the Ural Mountains in the north and the Altai Mountains in the east.

2 Project Description

6 336144/TRD/EFR/2/D October 2014 ESIA Volume II


Figure 2.1: Project Location

Source: Mott MacDonald



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Figure 2.2 presents the Project location in relation to nearby settlements and presents the existing infrastructure that the Project will use during its construction and operational phases.

The closest settlement to the proposed Project is Karabatan Station which is located 7 km to the south-east of the Project site and has an approximate population of 100 people. The next closest settlement is Railway Siding 496 and is located approximately 15 km to the south-west of the IPC and 20 km north-east of Atyrau and has an approximate population of 200 people.

There are a number of rivers located within the Atyrau Region, the closest major river is the Ural and at its closest point is 25km west of the IPC. The Project will not abstract or discharge water into any of these rivers but instead will use water sourced from the Kigach River located across the Kazakhstan/Russia border near to Astrakhan approximately 300km away and will be piped to the site using the existing Astrakhan – Mangyshlak pipeline and a new 27 km pipeline.

The closest industrial facility is the Bolashak Onshore Processing Facility (commonly called the Karabatan Refinery), operated by AGIP KCO and is located approximately 16 km south-east of the IPC. This Karabatan Refinery is part of the supporting infrastructure for the Kashagan offshore oil extraction project, located in the north Caspian Sea and is currently not operational.

The Project will utilise supplies of propane gas from the existing Tengiz oil field located approximately 150 km to the south east of the Project. Propane gas from the Tengiz oil field was historically flared as it was a by-product of the oil recovery process. However following a Government decree to reduce flaring and improve environmental performance propane was recovered and exported. The Project provides a local user for the recovered propane and will help promote economic growth through the production of higher value goods such as polypropylene pellets. In the future, the Project may also utilise additional propane supplies from the Karabatan refinery.



Figure 2.2: Project Infrastructure




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2.3 Project Configuration

2.3.1 Overview

Figure 2.3 presents a summary of the key Project components within the boundary of the Project and also presents the key inputs and outputs.

Figure 2.3: Project Configuration

Source: CB&I

2.3.2 Feedstock Transportation, Unloading and Storage

Propane will be the primary feedstock for the Project and will be sourced from the existing Tengiz oil field approximately 150 km to the south east of the IPC. Initially propane will be supplied directly from the Tengiz oil field however a new gas separation unit is planned to be built 20km north of the Tengiz site which will further process waste gas from the oil field and from which propane may be sourced in the future.

During the early phases of the Project’s operation propane will be delivered by train and arrive at the site via a rail spur and onsite rail station which has been specifically constructed for the IPC. Deliveries will consist of two trains per day each containing approximately 30 pressurised propane tank cars making a total of 60 propane tank cars delivered to site each day.



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On arrival the propane tank cars will either be directly connected to the unloading facilities or the train will be directed to a holding area located to the north of the rail station. To unload the feedstock the propane tank cars will each be manually connected to the unloading facilities at the train station.

Once connected the liquid propane will be removed from each of propane tank cars, this process will take approximately two hours for each train. Once all the liquid has been removed the vapour will then be extracted which will take approximately five hours. In total the unloading process of each train will take between 9-10 hours when accounting for the time taken to connect and disconnect the propane tank cars to the unloading system.

During the unloading phase propane will either be sent directly to the PDH plant for processing or to pressurised propane storage bullets located to the south of the unloading area. The storage bullets form part of the Project and will be located underground and away from the other process facilities for safety reasons. During the FEED verification the design has been altered to use storage bullets as opposed to gas storage spheres as they minimise fugitive emission releases and have a better overall safety performance. Each of the bullets will be 42 metres long and 8.4 metres in diameter.

To maximise the environmental performance of the unloading and storage of propane the unloading facilities and the storage bullets will be connected to the low pressure flare. All fugitive emissions will be collected and routed to the flare for combustion.

In the future a propane pipeline may be constructed to connect the IPC to the Tengiz gas separation unit. If this is constructed it will be done as part of the ethylene production facility to the north and is not considered an associated facility of this Project as it will operate without the pipeline.

2.3.3 Propane Dehydrogenation Plant (PDH Plant)

2.3.3.1 Overview

This section provides an overview of the process steps involved with the PDH plant. Figure 2.4 presents a process flow summary of the overall processes of the PDH plant. Processes within the green box relate to direct Project activities while those outside are provided from the associated project infrastructure.



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Figure 2.4: PDH Plant Overview

Source: CB&I

The PDH plant is designed to produce approximately 500,000 tonnes of propylene (63,000 kg/hr) based on normal operation for 8,000 hours per year. It will also produce 128 tonnes (16 kg/hr) of hydrogen.

During normal operation the PDH plant will process fresh propane plus an internal recycle stream. In addition it will process recycled propylene from the PP plant per year. The PDH plant will also use catalysts and chemicals within the reaction process. Section 12 on Materials and Waste Management provides detailed information on the types and quantities of each of these and how they will be stored and disposed.

In addition to these raw materials the PDH plant will also require the consumption of other utilities which will be provided by either process equipment with the Project boundary or by supporting infrastructure within the IPC and are presented below: High pressure steam Medium pressure steam Low pressure steam Nitrogen Instrument air Plant air Demineralised water Cooling water



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Boiler feed water Potable water Service water Hot water Electric power

2.3.3.2 CATOFIN Reaction Process

The PDH plant will utilise the CATOFIN® process which converts propane to propylene using a chromia-alumina catalyst. The Project will have multiple fixed-bed CATOFIN® reactors that operate on a continuous cycle. At any one time some of the reactors are on stream producing propylene, some reactors are on a reheat/regeneration phase and some reactors are undergoing evacuation and steam purge, air re-pressuring, cataclysm reduction or valve changing. Within the overall Project boundary a hot water boiler will be built to generate steam; this will be supplemented with steam generated via heat recovery within the PDH plant.

To meet the required temperatures within the CATOFIN® reactors natural gas or fuel gas produced by the process will be combusted. The resulting exhaust gases from the regeneration air stream are used to to superheat and generate steam. The internal steam generation plant also preheats the water used in the boiler and a surface condenser condensate.

The proposed design for the PDH plant uses the excess heat produced to improve the overall efficiency of the plant, and minimises emissions to the atmosphere.

2.3.3.3 Compression Section

Reactor gas is cooled and compressed with water and air being used to aid the cooling process. Water that condenses out of the reactor gas is collected and sent to the sour water stripper before being routed to the waste water treatment plant.

2.3.3.4 Recovery Section

During this phase inert gases such as hydrogen, nitrogen, carbon monoxide and carbon dioxide are removed from the compressed reactor gas. The propane and propylene and other heavier compounds are condensed and sent to the purification section. Light gases are sent to the low pressure fuel system for use in the Project to maximise efficiency.

2.3.3.5 Purification Section

This section consists of distillation towers to produce the high purity propylene product and to reject heavier compounds. Recovered light gases are reused as fuel.

Unreacted propane is returned to the reaction section as recycled propane so maximise the process efficiency and reduce waste gas from the Project.



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2.3.3.6 Storage

During normal operation approximately 80% of the propylene produced by the PDH plant will be sent directly to the PP plant and approximately 20% will be sent to the intermediate propylene refrigerated storage tank. This storage tank will be kept approximately 50% full at all times to allow flexibility in the operation of both the PDH and PP plants. In the event that either of the two process units are not operational the intermediate propylene storage tank will act as a buffer and can either supply propylene to the PP plant if the PDH plant is offline or in the event that the PP plant is not operational it will provide sufficient storage capacity to allow the PDH plant to continue to operate. In the event that the PDH plant is offline the storage tank can supply enough propylene to the PP plant for 1-3 days operation depending on the level of production.

The hydrogen produced within the process is removed from the process gas and compressed; it is then either sent directly to the PP plant for immediate use or stored in a designated storage area.

2.3.3.7 Sour Water System

Condensate from the compression stage will be stripped of hydrocarbons in the sour water stripper before being sent to the waste water treatment plant.

2.3.3.8 Other Utilities

Table 2.1 presents a summary of the other utilities which are required by the PDH plant.

Table 2.1: Summary of Other Utilities

Utilities Comments

Flare There will be two flares (high and low pressure each with a number of knockout drums depending on the origin of the gas for flaring) associated with the Project. All of the major process systems will be connected to the appropriate corresponding flare to collect any fugitive emissions from the PDH plant

Cooling water All water required for cooling will be provided by central utilities for the IPC and will provide all water at the required specification. Further information is provided in section 2.4.3.

Fuel Gas Natural gas is provided in one high pressure stream from the central utilities for the IPC. Further information is provided in section 2.4.2.

Instrument air, plant air and nitrogen Instrument air, plant air and nitrogen are provided by the central utilities for the IPC. Further information is provided in section 2.4.6.

Steam and Condensate system All steam requirements for the PDH plant are met from the Projects internal steam generation system. Condensate will be collected and treated in the central waste water treatment plant for the IPC.

Potable water and hot water Potable water is provided from the central provider for the



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Utilities Comments IPC. Further information is provided in section 2.4.4

Service water Service water is provided from the central provider for the IPC. Further information is provided in section 2.4.3

Liquid fuel system Liquid fuel (C4+) collected from the deoiler tower is used as a supplementary fuel for the CATOFIN reactors. In addition diesel will be supplied from IPC in case of lack of HP natural gas.

Oily water collection system Oily water is collected in the oily water pit and is sent to the central waste water treatment plant for the IPC. Further information is provided in section 2.4.7

Wash oil system Wash oil is sent to the central waste water treatment plant for the IPC. Further information is provided in section 4.4.7

2.3.4 Polypropylene Plant (PP plant)

2.3.4.1 Overview

The PP plant will have a capacity of approximately 500,000 tonnes per annum of polypropylene and will be generated using the Novolen® Process. Figure 2.5 presents the process overview for the production unit.

Figure 2.5: PP Plant Overview

Source: CB&I

Polypropylene will be produced in two separate production lines, the first of which will have a capacity of approximately 167,000 tonnes and the second 333,000 tonnes based on normal operation for 8000 hours per annum.

The PP plant will consume approximately 551,000 tonnes (69,000 kg/hr) of propylene and 8 tonnes per annum (1 kg/hr) of hydrogen under normal operating conditions. The reaction process will require



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additional catalysts, catalyst auxiliaries, adsorbents, chemicals and additives which are described in more detail in Section 12.

In addition to these raw materials the PDH plant will also require the consumption of other utilities which are presented below. Plant air Instrument air High pressure nitrogen Low pressure nitrogen High pressure steam Low pressure stream Cooling water Demineralised water Service water Potable water Hot water Boiler water

2.3.4.2 Novolen® Reaction Process

Liquid propylene will either be supplied to the PP plant directly from the PDH plant or from the intermediate storage tank. Prior to use in the PP plant the propylene will be purified to reduce its water content as this affects the polymerisation process.

The polymerisation reaction is carried out in vertical stirred gas phase reactors. Propylene is the main monomer feedstock and is added to the reactor; depending on the specification of required propylene other co-monomers such as ethylene and hydrogen are also added in varying quantities. The monomers are mixed in the reactor with a polymerisation catalyst and other co-catalysts. In this instance the polymerisation catalyst is activated using Triethylaluminium (TEA) before being mixed in the reactor.

From the reactor the resultant polymer powder and reactor gas is discharged to the polymer-gas separation phase. In addition any propylene gas that has not reacted with the polymerisation catalyst is recycled via a gas condenser and returned back to the reactor.

During the first stage of the polymer-gas separation phase the polymer powder and carrier gas is passed through a discharge vessel where the polymer powder is separated from the carrier gas at atmospheric pressure. From the discharge vessel the powder is passed by gravity flow to a purge vessel where it is mixed with nitrogen to purge the powder from remaining propylene. The purged powder is transferred by a pneumatic conveying system to a powder silo from where it is transferred again under gravity to the extrusion and mixing phase.

The dried powder first passes through an extruder where it is mixed with additives and water depending on the final specification of polypropylene required. At the end of the extruder is a face cutter which the mix in the extruder is passed through to create the polypropylene pellets. The water and pellet mix is passed



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through a centrifugal drier and the water recycled and passed back to the extruder system for reuse. The final dry pellets are transferred to one of the blending silos where there are constantly recirculated or discharged to bagging silos.

2.3.4.3 Bagging and Storage of polypropylene pellets

The Project will include four separate bagging silos. Three of these will have dedicated bagging machines which will load 35 kg bags at a maximum capacity of 1800 bags per hour. The fourth silo will have a spare bagging machine but also have the option of using a big bag bagging machine for bags in the region of 800-1200 kg or loading directly in 12 m long 24.75 tonne capacity containers.

The small 25 kg bags will then be palletized and transported to the enclosed storage warehouse. From here pallets will be loaded either onto trucks or rail tank cars depending on transportation methods.

2.3.4.4 Transport of polypropylene pellets

It is expected that the polypropylene will be sold to the following markets: Kazakhstan 10% Turkey 35% Rest of Europe 35% and China 20%

Currently the final transportation methods have not been confirmed although the pellets will be transported via a mixture of rail, heavy goods vehicles and shipping. At this stage the exact number of movements is not known as it will vary depending on the end users of the pellets. Approximately 1,500 tonnes of pellets will be produced every day and it is estimated that 20% of this will be transported via road. There is currently a large quantity of trucks that arrive in Kazakhstan full and leave empty and therefore the Project hopes to utilise these wasted return journeys.

On average it is anticipated that 65 rail carts of pellets will be transported from the Project daily. Depending on the end destination these could be transported using one train, however if the pellets need to be transported to different locations a maximum of three trains per day may be required.

If the pellets will be transported to Europe by rail they will be taken to the existing shipping port at the Black Sea and transported from there to the appropriate port in Europe. If the product is to be transported to China by rail the containers will be reshipped at the Chinese border and loaded onto new trains which fit the different gauge rail lines within China.

Due to the many potential shipping methods and the need to be able to transfer the polypropylene pellets from one form of transportation to another approximately 90% of pellets produced will be transported via shipping containers. Pellets will be loaded into 55 kg bags and packed onto pallets before being loaded into the containers 25 pallets at a time. The remaining 10% of pellets will be loaded into big bags or bulk storage and transported directly to the buyer.



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It is estimated that the Project would need to own or rent 3,000 containers to continuously transport the pellets to the various consumers around the world.

2.4 Utilities and Associated Infrastructure

2.4.1 Introduction

Utilities required for the operation of the Project will be supplied to each of the process plants of the IPC from the central utilities provider. They are being designed and managed via a Technical Council of the UCC and will operated by KLPE who will also be responsible for the ethylene and polypropylene production plants. This section describes the key utilities that will be provided by the central utilities provider and which are classed as associated facilities3.

2.4.2 Gas supply

The Project will require a continuous stream of natural gas for use within the following: Gas turbines located within the Project boundary CATOFIN reactors Boiler Supplementary firing in the heat recovery boiler Two Flares

The Project will require a supply of natural gas for use in the combustion equipment. In addition other utilities (such as the gas turbine power plant) under the responsibility of the central utilities provider will also require large volumes of natural gas.

To provide the required volumes of gas two new gas pipelines are being constructed to the IPC under the responsibility of KazTransOil. The pipelines will tie in to the existing ‘Central Asia – Centre’ gas pipeline system which runs from Turkmenistan to Russia and passes the IPC approximately 3km to the east. The first of these pipelines has already been constructed and has a capacity of around 80,000m3/day. When constructed the second pipeline will have a capacity of 100,000m3/day and will be built adjacent to the first pipeline. Both of the gas pipelines will be 300mm in diameter and when constructed will be buried below ground level.

Natural gas will be provided to the Project via one high pressure gas stream. This stream will be split into high and low pressure natural gas streams. The high pressure feed will be for the CATOFIN® reactors of the PDH plant and the low pressure feed will be for the boiler, gas turbines, waster heat recovery boiler and flares.

3 Associated facilities are those that are not funded as part of the project (funding may be provided separately by a client or third party including the government), and whose viability and existence depend exclusively on the project and whose goods or services are essential for the successful operation of the project.



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2.4.3 Process Water Supply

Process water for each of the separate projects within the IPC will be provided from a central water supply unit. KPI will purchase the required amount of water at the appropriate quality for use within the PDH and PP plants.

Water will be provided to the central water supply unit from the existing Astrakhan to Mangyshalk pipeline. Water for the pipeline is abstracted from the Kigach river, one of the tributaries of the Volga at Astrakhan. Further assessment of the additional abstraction of this water is made in Section 10.

Currently the capacity of the Astrakhan – Mangyshalk pipeline is approximately 50,000-60,000m3/day, however KazTransOil is in the process of expanding the capacity of the pipeline to 260,000m3/day. The current pipeline has a diameter of 1,200mm and to increase its capacity it will have additional pumping stations added along the route and the existing pumping stations will be upgraded. Currently there is a pumping station at the abstraction point and then at the 450km mark. As part of the upgrade an additional station will be added at the 300km mark.

As part of the IPC a new water pipeline will be constructed from the IPC to a tie-in point with the Astrakhan Mangyshlak pipeline. The new pipeline will be 27km in length and will have a capacity of 45,000m3/hour. KazTransOil will be responsible for the construction of this pipeline and supplying the water to the water supply unit in the IPC. The Project Documentation is currently being developed ready for submission to the relevant environmental regulatory (“State Environmental Expertise”) for approval. The new pipeline will have a diameter of 630mm and when constructed will be buried below ground level.

The raw water will be imported to the water supply unit and will be treated to the individual requirements of each of the process plants that the water will be used in.

The Project will have a normal process water demand of 712m3/hr and a peak water demand of 2005m3/hr. Table 2.2 presents the breakdown of the Project’s water requirements. The maximum water demand of the IPC including fire water will be 45,000m3/day.



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Table 2.2: Water Requirements (m3/hr)

Item Normal Peak

Service water 20 150

Demineralised water 39 57

Boiler feed water 326(b) 394(b)

Cooling tower make up water 327 452

Sand filter backwash 0 630

Fire water 0 322(a)

Total 712 2,005

Note (a): 1285.5 m3/h for 6 hours, the fire water tanks need to be re-filed a 24 hour period therefore peak demand is 1285.5 x 6 / 24 = 321.5 m3/h for 24

hours.

KPI

Note (b): Including polished condensate.

Note (c) : During start-up 115 t/h HP steam is to be imported.

In addition to the primary water supply options described above the State Environmental Expertise has requested that additional alternative supplies are also investigated. At present no detailed assessment of alternative options has been considered although options that will be investigated in accordance with State Environmental Expertise request include abstracting water from the Caspian Sea and piping it the 70km’s

to the IPC or using waste water from the City of Atyrau.

2.4.4 Potable Water Supply

Potable water consumption will be less than 5m3/hour for normal operation and will have a peak consumption of 17.5m3/hour. It will be supplied from a new water pipeline connecting the IPC to the existing potable water supply pipeline running from Atyrau to Makat which runs adjacent to the A27. The new pipeline will tie in with the main water supply pipeline 8 km from the IPC boundary and will be constructed as part of the plastic bag production plant to the south of the Project. The Project Documentation for the pipeline is currently being finalised for submission to the relevant authorities for approval. An agreement has been reached with the water supply provider of Atyrau (Atyrau Sy Arnasy) to provide 15,000 m3/year of potable water for the whole IPC.

2.4.5 Electricity Supply and Power Plant

The Project requires electricity for the process plants as well as the packing facilities and the administration buildings on site. The Project has a design capacity of 70.5 MWe and will require 66.2 MW of electricity under normal operation; of which the majority will be used within the PP plant.

Electricity will be supplied by the central power plant being constructed to supply electricity to the whole IPC. In total the power plant will consist of four gas turbine generators each with an electrical output of 50 MW. In addition each of the gas turbines will be fitted with a heat recovery steam generator (HRSG). Steam from the HRSG will be directed to two steam turbines which will each have an electrical output of 55 MW therefore the total electrical output will be 310 MW.



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The gas turbine will be fired using natural gas and exhaust gases will be vented through a stack of an appropriate height stack. Further consideration of impacts of exhaust gas emissions from the gas turbines is presented in Section 8.

The overall electricity demand of the IPC is presented in Table 2.3 below. The requirements of the Project are low in comparison to the total demand for the whole IPC.

Table 2.3: IPC Electrical Demand (MW)

Unit Normal demand Peak Demand

This Project 66.2 70.5

Ethylene Plant 108 114

Butadiene Plant 25 34

Plastic Bag Production Plant 6.5 9

Utilities 22 24

Total 227.7 251.5

Source: UCC Technical Council, KPI

2.4.6 Plant Air, Instrument Air and Nitrogen

Table 2.4 presents the Project’s plant air, instrument air and nitrogen consumption during the operational phase and will be provided by the central utility supply for the IPC.

Table 2.4: Utility Consumption (m3/hr)

Item Normal Design Peak

Plant Air 5,000 10,000 10,000

Instrument Air 5,000 10,000 10,000

Nitrogen 5,033 7,000 7,000

Source: KPI

2.4.7 Waste Water Treatment

Waste water generated from the Project will be directed to the central waste water treatment plant being developed for the IPC. Both process water and sanitary waste will be directed here although both waste streams will be kept separate during the treatment process.

The waste water treatment plant will consist of an additional reverse osmosis stage to reduce the salinity of the water prior to it being sent through the water clarification plant and reused within the IPC. There will be no discharges of waste water to either surface water bodies or ground water and water will be recycled and reused to minimise the overall raw water demand of the plant. Although the final designs are not yet complete it is anticipated that the waste water treatment system will make use of a large evaporation pond during the water treatment process.



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Table 2.5 presents an overview of the waste water streams from the Project that will be directed to the waste water treatment plant.



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Table 2.5: Waste Water Steams (m3/hr)

Item Normal Design Peak

Clean condensate 287 355 355

Suspect condensate and boiler blowdown 19.5 28 28

Waste stream 1 PP industrial waste water

14 20 20

PDH sour water

Oily water

Waste stream 2 PP pellets washing water

40 90 90

Storm water

Floor drains

Treated domestic water

Waste stream 3 Cooling tower blowdown

50 175 175

Total 410.5 668 668

Source: KPI

2.4.8 Waste disposal

During operation of the Project minimal solid waste will be generated. However every three years the catalysts used within the PDH plant will be replaced. All solid waste streams will be collected and separated according to type and stored within the specific waste storage area according to the national requirements. Waste will be disposed of by suitably licensed waste contractors in Atyrau. Full details of the wastes and proposed management arrangements are presented in Section 12.

2.4.9 Rail Spur and Station

Construction of a new rail spur and station to the IPC is nearing completion. The overall length of the rail spur is approximately 6 km and joins the existing rail network at Karabatan Station. The new rail track lies adjacent to the existing track at Karabatan Station and is approximately 30 metres from the closest residential receptors. To facilitate the rail spur a new overpass over the rail spur has been constructed for the A27 highway. Prior to construction all the appropriate national approvals and permits were obtained by KPI.

2.4.10 Access Road

A new two way access road has been constructed from the A27 highway to the IPC. This will provide the main access route for all vehicles during the construction and operational phases of the Project. The road is approximately 5 km in length and ties in to the existing highway to the north of Karabatan settlement. Prior to construction all the appropriate national approvals and permits were obtained.



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2.5 Construction Phase

2.5.1 Overview

Development and construction of the Project is expected to commence in early 2015 with the first stages of engineering and procurement being undertaken. The overall schedule for construction of the Project will depend on the delivery period of a number of major plant items and receipt of all approvals, permits and international finance and therefore the schedule presented in Figure 2.6 is preliminary. The final construction management plan is not confirmed and there may be an Engineering Procurement and Construction (EPC) contractor or an Engineering Procurement and Construction Management (EPCM) contractor and a main construction sub-contractor.. At present indicative construction plans for a facility of this type are available and have formed the basis of the ESIA.

Some of the supporting infrastructure for the Project is either currently in the process of being constructed or has already been completed. This includes the rail spur and associated road bridge, the access road to the site from the A27 and one of the natural gas supply pipelines. Prior to construction all the appropriate national construction permits and approvals were obtained.

Figure 2.6: Indicative Construction Schedule

Source: CB&I

2.5.2 Staffing

Based on the current estimates and the above construction schedule the Project will generate on average 1,000-1,500 construction jobs. It is expected that during the peak construction period will run through the second half of 2016 and the first half of 2017 when the number of construction workers will peak at between 2,000-2,500. Figure 2.7 presents the estimated manpower on a month-by-month basis across the construction period.

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4Engineering & procurement

Construction

Training & Commissioning

Performance Test

2015 2016 2017 2018



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Figure 2.7: Construction Phase Manpower

Source: CB&I

It is expected that the construction shifts will last for 10 hours and during the summer months double shifting will be used to make use of light and warm conditions. At present it is planned that the construction workforce will work on a 28 day rotation. It is anticipated that construction will take place six days a week and the maximum number of hours any construction worker will work within a week will be 60 hours. This approach is in accordance with Kazakhstan national labour laws.

Section 7 on social Impacts assesses the impacts of the construction labour workforce on the local area and issues associated with worker’s rights.

2.5.3 Workers’ Accommodation

Currently no construction contractor has been appointed for the Project so the exact details relating to workers’ accommodation have not been finalised. However there are a number of existing workers’ camps already located within the Atyrau region and it is anticipated that either these existing workers accommodation facilities would be utilised, or new workers accommodation would be built approximately 15 km from the IPC.

Prior to the beginning of the construction phase KPI or the relevant EPC contractor or EPCM contractor will perform an audit of any existing workers’ accommodation to confirm its compliance with the joint EBRD/IFC guidance document on workers’ accommodation.



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2.5.4 Laydown Area

During the construction phase one of the early items to be constructed will be the storage warehouse. Following completion, the warehouse will be used as the main laydown area for the Project. It is not expected that any additional land outside the IPC boundary will be required for additional laydown.

2.5.5 Contractor Requirements

All construction contractors will be required to implement the following environmental, social and health and safety requirements: Construction contractor to provide environmental and social management and mitigation plan prior to

the commencement of construction that addresses the requirements of the ESMP contained within Volume IV of this ESIA

All construction contractors (including sub-contractors) will be required to be ISO14001 compliant and to be able to demonstrate that its local joint venture partners are also accredited to ISO14001 or can provide evidence of working to a formal management system

The Invitation to Tender (ITT) requires that international standards for construction health, safety and environmental management are employed

During the construction management phase there will be a dedicated full time member of the Project management team from KPI who will oversee environmental, social and health and safety management and monitoring and liaise with the counterparty in the construction contractor.

2.5.6 Construction of Associated Facilities

The design and construction of the central utilities will be managed by a separate company called KLPE who are also responsible for the design, construction and operation of the ethylene and polypropylene plant within the IPC. The appropriate national approvals will be sought for all of the associated facilities prior to construction taking place.

2.6 Operational Phase

2.6.1 Overview

KPI will be responsible for the operations and maintenance (O&M) organisation for the Project. It is proposed that the majority of employees will be sourced from Kazakhstan although it is likely that these will be sourced from other cities as there are not sufficient resources located within Atyrau. KPI have already begun training of future operational staff at existing plants within Kazakhstan or through specific training centres.

Under normal operating conditions, the Project will be operated at 100% of capacity with a design basis of 8,000 hours per year. It is anticipated that the routine maintenance will be undertaken on a three year rotational basis.



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2.6.2 Staffing

It is expected that the Project will employ a total of approximately 400 operational workers. These will be split into three separate shifts with each shift lasting 8 hours a day.

2.7 Decommissioning Phase

Upon end of life of the Project all hazardous wastes will be removed and sent for safe disposal. A full ground investigation, including soil and groundwater monitoring, will be undertaken in and around all Project areas to identify any contamination. If contamination is identified, a remedial programme will be elaborated as part of decommissioning.

Remaining plant will be considered for re-use and recycling following dismantling. A dedicated decommissioning strategy (possibly including the preparation of an ESIA and ESMP specifically relating to decommissioning) will be developed in advance of the end of Project life.

There is a medium sized operational workforce so eighteen months prior to decommissioning a retrenchment plan will need to be produced. Activities to support workers finding alternative work will need to be implemented in advance of the end of Project life.



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3.1 Introduction

This section discusses the needs case for the Project in the context of economic, socio-economic and market factors in order to evaluate whether there are sufficient drivers to justify development of the Project. This section also provides analysis of the suitability of the site selection and potential alternatives.

The significant alternatives considered for the Project are broadly categorised as follows, and discussed in more detail below: Project need; No project alternative; Location for the Project and associated infrastructure; and Options and alternatives for key technical and process aspects of the Project.

3.2 Project Need

3.2.1 Introduction

This section presents the Project need and provides context on the current polypropylene market as well as setting out the various uses of products produced by the Project.

3.2.2 Polypropylene Uses

Polypropylene is formed from the polymerisation of propylene and is known as thermoplastic because when it is warmed it becomes pliable and can be moulded or extruded into various plastic products. The products are often characterised by their toughness, flexibility, low weight, and heat and water resistance. Polypropylene also has a better transparency than other polyolefin products which mean that it is widely used in packaging and for containers. Different properties of polypropylene can be achieved depending on the blend of additives and other monomers, such as ethylene, added at the polymerisation stage. Polypropylene therefore has many uses including: Packaging; Automotive products; Textiles; Houseware (such as plastic storage boxes); Furniture; Medicine and health products; and Tubing amongst others.

3.2.3 Governmental Drive to Develop Kazakhstan’s Petrochemical Industry

The Project has been developed under the Government’s program for further development of the

petrochemical industry in the Republic of Kazakhstan, which emphasises the importance of the implementation of technology-intensive production facilities that allow Kazakhstan to compete in the world

3 Need for the Project and Analysis of Alternatives



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petrochemical arena and to develop new export niches. The following requirements are the basis for the development of the integrated petrochemical complex close to Atyrau. Governmental Programme on the development of the petrochemical industry (Government decree

№1352 issued on 29 December 2007), replaced by the new programme “Programme on the

development of oil and gas sector for 2010-2014” approved by Government Decree № 1072 issued on October 18, 2010 (as amended of April 17, 2014)

Governmental Programme on forced industrial-innovation development of Kazakhstan (issued on 23 February 2010)

Establishment of Special Economic Zone “National Industrial Petrochemical Technopark in Atyrau region” (Decree of the President of the RoK №495 issued on 19 December 2007)

Development and maintenance of “Management of Special Economic Zone” National Industrial

Petrochemical Technopark” (Government decree №314 issued on 02 April 2008)

The construction of the PDH and PP plants is one of the key production plants that will form part of the IPC in the Atyrau Region.

3.2.4 National and International Demand for Polypropylene

The Republic of Kazakhstan has considerable hydrocarbon reserves and the oil and gas sector has been the cornerstone of Kazakhstan’s growth, with its share of the country’s GDP growing steadily from 3.7% in

1997 to 14.7% in 2006, and up to 25.8% in 2011.4 Until recently, however, oil refining and further processing of raw materials in petrochemical plants was ignored, with most projects revolving around upstream exploration and production. Moreover, during the global economic crisis, local production of plastics decreased significantly. To date, the plastics industry remains underdeveloped in Kazakhstan; however, there is increasing demand for polypropylene from local/national small and medium businesses and other production facilities.

Polypropylene production also presents a significant opportunity for Kazakhstan on the global export market. The global polypropylene market is the second largest volume polymer business in the world making up 25% of global polymer demand.5 Growing demand from end-use industries such as packaging, automotive and consumer products is expected to drive the polypropylene market over the next decade. In addition, factors such as changing lifestyles and increasing disposable incomes in Asia Pacific are further driving the market for various end-use industries. As a result there is now increasing pressue on producers to generate more propylene to meet the current demands.

3.2.5 Regional Job Creation

The Project will also create a number of additional jobs within western Kazakhstan. Employment opportunities will be created in both the construction and operational phases with the peak construction

4 Ernst & Young. 2013. Kazakhstan Attractiveness Survey. Online: http://www.ey.com/Publication/vwLUAssets/EY-Kazakhstan-

attractiveness-survey-2013-ENG/$FILE/EY-Kazakhstan-attractiveness-survey-2013-ENG.pdf 5 IHS.2014. World Analysis. Online http://www.ihs.com/products/chemical/planning/world-petro-analysis/polypropylene.aspx

http://www.ey.com/Publication/vwLUAssets/EY-Kazakhstan-attractiveness-survey-2013-ENG/$FILE/EY-Kazakhstan-attractiveness-survey-2013-ENG.pdf

http://www.ey.com/Publication/vwLUAssets/EY-Kazakhstan-attractiveness-survey-2013-ENG/$FILE/EY-Kazakhstan-attractiveness-survey-2013-ENG.pdf

http://www.ihs.com/products/chemical/planning/world-petro-analysis/polypropylene.aspx



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workforce expected to be 2,500. During operation the Project will directly employ approximately 400 people, although it is estimated that the IPC as a whole, and associated jobs from supply chain and other associated manufacturing industries, will be much higher.

3.2.6 Diversification of Industries in the Region

The Atyrau Region is one of the most industrially developed regions in Kazakhstan. It has the greatest concentration of foreign companies and national oil companies; however, these are currently focused towards upstream oil and gas as opposed to the downstream processing plants. The Project will therefore also contribute to the diversification of industries in the Region.

3.3 ‘No Project’ Alternative

3.3.1 Overview

The ‘no Project’ option considers the position if the proposed Project does not proceed and the existing supplies of feedstock, and any additional future supplies of feedstock generated by other developments available within the industrial area, are not utilised. If the Project is not constructed, national production levels of polypropylene will not increase at the desired rate and the Government of Kazakhstan would not achieve its desired position of becoming a global exporter of polypropylene.

3.3.2 Environmental Perspective

The ‘no project’ option considers the position that the site is not used for the purposes of the Project or for any other commercial enterprises. It assumes that no development would take place and the existing Kazakhstan steppe baseline situation would remain. The environmental perspective only considers the Project location and associated facilities and does not consider an expansion of the Tengiz oil field where the propane feedstock will be sourced. Historically this propane gas would have been flared into the atmosphere which has a number of significant associated negative environmental impacts6 but projects such as this one provide an efficient use of raw materials. The Project does not require any additional activities at the Tengiz oil field and any future expansion of this oil field will not be as a result of the Project.

By developing the PDH and PP plants adjacent to each other the propylene produced in the PDH plant will be used as the main raw material for the PP plant. This reduces the need for the transportation of propylene between plants and further reduces environmental impacts.

No known notable flora exists on the Project site and it does not feature any sensitive habitats. There are, however, fauna with international and/or national conservation concern, which have been identified within the Project’s zone of influence (ZoI) although it is not considered that the Project will have a significant

effect on them. Air quality will not change significantly compared to the baseline conditions and will not cause significant impacts at any nearby sensitive receptors. There are no culturally significant sites within

6 For example, an increase in GHGs and a contribution towards climate change or acid rain



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the IPC and the land is currently only used as informal grazing land by the nearest settlement of Karabatan Station which is located 7 km away.

Environmental effects caused by the Project will be reduced by suitable mitigation measures proposed within this ESIA which will minimise environmental impacts whilst enabling the Project to contribute to the national petrochemical production targets and assist in meeting the rising demand for polypropylene in the domestic and international markets. The Project design has been developed in line with best practice national and international environmental standards. Where environmental impacts have been identified a range of appropriate mitigation measures have been proposed. These measures will be written into the Project’s construction and operation Environmental and Social Management Plans (ESMPs) covering all phases of the Project life.

3.3.3 Economic Perspective

Once operational, the Project would contribute significantly towards the national petrochemical production programme, a key drive currently being made by the Government. The Project will help support an emerging petrochemical market in Kazakhstan, but will also complement existing markets. For example, the development of the Project could further strengthen the position of the existing oil and gas industry that is located in close proximity to the IPC. Propane is a by-product of natural gas processing and petroleum refining, the PHD / PP plants are taking the propane feedstock and turning it in to a high-value, saleable product.

The development of the Project also promotes economic diversification, which can be seen as important in achieving sustained economic growth by reducing the country’s reliance on oil and gas exports.

Strengthening and diversification of the Atyrau economy can also play a role in assisting the region to combat any severe economic difficulties experienced within any one industry. The Project would also be expected to have a positive knock-on effect upon supply-chain businesses.

Not developing the Project would result in the benefits noted above not being realised, placing a reliance on importation of polypropylene, which has inherent price and supply risks. However, producing polypropylene in Kazakhstan would not only ensure the security of supply of polypropylene products within the Atyrau Region and Kazakhstan itself, but will also offer the potential to further establish trading relationships with key international markets, in particular China. Enabling high-value polymer products to be exported will have a positive effect on the economy.

3.3.4 Socio economic Perspective

The Project will result in significant job opportunities during the construction phase and approximately 400 direct new jobs during the operational phase. The Project will provide good quality direct employment and training opportunities for local people as well as other people within the Atyrau as a whole. The Project will also stimulate secondary economic activity in the form of suppliers and other local service providers that will be supported by the increased income of people working at the Project. As a result of the job creation it is likely that the Project will encourage inward migration of people into Atyrau. This could put pressure on



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local communities and on the existing infrastructure within the area (i.e. housing and transport) and cause resentment from the locals if they are unable to get employment.

With a ‘no Project’ alternative the current situation would remain and although this avoids some of the minor impacts, and none of these identified major benefits would be realised.

3.3.5 Conclusions

It can be concluded that a ‘no Project’ alternative would not satisfy Government objectives aimed at promoting Kazakhstan’s petrochemical industry, nor would it contribute to the economic growth of the

Atyrau Region or the Republic of Kazakhstan as a whole. Opportunities for additional job creation in the Region would be lost and so would the security of polypropylene supply. A ‘no project’ scenario will have

obvious minor environmental benefits, as noted above; however the likely environmental impacts from the Project would be carefully managed during the design stage and easily mitigated during operation through the implementation of the ESMP developed for the project.

3.4 Location for the Project

3.4.1 Introduction

When assessing the suitability and therefore selection of a project site the location is often driven by all or a selection of the following factors: Designation of site for the use of land; Proximity to sensitive receptors; Proximity to raw materials; Proximity to connections for utilities; Proximity to infrastructure to transport raw materials in and products out; Proximity to markets.

During the site selection process a former chemical plant located in Atyrau was also considered. However, as a result of urban sprawl, this location is now close to sensitive receptors, including local communities and businesses.

Following a review of potential sites the proposed IPC site was selected for the following reasons (more details on site selection have been presented below): The land was designated as a “National Industrial Petrochemical Technopark” – the site has been

designated by the Government as a special economic zone (SEZ)7; The site is located not too far from the required feedstock (propane); There are large natural gas and water pipeline running close to the site The site is located close to existing road and rail infrastructure

7 Kazakhstan has set up several special economic zones (SEZs) to encourage the creation of efficient export-oriented manufacturing;

attract investment; implement new technology; and introduce modern management techniques. The SEZ law requires a presidential decree to set up a new SEZ and it may be established for a maximum of 25 years.



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The site is located away from Atyrau and any potential local sensitive receptors the closest of which is approximately 6 km away.

During the site selection KPI reviewed all the above factors and concluded that the proposed location provided the best balance of all the above factors which couldn’t be matched by any other site.

3.4.2 Creation of the Special Economic Zone (SEZ)

The Project is being developed as part of an IPC in a designated SEZ8. In 2007 the IPC site was selected to become a SEZ with its primary purpose being to raise construction investment and develop petrochemical production and hydrocarbon processing in Kazakhstan. The SEZ offers companies a range of tax concessions, for example corporate income tax and VAT exemptions, provided at least 90% of their aggregate annual income is generated by petrochemical sales, and sales of products from related industries.

Originally it was proposed to locate the IPC within Atyrau City close to the existing oil refinery; however this was rejected by the Ministry of Environment because of issues with the required SPZ and existing environmental impacts. An Alternative site close to the existing Tengiz oil fields was investigated but this were not viable as it did not have access to the required infrastructure links to easily export the products from the site. The current location was decided upon due to it being far enough from Atyrau not to cause environmental impacts but close enough to make use of its existing infrastructure such as transport links. The 2006 pre-OVOS procedure approved the location of the special economic zone.

3.4.3 Availability of Feedstock

The main feedstock for the Project is propane and as discussed above, propane is generated during the refining process of petroleum and natural gas. Kazakhstan is one of the largest oil producers in the world and it has the second largest oil reserves as well as the second largest oil production among the former Soviet republics after Russia. Its estimated total petroleum liquids production was 1.64 million barrels per day (bbl/d) in 2013. In addition, Kazakhstan has extensive natural gas reserves (estimated 85 trillion9 cubic feet (Tcf)) and produced 1.4 trillion cubic feet (Tcf) in 2011. Kazakhstan's current production of oil and gas is dominated by two giant fields: Tengiz and Karachaganak.

The availability of propane supplies for the Project is a key determining factor when determining the location. The Tengiz oilfield is located approximately 150 km from the proposed IPC, which produces large quantities of propane during the refining process. No other sites in closer proximity to Tengiz were considered as the supporting infrastructure such as major roads would not have been present. The proposed Project location will also be able to utilise the majority of the existing rail network, which will allow the propane to be effectively sourced from the Tengiz oilfield.

8 Kazakhstan has set up several special economic zones (SEZs) to encourage the creation of efficient export-oriented manufacturing;

attract investment; implement new technology; and introduce modern management techniques. The SEZ law requires a presidential decree to set up a new SEZ and it may be established for a maximum of 25 years.

9 U.S. Energy Information Administration (EIA). 2013. Online: http://www.eia.gov/countries/cab.cfm?fips=KZ

http://www.eia.gov/countries/cab.cfm?fips=KZ



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3.4.4 Accessibility

From a logistical perspective, the site is also very well connected to Atyrau and surrounding areas through existing road and rail networks. This is an important factor when in relation to the import of raw materials for the facility and the export of the high-value PP product as well as access for the workforce during both construction and operational phases. The availability of transport infrastructure also provides access to the markets of neighbouring countries and further afield countries through road, rail and sea options.

The Project will also be located near to key utilities such as gas and water which have existing pipelines close to the IPC site which will be utilised.

3.4.5 Environmental and Social Perspective

As identified in section 3.3.2 the proposed Project will have some environmental impacts on the surrounding environment. It should be noted that there are also a number of environmental and social advantages to locating the Project in the proposed IPC site, which include: There are no environmentally designated areas within 85 km of the industrial area; There are no known historical or cultural heritage sites within the site boundary or located in close

proximity to the industrial site; and It is located away from Atyrau and therefore away from the largest population centre in the area.

3.4.6 Conclusion

The proposed Project location is on land specially created for petrochemical production activities and forms part of the Government of Kazakhstan development plans. The selected site has many advantages particularly related to environmental and social impacts given its remote location. As such the proposed Project location is considered to be appropriate and further detailed investigation of other potential locations has not been undertaken.



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3.5 Analysis of Alternatives

The Project will be designed to meet current international best practise to minimise potential environmental impacts. This section provides a brief summary of some key Project component technologies selected, expanding on the key options and/or reasons as to their selection taking into account technical, economic and environmental, health and safety considerations.

The scale of the proposed PDH and PP plant is well within the commercially proven range and the technology employed at all stages of the Project is mature and well understood.

In particular during the project development phase careful consideration has been given to greenhouse gas emissions. To minimise emissions the project has been designed to maximise internal steam generation by using excess heat from other combustion processes. Therefore this has reduced the need to install additional steam raising boilers for the Project which would increase total greenhouse gas emissions.

The technology providers are well established and reputable, which provides confidence that the technology chosen will deliver the required technical and EHS standards.

Table 3.1 provides a summary of the reasons for the selection of specific project components.

Table 3.1: Summary of Technology Selection

Component Selected Design / Technology Reasoning for Technology Selection

Internal steam generation

Process gases from the CATOFIN reactors sent used to generate steam

Maximises heat recovery from the plant to generate steam needed for the process and reduces overall fuel demand and reduces greenhouse gas emissions.

Alternative designs would resulted in reduced heat recovery from process gases and the need for additional steam raising boilers which would increase greenhouse gas emissions.

Feedstock storage Storage bullets have been selected to store propane as opposed to storage spheres.

Storage bullets have an improved safety standard and environmental performance with fewer fugitive emissions compared to alternative storage methods such as storage spheres and therefore the proposed choice is considered best practice. By reducing fugitive propane releases the selected design also minimises greenhouse gas emissions as propane has a global warming potential 3.3 times greater than CO2

Waste water treatment Closed circuit wastewater treatment system, including fully lined wastewater pond. All waste water streams will either be recycled within the process or captured and re-routed to the waste water treatment system resulting in a zero-discharge waste water system.

Technically proven. The waste water discharge philosophy is considered to be aligned to the EHS Guidelines that aim for zero discharge design / Use of treated waste water to be included in Project design processes.

Alternative designs would have resulted in discharges to surface water bodies such as the Ural river. This river is already polluted and additional discharges would increase the



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Component Selected Design / Technology Reasoning for Technology Selection environmental impact of the Project.

Electric power and steam generation

Onsite power generator, 4 gas turbines and waste heat recovery (WHRU) boilers fired on natural gas from the existing Central Asia gas pipeline. Steam will be generated from the WHRU and used to generate additional power in two steam turbines. Low NOx technology will be used in the gas turbines.

Selected power and steam generation technology will be more energy efficient than a single cycle power generation system and separate steam raising boilers.

The project has chosen to use gas as a fuel and combined heat and power generation, which is considered as best available technique for gas fired generation. Efficiencies of this technology are above 50% compared to other methods such as coal which are approximately 35% efficient.

In addition to the improved efficiencies of gas over coal lower greenhouse gas emissions are also associated with the transport of the fuel. Gas will be delivered to the IPC from a short new pipeline to an existing pipeline running close to the IPC. Coal would need to be transport large distance using boats, rail or road or a combination of all three and would therefore lead to additional greenhouse gas emissions. Finally it would not be economically viable for new power sources such as nuclear or hydro-electric power generation to have been considered.

Alternatives such as the use of intermittent renewable generation (e.g. wind, solar) is not feasible given the need for 24 hour secure power and steam supply and use of non-intermittent renewable generation (e.g. biomass) is not feasible due to lack of available and reliable fuel source. The choice of renewable energy would also not be economically viable especially given that it is not well developed in Kazakhstan.

Therefore it is considered that the Project and IPC has selected the most appropriate electric and steam generation system to minimise greenhouse gas emissions.

Water supply 27 km pipeline from the existing Astrakhan to Mangyshlak water pipeline to the on-site shared water treatment plant. Water is abstracted from the Kigach river.

Use of existing abstraction point means Project will not require a new abstraction point and the Kigach river has sufficient flow to allow for the additional abstraction.

Technically and economically viable solution tying into existing infrastructure and minimising need for extensive new infrastructure. The other potential options currently be investigated following a request from the State Expertise would require further additional infrastructure particularly if water was to be abstracted and piped from the Caspian Sea.

The Project design has included for various water recycling opportunities included in the process design and includes a reverse osmosis plant to minimise the overall water use as such aligned to the EHS Guidelines objectives to minimise water use.



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Component Selected Design / Technology Reasoning for Technology Selection

Flare High and low pressures flare to prevent process gasses and fugitive emissions being vented to atmosphere during normal operation and during emergency situations.

Provision of flares prevents venting of hydrocarbons to the atmosphere collected from process units and storage tanks and thereby reducing emissions of greenhouse gases compared to these gases being vented without combustion. By collecting and combusting any fugitive emissions the global warming potential of these releases is being reduced as following combustion only CO2 is released which has a global warming potential of 1 compared to other hydrocarbons which are much greater.



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4.1 Introduction

There are a number of national and regional requirements that the Project will have to comply with in addition to appropriate international lenders requirements. This section provides a brief overview of the applicable regulations and standards that will be applied to the Project.

4.2 National Requirements

4.2.1 Overview

The main environmental and social principles of the Republic of Kazakhstan (RK) are set out in the Constitution of the Republic of Kazakhstan, Environmental Code and Code on public health and healthcare system.

The constitution of the Republic of Kazakhstan was accepted August 30, 1995 via public referendum and put into force September 5, 1995 (as amended on 02.02.2011) and establishes and protects citizens’ rights

and freedoms and states that “State aims at environmental protection and wealthy and healthy life of the population” (Article 31, RK Constitution).

National strategy “Kazakhstan – 2050” dated December 14, 2012 sets forth the Kazakh development programme until 2050 which includes 7 main state development directions. Sustainable development and improved social conditions are described among the key goals and corresponding actions for their achievement are envisaged.

Environmental protection and public welfare in the Republic of Kazakhstan is regulated by the following legal acts and regulations: International contracts, conventions, agreements and other international legal acts wherein the

Republic of Kazakhstan is a participant (assignee); the Republic of Kazakhstan Constitution; the Republic of Kazakhstan Codes and Federal Laws; the Republic of Kazakhstan President Decrees, the RK Government Regulations (Orders); the Republic of Kazakhstan Subjects’ Laws; Orders issued by the heads of executive bodies of the Republic of Kazakhstan subjects; Systems of state sanitary-hygienic norms and rules (SanPiN, GN), State Standards (GOSTs) and

Building Codes (SNiPs), Code of Conduct (SN); and Systems of interdepartmental and departmental research documentation.

4.2.2 Environmental Protection

The main environmental protection legal regulation is: Environmental Code No. 212-III dated January 9, 2007 (as amended on 11.04.2014) of the Republic of

Kazakhstan.

4 Legal Requirements and Standards



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The Environmental Code was created in 2007 in order to substitute several laws regarding environmental protection and to combine them in one legal document that would summarize environmental goals and objectives of the Republic of Kazakhstan.

Environmental Code sets forth the legal basis of the environmental policy to ensure environmental protection, rehabilitation, preservation and rational use of natural resources on the territory of the Republic of Kazakhstan. It also comprises the list of the legal normative documents which are to be accepted under the implementation of the Environmental Code.

It covers most of the environmental aspects, defines environmental norms and approvals. Examples of the articles covered by the Environmental Code are provided below: Chapter 6: Environmental Impact Assessment (OVOS) Chapter 8: Environmental Permits Chapter 14: Industrial environmental supervision Chapter 33: Environmental requirements on water bodies use Chapter 35: Environmental requirements on fauna Chapter 42: Environmental requirements on domestic and industrial waste

There are a number of specific environmental protection acts and regulations which are considered within the national OVOS process, including the above mentioned and the following documents: Water Code No. 481-II dated July 9, 2003 (as amended on 11.04.2014) of the Republic of Kazakhstan

regulates the use and conservation of water bodies. Law No. 175-III “On special protected territories” dated June 07, 2006 (as amended on 03.07.2013) of

the Republic of Kazakhstan sets forth the systems of protected areas and details the pattern of their use and protection of species pool.

Law No. 593-II “On protection, rehabilitation and use of wildlife” dated July 9, 2004 (as amended on 03.07.2013) of the Republic of Kazakhstan regulates the protection and use of wildlife, conservation and restoration of wildlife habitats in order to ensure biological diversity

Government Decree No. 969 dated July 25, 2012 “On prohibition of the saiga antelope usage or their parts but research usage on the territory of the Republic of Kazakhstan until 2020 year”.

Land use is regulated by the following legal act: Land Code No. 442-II dated June 20, 2003 (as amended on 17.01.2014) of the Republic of

Kazakhstan. The code sets forth the legal basis for the use and conservation of land, provisions of the land law and land relations.

Public welfare is health is regulated by the following legal acts: Code No. 193-IV "On public health and healthcare system" dated September 18, 2009 (as amended on

11.04.2014). The Code sets forth (inter alia) key 17 principles of the national health care policy (Article 4), public health monitoring and control and general responsibilities of businesses and organisations in preventive measures and public health control (Article 90).

Law No. 188-V "On civil defence" dated April 11, 2014 of the Republic of Kazakhstan. The main objectives of this law are protection of population, environment and facilities management from emergency situations and the consequences caused by them.



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Sanitary norms "Sanitary requirements for radiation safety" approved by RK Government Decree №

201 dated February 3, 2012.

4.2.3 National EIA Process

According to the Environmental Code Environmental Impact Assessment (EIA) is mandatory procedure “for all economical or other activities which may have direct or indirect environmental impacts” (Article 36,

Section 6).

Environmental Impact Assessment procedure (OVOS) is regulated by the following legal act: “Procedure for the environmental impact assessment of proposed economic and other activities when

developing pre-planning, planning, pre-design and project documentation” adopted by Order of the RK

Minister of Environment No. 204-P dated June 28, 2007 (as amended on 24.09.2013) of the Republic of Kazakhstan.

The OVOS procedure is broadly compatible with the Environmental Impact Assessment (EIA) process applied internationally and incorporates: a description of the development; a characterisation of the existing environment and its components, effect predictions; an assessment of the significance of effects; and details of proposed mitigation measures.

According to the above-cited legal acts Kazakh EIA (OVOS) process includes the following stages: Pre-OVOS – initial environmental impact assessment that covers preliminary evaluation of possible

impacts of a project considered OVOS – environmental impact assessment including consideration of alternative scenarios Volume OVOS – to be included in the working project of the design documentation. On this stage

mitigation measures to minimise environmental impacts should be developed.

Declaration on the potential environmental consequences shall be issued on the each stage of the OVOS development. Declaration should be included in the documentation for the State environmental expertise review and presented for public hearings.

After the completion of every OVOS stage a project should go through the State environmental expertise.

Statutory and public consultations are expected throughout the preparation of the OVOS. The Kazakh OVOS procedures are broadly similar in most respects to those adopted by international institutions including the World Bank Group. However, there are differences in the scope, methodology and style of the two approaches.



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4.2.4 State and Environmental Expertise

Projects being developed in the Republic of Kazakhstan should go through a process of the State and State environmental expertise review. Main legal acts that regulate the process are, as follows: Law No. 242-II "On architectural, planning and construction works in the Republic of Kazakhstan"

dated July 16, 2001 (as amended 11.04.2014). “Guidelines for the state ecological expertise” approved by Order of the RK Minister of Environment

No. 207-P dated June 28, 2007 (as amended 11.04.2014) of the Republic of Kazakhstan. “Rules of expertise pre-project (feasibility studies) and project (design and estimates) documentation

for construction regardless of the funding source and project approval of construction projects under state investments” approved by Government Decree No.918 dated August 19, 2002 (as amended 12.03.2012) of the Republic of Kazakhstan.

It is required that State Expertise (Review) of all technical design documentation to assess whether the proposed designs meet the appropriate technical and other applicable regulations. Among others, this includes review and compliance of the following aspects: Industrial and occupational safety; Public safety; Environmental protection; Protection of cultural and archaeological heritage; and Fire safety, etc.

Projects receive positive/negative conclusion of State Expertise depending on the information provided.

State Environmental Expertise is carried out for the projects with potential significant environmental impacts and the review stages are following: Analysis of the design documentation provided including feasibility of the planned activity; Introduction of suggestions and comments; and Local representatives of the authorities participate in the documentation review, if necessary.

After the review process the project obtains State environmental expertise conclusion which can be positive, negative or considered that a project requires amendments.

4.2.5 Environmental permits

According to the Environmental Code each project must obtain environmental permits for a project’s

operation in a corresponding authorized environmental body. Environmental permits are obtained on the basis of the information provided and can cover following emissions: Air emissions/ wastewater discharge/ waste disposal apart from air emissions from movable sources Combined environmental permits

Environmental permits are issued as a minimum for three years and maximum for five years.



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Once the facility’s construction and commissioning are underway, permits for wastewater/emissions

discharge and for disposal of waste must be obtained. Together these measures may be viewed as operating as a facility’s ‘environmental permit’. If the environmental procedures described in the

project/design documentation are not observed or other environmental violations are committed, civil, administrative or criminal liability measures may be imposed.

In case of the exceeding of the emission limits being set by environmental permits a company has to pay environmental fees which are described in the following legal act: Code 99-IV “On taxes and other obligatory payments to the budget” dated December 10, 2008 (as

amended 23.04.2014).

4.2.6 Special Economic Zone in Atyrau Province

The territory of the Project is located in the Special Economic Zone (SEZ) “National industrial petro-chemical technopark” of Atyrau Province. The Republic of Kazakhstan has nine Special Economic Zones.

Each SEZ has taxes exemption and a number of privileges regarding workforce employment. The law that regulates SEZ is: Law No. 469-IV “On Special Economic Zones in the Republic of Kazakhstan” dated June 21, 2011 (as

amended on 03.12.2013).

4.2.7 Labour Legislation

The Labour Legal Framework in Kazakhstan is based on the Constitution, the Labour Code and includes other laws and regulations of the Republic of Kazakhstan. The RK labour legislation addresses labour and employment, and any other relations directly related to labour and employment, aims at protecting the rights and interests of all parties, and establishes guaranteed rights and freedoms of workers. It also provides a framework to at balancing the interests of the parties engaged in labour relations with the target for economic growth and welfare.

The main law governing labour, employment and working condition in the country is: Labour Code No.251-III dated May 15, 2007 (as amended on 17.01.2014).

The Labour Code contains provisions that (i) prohibit any restriction of human and civil rights at work; (ii) guarantee freedom of labour; (iii) ban discrimination at work, and any forms of forced labour or the worst forms of child labour; (iv) guarantee the right to safe working environment; (v) set out a priority of individual health and safety to any operational targets; (vi) guarantee the right to fair remuneration; (vii) guarantee the right to rest and leisure; (viii) guarantee equal opportunities for employees; (ix) guarantee the right to associate in trade unions; (x) support social partnership; (xi) define governmental regulation in occupational health and safety; and (xii) establish the right of workers' representatives to control compliance with the labour legislation.

Other key laws that govern labour and employment related issues in the country include: Law No.2107-XII “On Trade Unions” dated April 09, 1993 (as amended on 03.07.2013)



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Law No.149 “On Employment” dated January 23, 2001 (as amended on 13.01.2014) Law No.105-V “On Pension Provision in the Republic dated Kazakhstan” dated June 21, 2013 (as

amended on 31.03.2014) Law No.126 “On Social Disability, Survivorship and Age Social Allowances in the Republic dated

Kazakhstan” dated June 16, 1997 (as amended on 31.03.2014) Law No.405 “On Compulsory Social Insurance” dated April 25, 2003 (as amended on 13.01.2014)

4.3 International Requirements

4.3.1 Overview

The Project is seeking international financing and therefore in addition to meeting national and regional legislation requirements the project is required to demonstrate compliance with international requirements. The following international guidelines are relevant to the Project and have been considered during the ESIA process: The Equator Principles; International Finance Corporation (IFC) Performance Standards on Social and Environmental

Sustainability; IFC Sector Specific EHS Guidelines; Japan Bank for International Cooperation (JBIC) Guidelines for Confirmation of Environmental and

Social Considerations; The European Bank of Reconstruction and Development’s 2008 Environmental and Social Policy

(ESP) and related Performance Requirements (PRs); and Organization for Economic Co-operation and Development (OECD) Recommendation for Common

Approaches;

Further details on these lending requirements are included in the following sections.

4.3.2 The Equator Principles

The Equator Principles III10 (EPs), adopted in the 4th of June 2013, are the latest version of this voluntary set of guidelines designed to manage environmental and social issues associated with Projects subject to project financing11. The EPs were developed by leading financial institutions. As of June 2014, 79 EP Financial Institution’s (EPFI’s) are signatory to the guidelines.

Kazakhstan is defined as a non-designate country by the EPs and as such, for the purposes of project financing in Kazakhstan, the Project is required to demonstrate not only compliance with host country laws but also compliance with all the applicable IFC Performance Standards and supporting EHS Guidelines.

10 The Equator Principles were first adopted in June 2003 by a number of key commercial lenders as a voluntary set of guidelines

developed to ensure that projects under consideration for finance are developed in a manner that is socially responsible and reflective of sound environmental management practice. The Equator Principles apply to all new project financings with total capital costs of $10 million or more across all industry sectors globally.

11 Project financing is a method of funding in which the lender looks primarily to the revenues generated by a single project both as the source of repayment and as security for the exposure.



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4.3.3 International Finance Corporation (IFC)

Project Categorisation

IFC’s Policy on Environmental and Social Sustainability, 2012 requires initial screening and categorisation of each proposed Project to determine the appropriate extent and type of environmental assessment needed. The resulting category also specifies IFC’s institutional requirements for disclosure in accordance

with IFC’s Access to Information Policy. Projects can be placed into one of four categories, depending on the type, location, sensitivity, and scale of the Project, as well as the nature and magnitude of its potential environmental impacts. The different categories are listed in Table 4.1.

Table 4.1: IFC Project Categorisation

Category Description

Category A Business activities with potential significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented.

Category B Business activities with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures.

Category C Business activities with minimal or no adverse environmental or social risks and/or impacts.

Category FI Business activities involving investments in FIs or through delivery mechanisms involving financial intermediation. This category is not applicable to the Project being considered here.

The Project has the potential to cause adverse impacts on the community and on the environment. Therefore this Project is considered to be a Category A project. However, it is considered feasible to mitigate and manage the majority of impacts associated with the Project through appropriate environmental and social management together with the monitoring to be specified in the ESMP and related plans that will be the outcome of this ESIA process.

Performance Standards

The IFC is a member of the World Bank Group and is recognised as an international leader in environmental and social sustainability policy. As a part of the ‘positive development outcomes’ outlined in

the IFC’s Policy on Social and Environmental Sustainability, the corporation applies a comprehensive set of social and environmental Performance Standards in its project review process. In April 2012, the IFC updated its Policy and Performance Standards (PSs) on Social and Environmental Sustainability.

Table 4.2 identifies the relevant IFC Performance Standards and summarises how these have been incorporated into this environmental and social assessment.



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Table 4.2:IFC Performance Standards – Relevance to Project

Performance Standard

Scope and Triggers Action in ESIA

PS1 - Assessment and Management of Environmental and Social Risks and Impacts

PS1 establishes the importance of: (i) integrated social and environmental assessment; (ii) effective community engagement through information disclosure and consultation with local communities; and (iii) the client’s management of social and environmental performance throughout the life of the project.

This report constitutes a social and environmental assessment. Section 6 of the ESIA Report provides an explanation of the consultation and disclosure activities undertaken and planned for the future includes an ESMP included for the management and mitigation of significant environmental impacts.

PS2 - Labour and Working Conditions

PS2 recognizes that economic development should be balanced with workers’ rights. PS2 aims to: establish, maintain and improve the worker-management relationship; promote the equal opportunity of workers, and compliance with national labour and employment laws; protect the workforce by addressing child labour and forced labour; protect vulnerable workers and promote safe and healthy working conditions and the health of workers.

Issues pertaining to labour and working conditions are fully applicable to the Project and undergo assessment within Section 7

PS3 – Resource Efficiency and Pollution Prevention

PS3 recognises that economic activity and urbanization often generate increased levels of pollution to air, water, and land, and consume finite resources in a manner that may threaten people and the environment at the local, regional, and global levels. PS3 aims to: avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing pollution from project activities; promote more sustainable use of resources including energy and water; and to reduce project-related emissions that contribute to climate change.

Issues pertaining to pollution prevention and abatement are fully applicable to the Project and undergo assessment throughout the report.

PS4 – Community Health, Safety and Security

PS4 recognizes that project activities, equipment, and infrastructure can increase community exposure to risks and impacts. PS4 aims to: anticipate and avoid adverse impacts on the health and safety of the affected community during the project life cycle; and ensure that the safeguarding of personnel and property avoids or minimizes risks to the community’s safety and security.

Issues pertaining to community health, safety and security are fully applicable to the Project and undergo assessment within Section 7.

PS5 – Land Acquisition and Involuntary Resettlement

PS5 recognizes that project-related land acquisition and restrictions on land use can have adverse impacts on communities and persons that use this land. PS5 aims to: avoid or at least minimize involuntary resettlement wherever feasible by exploring alternative project designs; mitigate adverse social and economic impacts from land acquisition by (i) providing compensation for loss of assets and (ii) ensuring that resettlement activities are implemented with appropriate consultation and disclosure; and improve or at least restore the livelihoods, standards of living and living conditions of displaced persons.

No involuntary resettlement impacts are envisaged and therefore this SP is not triggered.

Comment to support this conclusion are provided within Section 7.

IPS6 – PS6 encourages sustainable development while Issues pertaining to biodiversity



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Performance Standard

Scope and Triggers Action in ESIA

Biodiversity Conservation and Sustainable Management of Living Natural Resources

recognising that the protection and conservation of biodiversity and sustainably managing living natural resources are fundamental to sustainable development. PS6 aims to protect and conserve biodiversity; to maintain the benefits from ecosystem services; and promote the sustainable management and use of natural resources through practices that integrate conservation and development.

conservation and sustainable natural resource management are fully applicable to the Project and undergo assessment specifically within Sections 10, 11 and 12.

PS7 - Indigenous Peoples

PS7 aims to: ensure that the development process fosters full respect for Indigenous Peoples; anticipate and avoid, minimize or compensate adverse impacts of projects on Indigenous Peoples and provide opportunities for development benefits; establish and maintain an ongoing relationship with affected Indigenous Peoples throughout the life of the project; to ensure free, prior and informed consent of Indigenous Peoples; and respect and preserve their culture, knowledge and practices. s.

There are no groups meeting the IFC definition within the project area of influence, therefore this PS is not triggered.

Comment to support this conclusion are provided within Section 7.

PS8 - Cultural Heritage

PS8 recognizes the importance of cultural heritage for current and future generations. PS8 aims to protect cultural heritage from the adverse impacts of project activities and support its preservation as well as to promote equitable sharing of benefits from cultural heritage.

No issues are anticipated in relation to cultural heritage features. However, potential impacts upon cultural heritage are addressed within Section 16

PS2 on Labour and Working Conditions, PS3 on Pollution Prevention and Abatement, PS4 on Community Health, Safety and Security require reference to be made to the relevant EHS Guidelines; these are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP).

The following EHS Guidelines are considered applicable to the Project: General EHS Guidelines (April 2007) Petroleum-based Polymers Manufacturing (April 2007) Large Volume Petroleum-based Organic Chemicals Manufacturing (April 2007) Thermal Power Plant

Where host country regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to achieve whichever standards are more stringent. If less stringent levels or measures are appropriate in view of specific project circumstances, a full and detailed justification for any proposed alternatives is needed as part of the site-specific environmental assessment.

4.3.4 Japan Bank for International Corporation

Although not confirmed as a lender the environmental and social requirements specified by the Japan Bank for International Corporation (JBIC) have been included for completeness within the ESIA. In



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addition the requirements of the Nippon Export and Investment Services (NEXI) have also been considered throughout the ESIA process.

The JBIC requires that proponents of projects seeking financing undertake appropriate actions to prevent or minimise impacts on the environment and local communities such that unacceptable effects are avoided. The primary document governing JBIC environmental and social lending requirements is ‘Guidelines for Confirmation of Environment and Social Considerations’ (JBIC Environmental and Social

Guidelines) first issued in 2003 with a revised version adopted on 21 July 2009 and further amended in April 2012.

JBIC undertakes a three stage process to confirm adequate consideration of environmental and social considerations: 1. Classifies the project into one of three categories, A, B or C via a screening process. 2. Conducts a review of environmental and social considerations (in the form of an EIA submitted buy

the project proponent) to confirm that requirements are duly satisfied through an environmental review process.

3. Conducts monitoring and follow-up after the funding decision has been made.

Part 1 (4) of the JBIC Environmental and Social Guidelines identifies the applicable environmental and social standards that are required to be achieved and which JBIC will undertake its environmental review against: Host country environmental laws, standards, policies and plans; Relevant aspects of the World Bank Safeguard Policy regarding environmental and social

considerations; and For private sector limited or non-recourse project finance cases or otherwise where appropriate, the

relevant aspects of the IFC Performance Standards.

JBIC also refers to standards established by other international financial institutions and other internationally recognized standards and/or good practices established by developed countries in its environmental review process for benchmarking and reference as required. Environmental checklists are provided for different industry types that detail the environmental and social issues that should be assessed. The environmental checklist of particular relevance to the proposed Project is: Environmental Checklist 8: Petrochemicals. Environmental Checklist 11: Thermal Power Environmental Checklist 16: Roads, Railways and Bridges Environmental Checklist 19: Water Supply; and Environmental Checklist 21: Waste Management and Disposal.

4.3.5 The European Bank for Reconstruction and Development

Project Categorisation

Under the EBRD Environmental and Social Policy (ESP) (latest version adopted on May 7th 2014), EBRD categorises projects as either A / B / C / FI based on environmental and social criteria to: (i) reflect the level



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of potential environmental and social impacts and issues associated with the proposed Project; and (ii) determine the nature and level of environmental and social investigations, information disclosure and stakeholder engagement required for each project, taking into account the nature, location, sensitivity and scale of the Project, and the nature and magnitude of its possible environmental and social impacts and issues.

According to the EBRD ESP, a proposed project is classified as Category A when it ‘could result in

potentially significant and diverse adverse environmental or social impacts and issues which, at the time of categorisation, cannot readily be identified or assessed and which require a formalised and participatory assessment process carried out by independent third party specialists in accordance with the PRs’.

Although the EBRD are not yet involved in the Project and so have not categorised the Project according to their criteria, it is anticipated that it would be categorised as ‘A’ due to the diversity of potentially

significant impacts and therefore would require third party assessment, which this ESIA constitutes

EBRD Performance Requirements

EBRD has adopted a comprehensive set of specific Performance Requirements (“PRs”) that projects are

expected to meet. Furthermore, EBRD is committed to promoting EU environmental standards as well as the European Principles for the Environment (EPE). It is noted that the requirements of the EPE are reflected in the PRs. The following PRs are relevant to this Project: PR1 Environmental and Social Appraisal and Management PR2 Labour and Working Conditions PR3 Pollution Prevention and Abatement PR4 Community Health Safety and Security PR5 Land Acquisition, Involuntary Resettlement and Economic Displacement PR6 Biodiversity Conservation and Sustainable Management of Living Natural Resource PR8 Cultural Heritage.

PR7 on indigenous peoples is not relevant as there are no indigenous peoples affected by the project.

4.3.6 OECD Recommendation on Common Approaches

The OECD aims to promote good environmental and social practice, as embodied within the guidance document ‘Recommendation of the Council on Common Approaches for Officially Supported Export Credits and Environment and Social Due Diligence’ (2012). These ‘common approaches’ contain

environmental and social standards that are applied to officially supported export credits with a view to promoting good practice and achieving a high level of performance as measured against the relevant international standards. The recommendations apply to projects with a repayment term of two years or more.

The key requirements of the OECD Recommendation are broadly in line with the requirements of the Equator Principles and supporting IFC PSs. Table 4.3 identifies the recommendations and summarises how these are satisfied by this environmental and social assessment.



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Table 4.3: OECD Recommendation on Common Approaches– Relevance to Project

Recommendation Scope

Screening and classification of projects

This concerns consideration of all applications for assistance as early as possible in the risk assessment process, as well as categorisation of the project as either Category A (potential for significant adverse diverse, irreversible and/or unprecedented environmental or social impacts), B (potential environmental or social impacts less adverse than those of Category A projects) or C (likely to have minimal or no adverse environmental impacts).

This project is not yet under consideration by OECD. It is categorised as Category A due to the potential for diverse, significant adverse impacts.

Environmental and social review

Determining the need for an ESIA. Category A projects require an ESIA to be undertaken in accordance with international standards (the eight performance standards and EHS Guidelines of the IFC) and host country standards. OECD also has a focus on human rights, labour issues and climate change.

This ESIA meets the requirement for environmental and social review.

Evaluation, decision and monitoring

Members are required to evaluate the information resulting from screening and review, and decide whether to request further information, decline or provide official support; and decide whether this should involve mitigation measures, covenants, monitoring requirements to fulfil prior to, or after the final commitment for official support. In addition, for Category A projects, members may require regular updates to ensure that environmental and social issues are being adequately addressed.

These steps are forthcoming for EP-1000.

Exchange and disclosure of information

For Category A projects, project information and the ESIA should be disclosed as early as possible in the review process and at least 30 calendar days before a final commitment to grant official support. Category A projects should also make available to the public at least annually environmental and social information on projects, for which a Member has made a final commitment with respect to providing official support.

Reporting and monitoring

Members shall monitor and evaluate Category A projects and report to the Working Party on Export Credits and Credit Guarantees on performance and human rights an on-going basis or at a minimum semi-annually.



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5.1 Introduction

In accordance with international requirements for environmental and social assessment, the scope of works for the ESIA includes: Environmental, social, labour, gender, health, safety, risks and impacts; The Project and related facilities; Risks and impacts that may arise for each key stage of the Project cycle, including pre-construction,

construction, operations and decommissioning or closure; Role and capacity of the relevant parties including government, contractors and suppliers; and Potential third party impacts including supply chain considerations.

The ESIA has identified negative and positive, direct and indirect, and cumulative impacts of the Project related to the bio-physical and the socio-economic environment.

The definition of the Project includes all infrastructure and facilities that are directly part of the proposed development or are associated development that exists specifically for or as a result of the Project.

This section presents the key findings of the scoping stage and the general methodology followed to produce this ESIA to meet international standards.

5.2 Scoping Stage

For the first step in the ESIA process, MML produced a Scoping Report (June 2014) that set out the potential environmental and social issues associated with the Project. This was produced using information from the Project Documentation (Stadiya Proyect) and the National OVOS, which was managed by Sinopec and produced by LLP Tetracon Engineering and based on FEED package prepared by Sinopec for the Project, and a scoping site visit undertaken in April 2014.

The scoping report established the scope and methodology of the potentially significant environmental and social impacts from the Project. A summary of the potential environmental and social issues associated with the Project is provided in Table 5.1 and has been based on a review of available documents, the April 2014 site visit and consultations with relevant environmental authorities and local government representatives in Atyrau. The table is intended to be a summary and is not an exhaustive list of potential impacts and risks, some of which were identified during the ESIA process following the Scoping stage. Detailed consideration of all potential impacts has been reported in the subsequent individual assessment sections. It has been considered that decommissioning impacts would be similar in nature to those identified within the construction phase.

5 Assessment Scope and ESIA Process



Table 5.1: Summary of Key Impacts and Risks

Project Aspect Project Phase Potential Impact Summary of Potential Impact

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Social

Employment Generation Construction Employment opportunities anticipated for people in the local area and Kazakhstan more widely will be generated during both the construction and operations phase of the Project.

Operation

Loss of access to grazing land

Construction Livelihoods in the settlements nearest to the Project site are supplemented by keeping livestock such as cattle. Reduction in grazing land is a cause for concern amongst villagers however the impact is not expected to be highly significant due to the availability of other grazing land in the area. Operation

Risk of community conflict Construction Largely as a result of lack of attention from local authorities and un-kept promises made by other companies working in the area members of the local communities feel marginalised and somewhat excluded from the mainstream society of Atyrau. There is the risk of community conflict related to jobs, altered sense of place and lack of inclusion in the Project. Information disclosure and public consultation will be important throughout. A Stakeholder Engagement Plan is being prepared to guide disclosure and consultation activities.

Operation

Risks to occupational health and safety (OHS) and workers’ rights

Construction Generic risks to OHS relate to construction site activities; specific risks for this Project relate to high winds and dust. Effective management and monitoring of safety, working conditions, accommodation and catering will be important.

Operation Risks specific to this Project include handling and transportation of chemicals. Safe working systems and practices will be important for maintaining workers’ health and safety.

Ecology and Biodiversity

12 Cumulative impacts – The combination of multiple impacts from existing projects, the proposed project and/or anticipated future projects that may result in significant adverse and/or beneficial

impacts that would not be expected in case of a stand-alone project. 13 Transboundary impacts – impacts that extend to multiple counties, beyond the host country of the project but are not global in nature. Examples include use of pollution international waterways (any

river or body of surface water that flows through two or more states).




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Habitat Alteration Construction Potential negative impacts on terrestrial ecology and biodiversity of the Project footprint through habitat loss and disturbance during construction phase. This is a result of vegetation cover and possible disturbance of ground nesting birds.

Operation Potential negative impacts on local ecology and biodiversity through air emissions and materials transport to and from the Project.

Water Resources and Hydrology

Abstraction and effects on surface water flow patterns

Construction

Potential temporary or permanent changes to surface water flow and drainage patterns during Project construction

Operation

Potential temporary or permanent changes to surface water flow and drainage patterns during Project operation.

Effluent Discharges and Water Quality

Construction Water quality is at risk of contamination during the construction phase of the project through

mismanagement of wastewater streams and leaks.

Operation There will be no discharges of industrial process wastewater from the Project

Hydrogeology / Ground Contamination

Abstraction and impact of contaminative releases

Construction Potential contamination of soil and groundwater by spills and leaks of fuel and other chemicals.

Operation

Materials and Waste

Waste Management Construction Waste steams produced during construction will primarily be of non-hazardous forms.




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Operation

Potential hazardous waste materials produced across the Project will include spent catalysts, used oils and solvents etc.

Hazardous and non-hazardous waste streams not handled, stored or disposed of in a fashion that is consistent with good EHS practice has the potential to negatively impact Project workforces and the surrounding environment.

Noise and Vibration

Noisy activities Construction

Potential noise impact will come from a range of construction activities, particularly through piling, drilling, excavation works and site vehicle movements. Due to the distance of local sensitive receptors from the various project sites, it is not deemed necessary to carry out a vibration assessment as part of the ESIA.

Cumulative noise impacts from the construction of the Project and other projects in the IPC

Operation

Significant noise impacts during operation phase are not expected to be due to the transmission distance of the project from local sensitive receptors.

Cumulative noise impacts with other projects within the IPC.

Traffic and Transportation

Traffic Movements Construction

During the construction of the Project, large plant items will need to be transported via existing shipping road and rail networks. Cumulative impacts could be experienced if construction schedules of other projects within the IPC overlap.

Operation

Export of materials from the Project site will be done via the new rail spur and existing rail network and using the new road and existing road infrastructure. Cumulative impacts could be experienced depending on the transportation methods of other projects products.

Landscape and Visual

New infrastructure in landscape

Construction

The construction phase of Project may lead to some visual impact on the surrounding area. Given the existing landscape and the nearest sensitive receptors being 6 km away landscape and visual impacts are not considered to be significant and have been scoped out.




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Operation

Infrastructure associated with the Project, such as the stacks and other towers have the potential to visually impact surrounding receptors and landscape setting. Impacts will be minimal given the existing setting that the Project will be located in and therefore are not considered significant and have been scoped out.

Air Quality

Emissions associated with construction and operation

Construction

Construction site plant and equipment often use diesel which leads to the emission of particulate matter (PM10) and oxides of nitrogen (NOx).

Construction traffic can also lead to a temporary increase in local air pollutants in the area surrounding construction activities.

Dust arising from construction activities and vehicle movements and can be mechanically transported off site and has the potential to increase wind-blown dust in the area.

Operation

Emissions from power generation produce a range of air pollutants including NOx, particulates and carbon monoxide (CO). These have the potential to lead to acute and chronic health impacts. They also have the potential to contribute to nutrient nitrogen and acid deposition which can have detrimental impacts on ecosystems and internationally designated sites.

Emissions from process plant and other key equipment such as boilers also will release emissions of NOx, particulates and CO and can also impact upon local air quality.

Greenhouse Gas Emissions

Emissions of greenhouse gases

Construction

Emissions of GHGs will arise from several components, particularly with regards to the ‘embodied carbon’ costs of the materials used during construction, and also the GHG emissions associated with construction phase transportation and disposal activities.

Operation Emissions of GHGs will arise from several components, particularly the energy used in PDH furnaces, the

gas turbines and boilers.

Cultural Heritage

Archaeological and Cultural Construction The archaeological study has confirmed that there are no areas of cultural importance within the IPC




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Heritage Operation although there is still the possibility of uncharted finds when undertaking construction activities outside the IPC.



5.3 Impact Assessment Methodology

5.3.1 Introduction

Following scoping and identification of likely environmental effects, specialist assessments were carried out in order to predict potential impacts associated with the Project and propose measures to mitigate the effects as appropriate. Each assessment chapter (Sections) follows a systematic approach, with the principal steps being: Identification of relevant legislation and guidelines; Description of assessment methodology used and identification of the spatial and temporal scope of

potential impacts (zone of influence); Description of baseline conditions; Impact assessment and determination of significance of the impacts; Identification of cumulative impacts; Identification of appropriate mitigation measures as required; and Assessment of residual environmental effects.

5.3.2 Baseline

Baseline information has been obtained from the Project specific social and environmental baseline studies that have been carried out as part of this ESIA. These studies have been compiled through specifically commissioned surveys, collated from a range of sources including publicly available information and through consultation.

Relevant baseline information used to support the assessment process is referenced / summarised in the relevant impact assessment chapters.

5.3.3 Zone of Influence

The zone of influence (ZoI) indicates where proposed works, including related facilities and infrastructure will have a direct or indirect impact on the physical and social environment. This can result from aspects such as the physical land-take or as a result of the extent of the potential impact that extend beyond the development physical boundary such as noise emissions or emissions to air. The zone of influence can also vary according to the stage of the Project that is being assessed such that construction impacts may have a greater area of impact than for operation.

For each impact assessment chapter the spatial and temporal zone of influence are defined.



5.3.4 Assessment of Effects

5.3.4.1 Overview

The assessment of the significance of effects and identification of residual impacts has taken account of any incorporated mitigation measures adopted by the Project, and is largely dependent on the extent and duration of change, the number of people or size of the resource affected and their sensitivity to the change. The criteria for determining significance are specific for each environmental and social aspect but generally for each impact the magnitude is defined (quantitatively where possible) and the sensitivity of the receptor is defined. Generic criteria for defining magnitude and sensitivity are summarised below.

5.3.4.2 Magnitude

The assessment of magnitude has been undertaken in two steps. Firstly, the key issues associated with the Project have been categorised as beneficial or adverse. Secondly, the magnitude of potential impacts have been categorised as major, moderate, minor or negligible based on consideration of the parameters such as: Duration of the impact - ranging from beyond decommissioning to temporary; Spatial extent of the impact – for instance, within the site, boundary to regional, national, and

international; Reversibility - ranging from permanent requiring significant intervention to return to baseline to no

change; Likelihood – ranging from occurring regularly under typical conditions to unlikely to occur; and Compliance with legal standards and established professional criteria - ranging from substantially

exceeds national standards and limits / international guidance to meets or exceeds minimum standards or international guidance.

Table 5.2 outlines generic criteria for determining magnitude.

Table 5.2: Criteria for Determining Magnitude

Magnitude (Beneficial or Adverse) Description

Major Fundamental change to the specific conditions assessed resulting in long term or permanent change, typically widespread in nature, and requiring significant intervention to return to baseline; exceeds national standards and limits.

Moderate Detectable change to the specific conditions assessed resulting in non-fundamental temporary or permanent change.

Minor Detectable but minor change to the specific condition assessed.

Negligible No perceptible change to the specific condition assessed.

Source: MML



5.3.4.3 Sensitivity

Sensitivity is generally site specific and criteria have been developed from baseline information gathered. The sensitivity of a receptor will be determined based on review of the population (including proximity / numbers / vulnerability) and presence of features on the site or the surrounding area. Generic criteria for determining sensitivity of receptors are outlined in Table 5.3. Each detailed assessment will define sensitivity in relation to their topic.

Table 5.3: Criteria for Determining Sensitivity

Magnitude (positive or negative) Definition (considers duration of the impact, spatial extent, reversibility and ability of comply with legislation)

High Vulnerable receptor (human or terrestrial) with little or no capacity to absorb proposed changes or minimal opportunities for mitigation.

Medium Vulnerable receptor (human or terrestrial) with limited capacity to absorb proposed changes or limited opportunities for mitigation.

Low Vulnerable receptor (human or terrestrial) with some capacity to absorb proposed changes or moderate opportunities for mitigation

Negligible Vulnerable receptor (human or terrestrial) with good capacity to absorb proposed changes or and good opportunities for mitigation

Source: MML

5.3.4.4 Impact Evaluation and Determination of Significance

Impacts will be identified and significance will be attributed taking into account the interaction between magnitude criteria and sensitivity criteria as presented in the significance matrix in Table 5.4.

Table 5.4: Impact Significance Matrix

Magnitude of Impact Sensitivity of Receptors

Negligible Low Medium High

Negligible Insignificant Insignificant Insignificant Insignificant

Minor Insignificant Insignificant Minor Minor

Moderate Insignificant Minor Moderate Moderate

Major Insignificant Minor Moderate Major

Source: MML

For each aspect, the significance of impacts will be discussed before and after mitigation (i.e. residual impact). Impacts identified as having major or moderate significance based on the above approach are classified as significant impacts.

Where feasible the following hierarchy of mitigation measures will be applied to significant impacts to reduce, where possible, the significance of impacts to acceptable levels: Mitigation / elimination through design;



Site / technology choice; and Application of best practice.

For non-significant effects mitigation and good practice measures will be recommended where appropriate.

5.3.4.5 Uncertainty

Any uncertainties associated with impact prediction or the sensitivity of receptors due to the absence of data or other limitations have been explicitly stated. Where applicable, the ESIA will make commitments concerning measures that should be put in place with monitoring and /or environmental or social management plans to deal with the uncertainty. This will be summarised in the Project ESMP that will form part of the ESIA and be implemented through the Project Environment and Social Action Plan (ESAP).

5.3.5 Assessment of Cumulative Impacts

Cumulative impacts are those effects that may result from the combination of past, present or future actions of existing or planned activities in a Project’s zone of influence. While a single activity may itself

result in an insignificant impact, it may, when combined with other impacts (significant or insignificant) in the same geographical area and occurring at the same time, result in a cumulative impact that is significant.

The assessments within this ES have included, where relevant, an assessment of the cumulative impact of the Project with other present developments within in the zone of influence.

The existing and planned developments which have been included in the cumulative impact assessment are: AGIP KCO Karabatan Refinery approximately 16 km south east of the Project The Ethylene and polypropylene plant adjacent to the north boundary of the Project; The Butadiene plant adjacent to the southern boundary; and The plastic bag production plant also adjacent to the southern boundary.

Other existing developments such as the Tengiz oil field and the Atyrau refinery located 150 km and 45 km from the Project respectively have not been considered within the cumulative assessment given their distance from the Project site.

5.3.6 Proposals for Monitoring

Where appropriate, proposals for future monitoring have been put forward within the assessment chapters. These proposals for monitoring have been designed to evaluate the accuracy of the impact prediction and the success of the implemented mitigation measures. All future monitoring has been committed within the ESMP which constitutes part of this ESIA documentation.



6.1 Overview

This Chapter outlines the information disclosure, consultation and participation activities that have been undertaken as part of the ESIA process (in accordance with the Stakeholder Engagement Plan (SEP), July 2014). This Chapter reports the outcomes of these activities, as well as those activities planned for future phases in the lifecycle of the Project.

The Chapter consists of the following sub-sections: Principles of consultation Consultation requirements Stakeholder identification Project consultation activities and outcomes Project grievance redress mechanism

6.2 Principles of Consultation

Early and ongoing consultation, disclosure and meaningful stakeholder engagement are key requirements for projects financed by international lenders. The ESIA is informed by the outcomes of consultation activities that are guided by the SEP initially produced for the Project at the outset of the ESIA process (July 2014).

The Project SEP has been designed to guide public consultation and disclosure activities up to the completion of the ESIA Report and through the construction and operational phases of the Project. It is a strategic document for planning meaningful and appropriate consultation with stakeholders that will be periodically updated as the Project progresses. Stakeholders are defined as persons and entities who are interested in, are affected by, or can affect the outcome of the Project. Specific objectives of the SEP are to provide a consultation strategy for the Project to: Ensure all legal and international finance requirements related to consultation are addressed Involve a full range of stakeholders in the planning of the Project to improve the acceptability of the

Project design, implementation and monitoring Encourage an open dialogue with Affected Communities (ACs) where the Project is located Keep all interested and affected stakeholders informed of project progress Provide a grievance mechanism for ACs to raise complaints that are appropriately addressed by the

Project

The SEP is underpinned by the principles that community engagement should be free of external manipulation, interference, coercion and intimidation and conducted on the basis of timely, relevant, understandable and accessible information. Consultation activities should always be well planned and based on principles of respectful and meaningful dialogue.

6 Information Disclosure, Consultation and Participation



6.3 Consultation Requirements

6.3.1 Overview

This sub-section provides an overview of the international disclosure, consultation and stakeholder engagement requirements of the Equator Principles, IFC, JBIC, EBRD and OECD, and the national requirements contained within the Kazakh EIA procedures. Fulfilling the national requirements will be part of the forthcoming OVOS which is being prepared to address changes to the Project design.

6.3.2 National Requirements

Environmental protection is governed by the Ministry of Environmental Protection (MEP), the Sanitation and Epidemiological Services and the Ministry of Emergency Situations. Issues of environmental protection are primarily controlled by Law No 212-III, the Environmental Code of 2007, which establishes a system of ‘polluter pays’. The Environmental Code describes the regulatory requirements for environmental impact

assessment (OVOS) and pollution control and requires developers to aspire to the highest international standards of environmental and social management for project development. The regulations contain general requirements as to how developers must conduct the OVOS process.

According to the Environmental Code Chapter 7, two types of consultation are required before an OVOS can be completed: review by a state ecological expertise and public ecological expertise. Review by the state expert panel is carried out by the Kazakh State agency responsible for environmental protection and by the local executive board. State bodies are required by the law to respond to the concerns of environmental non-governmental organisations (NGOs).

The RoK has ratified the UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (the Aarhus Convention). The Aarhus Convention requires governments to grant to the public rights regarding access to information on the environment, including information on the environmental impacts of corporate activities. This environmental information should be provided in advance to any affected party.

Accordingly to the legal regulations information disclosure and dissemination, as well as public consultation, are a part of the development process, especially if the project impacts the environment.

The following legislative acts relate to public participation in decision making within Kazakhstan: Environmental Code of RK No. 212-III of 09.01.2007 (as amended on 02.07.2014). Instruction of Environmental Impact Assessment Conduction of Proposed Economical or Other

Activities during Development of Pre-planning, Planning, Pre-design and Design Documentation, approved by Order of Minister of Environmental Protection of RK No.204-p of 28.06.2007.

The Order of the Minister of Environmental Protection of the Republic of Kazakhstan of May 7, 2007 No. 135-p. to replace with the Order of the Minister of Environmental Protection of the Republic of Kazakhstan of March 26, 2013 No. 50-p on Rules on Public Hearing Conduction.



Rules on Access to Environmental Information Relevant to Environmental Impact Assessment (EIA) Procedure and Decision-Making Process on Proposed Economical and Other Activities, approved by Order of Minister of Environmental Protection of RK No.607-p of 03.06.2014. The scale of public consultation and participation in decision-making is dependent on the type and scale of the proposed project and degree of public interest.

6.3.3 International Consultation Requirements

6.3.3.1 Overview

Project finance may be sought from the EBRD and Equator Principles (EqPs) signatory private lenders. This sub-section summarises relevant stakeholder engagement requirements of the EBRD and the EqPs that the Project should meet in order to be considered for international financing. Since the Project is not located in a Designated Country, the Project will have to adhere to the International Finance Corporation’s

(IFC) Performance Standards (PSs) that are referred to within the EqPs. The guidelines of the Organisation for Economic Co-operation and Development (OECD) have also been considered in the planning of stakeholder engagement.

6.3.3.2 The Equator Principles

Equator Principle 5 states that for all Category A projects, there must be effective stakeholder engagement as an ongoing process in a structured and culturally appropriate manner with Affected Communities and, where relevant, other stakeholders. For projects with potentially significant adverse impacts on Affected Communities, the client will conduct an Informed Consultation and Participation process, similar to that required by the IFC Performance Standards.

In order to accomplish this, the environmental and social assessment documentation will be made available to the public by the borrower in the relevant local language (in this case, Russian and Kazakh) and in a culturally appropriate manner. The borrower will take account of and document the process and results of the consultation, including any actions agreed resulting from the consultation. For projects with adverse social or environmental impacts, disclosure should occur early in the environmental and social assessment process and in any event before the project construction commences, and on an on-going basis.

For projects not located within Designated Countries, relevant IFC standards must be adhered to.

Equator Principle 6 requires Category A projects to establish a grievance mechanism designed to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social

performance.



6.3.3.3 The IFC Performance Standards

Public consultation, disclosure and stakeholder engagement are key requirements of IFC’s Policy on

Social and Environmental Sustainability embodied within the Performance Standards (PS) of 2007 (updated in January 2012).

The eight IFC PSs are applicable to private sector projects in emerging markets. Each PS has specific consultation requirements and these are embedded in the general requirements specified in PS 1: Assessment and Management of Environmental and Social Risks and Impacts. These requirements specifically refer to the need for and means of achieving community engagement, disclosure of relevant project information, appropriate consultation processes and grievance mechanisms throughout the project lifecycle. The requirements for stakeholder engagement in projects are: Start as early as possible in the project cycle Continue throughout the life of the project Be free of external manipulation, interference, coercion, or intimidation Where applicable enable meaningful community participation Be conducted on the basis of timely, relevant, understandable, and accessible information in a

culturally appropriate format

IFC PSs seek to provide accurate and timely information regarding Project investment and advisory activities (draft 2010). IFC’s Access to Information Policy states that for Category A projects proposed for

financing, a summary of review findings and recommendations must be disclosed and include as a minimum the following information: Reference to the Performance Standards and any applicable grievance mechanisms, including the

compliance advisor/ombudsman. The rational for IFC’s categorisation of the project. A description of the main social and environmental risks and impacts of the project. Key measures identified to mitigate those risks and impacts, specifying any supplemental measures

and actions that will need to be implemented to undertake the project in a manner consistent with the Performance Standards.

Electronic copies or web-links to any relevant environmental and social impact assessment (ESIA) prepared by the developer.

Any additional documents such as Action Plans, Stakeholder Engagement Plans and Resettlement Action Plans.

6.3.3.4 EBRD Consultation Requirements

EBRD’s Environmental and Social Policy (2014) and Public Information Policy (2014) documents outline the Bank’s key policies regarding information disclosure and stakeholder engagement.

For Category A projects, EBRD requires the project developer to build disclosure and consultation into each stage of the Environmental and Social Impact Assessment (ESIA) process. The developer should also engage with interested parties and identified stakeholders at an early stage to ensure key issues are identified for consideration in the ESIA. During the scoping stage stakeholders should also be provided



with an opportunity to comment on the draft SEP and ESIA scoping documents. Where an Environmental and Social Action Plan (ESAP) is agreed between EBRD and the developer, this must be disclosed to affected parties.

The 2014 EBRD policy requires project developers to engage with stakeholders from the earliest stages and throughout the life of the Project. Stakeholder engagement must be open, meaningful, and conducted in a culturally and linguistically appropriate manner to the potentially affected communities. The engagement program must actively address the needs of vulnerable populations who may be affected by the project. The ESIA documents must remain in the public domain for the life of the Project, and if changes to project plans are necessary, these must be made public as well. A key requirement of EBRD’s

Performance Requirement 10 on Information Disclosure and Stakeholder Engagement is the provision of a grievance mechanism to address concerns and complaints.

EBRD’s Public Information Policy requires ESIA documents to be available through their Business

Information Centre and resident offices as well as their website at least 60 days prior to consideration of the project by the Board of Directors for private sector projects.

6.3.3.5 JBIC Requirements

JBIC’s Guidelines for Confirmation of Environmental and Social Considerations (April 2012) state (Part 2.1)

that for projects with a potentially large environmental impact (Category A projects); sufficient consultations with stakeholders, such as local residents, must be conducted via disclosure of information from an early stage. The outcome of such consultations must be incorporated into the contents of the project plan. Furthermore, appropriate consideration must be given to vulnerable social groups - such as women, children, the elderly, the poor and ethnic minorities - all of whom are particularly susceptible to environmental and social impacts and who may have little or no access to the decision-making process within society.

In addition to consultation and disclosure during the ESIA preparation phase, JBIC has specific disclosure requirements before granting project finance (financial close). The following information must be disclosed on the JBIC website before the signing of a loan agreement: Project name, country, location, an outline and sector of the project, and its category classification, as

well as the reasons for that classification. For Category A and Category B projects, the status of acquirement of the EIA reports and

environmental permit certificates issued by the host government or other appropriate authority and the actual reports themselves.

Of the documents other than (but related to) the ESIA reports, those being made available to the public in the host country are promptly made available on the JBIC website.

After executing an agreement of loan and investment, JBIC provides the results of its environmental review and screening on the website. Regarding the timing of disclosure for screening information, the Environmental Guidelines stipulate that this should be done ‘in a manner that allows enough time before

decisions are made on funding’. Based on this, the information is disclosed as promptly as possible

following a tentative decision on category classification. JBIC states that it is difficult to set a uniform



disclosure period for the ‘screening’ information of projects because JBIC’s involvement in projects occurs

at varying points in the project lifecycle. However, for Category A projects which are likely to have a significant adverse environmental and social impact, JBIC draws on examples of other countries and it aims to disclose information on screening results for approximately 45 days. No disclosure period is set for results of any environmental review.

6.3.3.6 OECD Guidelines

The OECD has guidelines and requirements on information disclosure. Those most applicable to the Project are outlined below: Enterprises should ensure that timely and accurate information is disclosed on all material matters

regarding their activities, structure, financial situation, performance, ownership and governance. This information should be disclosed for the enterprise as a whole, and, where appropriate, along business lines or geographic areas.

Disclosure policies of enterprises should include, but not be limited to, material information on foreseeable risk factors and issues regarding workers and other stakeholders.

Enterprises are encouraged to communicate additional information that could include: – Value statements or statements of business conduct intended for public disclosure – Policies and other codes of conduct to which the enterprise subscribes, their date of adoption and

The countries and entities to which such statements apply – Its performance in relation to these statements and codes – Information on internal audit, risk management and legal compliance systems – Information on relationships with workers and other stakeholders

Enterprises should apply high quality standards for accounting, and financial as well as non-financial disclosure, including environmental and social reporting where they exist.

6.4 Stakeholder Identification

Stakeholders are persons or groups who are directly or indirectly affected by a project, as well as those who may have interests in a project and/or the ability to influence its outcome, either positively or negatively. Stakeholders for the Project include locally affected communities and their formal and informal representatives, national or local government authorities, civil society organisations and groups with special interests, the academic community, or businesses. A stakeholder identification and analysis exercise and identification of the most appropriate communication methods was undertaken at the outset of the ESIA process, the results are shown in Table 6.1.



Table 6.1: Stakeholder identification and analysis

Key stakeholder Group Stakeholders Identified Relevance to the project

Communication and Consultation Methods

Local community groups and organisations

Project affected communities

Residents of:

Karabatan Station (Approx. 100 persons)

Railway Siding 496 (Approx. 200 persons)

Atyrau City (Approx. 168,000 persons)

Could be affected by the Project - in particular in regard to employment opportunities and changes to grazing land.

Meetings in Kazakh/Russian with community representatives in the ESIA phase.

Public consultation event.

Provision of non-technical summary (NTS) of ESIA documentation in Kazakh and Russian.

Ongoing engagement with Community Liaison Officer.

Marginalised and disadvantaged groups

Disabled, elderly and sick people, residents of Karabatan Station and Railway Siding 496.

There is the potential for marginalised groups to be excluded from communications and management measures.

Measures to enable their inclusion in the Project will be identified and implemented. See section 6.5.3.

Project employees and job seekers

Employees and prospective employees (direct/indirect)

Interested in employment opportunities throughout lifecycle of the Project, health and safety issues and in labour standards (including workers’ accommodation standards).

As above

Engagement with Project staff member responsible for workers’ liaison.

Worker grievance mechanism.

Workers’ representatives

Interested in labour standards and workers’ rights.

Provision of NTS.

Engagement with Project staff member responsible for workers’ union liaison.

Annual corporate forum.

Worker grievance mechanism.

Governmental Authorities

Ministry of Environmental Protection and Sanitary Body

Representatives in Atyrau City

Will provide required State Environmental Expertise as part of the OVOS process.

Provision of OVOS documentation.

Face-to-face meetings.

Project contact provided for direct feedback.

Notification of availability of ESIA/OVOS documentation.

Other relevant government departments

Ministry of Labour Forestry and Hunting Inspection of Atyrau Region

Provides oversight to workers’ rights issues.

Can provide information on flora and fauna.



Akimats14 at Province level

Atyrau Province Akimat (local government)

Formal government authorities responsible for the Project area will be interested in the project impacts and



14 Local government





status. Provision of NTS.


Akimats at District and settlement levels

Makatskiy District Akimat

Akimat of Geolog rural district which includes Karabatan and Railway Siding 496

Local government authorities representing local residents and interested in the project impacts and status.



Provision of NTS


Emergency Service Providers

Atyrau City fire, health, police and security services.

Need to be informed about the Project’s progress and possible threats/safety hazards as they may play a crucial role in providing emergency services when required.


Access to website for project documentation.

Non-government organisations and private sector

Non-governmental organisations (NGOs) and Civil society organisations

Arhus Centre

“Caspi Tabigaty”

Environment and Legal Initiative Centre “Globus”

“Arlan”

SPA “Megapolis”

OO “Zaman”

OO “Ayaly Orta”

Youth Association “Nezavisimoye Pokoleniye Kazakhstana”15

KF “Alians Studentov Atyrau”16

Rural Youth Association (Maslikhat) of Atyrau Region

Civil Alliance

NGOs with interests in human rights, environmental conservation or large infrastructure projects.

Interested in impacts of Project and research opportunities.

Potentially stringent observers and commentators.

Depending on mission and understanding of the Project area, could act as a partner in implementing or monitoring.





Business partners and other local suppliers and businesses

Business partners will have an interest in the development of the Project, in particular economically.




Others

Higher education institutions

Interested in impacts of Project and research opportunities.

Will provide candidates for



15 Independent Generation of Kazakhstan

16 Atyrau Students Alliance





employment in the operational phase.

Potentially stringent observers and commentators.

Media Public newspapers

Radio

Television

Interest in the Project’s impacts and status.




The Project team recognises that marginalised and disadvantaged groups are likely to experience impacts differently from mainstream society. For instance, they may be less able to cope with change such as influx of workers into the area than a typical community household or may be less able to take advantage of benefits such as employment generation. Consultation activities will be used to gather information and opinions on how different groups are affected. Consultation and information disclosure activities will take into consideration logistical and cultural factors such as language, physical access, literacy levels, and time availability of these groups. The two settlements in the Project affected area have a common Akim (mayor) and are both considered to be vulnerable and marginalised, although Karabatan Station is generally likely to be more impacted than Railway Siding 496 due to their respective locations (see Figure 2.1). For further analysis, see Section 7.

6.5 Project Consultation Activities and Outcomes

6.5.1 Overview

This sub-section presents the activities undertaken during the Project and the outcomes, and summarises those activities planned throughout the remainder of the Project’s lifecycle in accordance with the SEP and the requirements outlined in Section 6.3. These activities are presented in chronological order in Table A1 in Appendix A, Volume III.

6.5.2 Consultation Prior to ESIA

In July 2012, consultation in relation to the OVOS for the Project was undertaken. This consultation was based on the original project concept which had some slight differences from the Project as it is conceived in May 2014. One of the key differences between the original project and the Project currently proposed is that in the original project KPI were to develop the waste water treatment plant and gas fired power plant, which are now being developed by another company, although they will remain within the confines of the IPC.

On 4 April, 2013, a public hearing for the OVOS was attended by industries, NGOs, mass media representatives and interested parties totalling 83 persons. The meeting was chaired by a representative of



the regional ‘Zhaiyk-Caspian Aarhus Centre’. The key concerns raised and their corresponding responses are detailed in Table A.2 in Appendix A, Volume III.

6.5.3 ESIA Consultation

6.5.3.1 Overarching Approach

All stakeholders, including NGOs and members of ACs, have the right to participate in the ESIA process from the scoping phase onwards. The level of involvement will range from receipt of information and key documents to face-to-face meetings and other methods of feeding back comments and concerns. Local communication channels and public mass media will be used to enable accessibility of information to the greatest number of people. Different forms of media such as phone calls and meetings will be used to communicate information to those with literacy problems.

6.5.3.2 Use of Local Community Representatives

In order to reach members of settlements near to the Project site who do not have access to the internet and are feel excluded from the mainstream society in Atyrau, KPI will liaise with the Akim of Geolog (which is the Akimat that Karabatan Station and Railway Siding 496 belong to) to request his assistance and cooperation in stakeholder engagement activities. The Akim will hold hard copies of project documentation (the ESIA NTS in Kazakh and the SEP, NTS and environment and social management and mitigation tables in Russian) and/or make them available in local public buildings so that when announcements are made in the media villagers can easily access further information. The Akim will also be asked to help coordinate meetings and channel feedback from the communities to the Project via the Community Liaison Officer (CLO). The CLO role is explained further below.

6.5.3.3 Use of Electronic Media

The Project website www.kpi.kz will be used to advertise the availability of ESIA/OVOS documentation, to provide links to the documents on the Project website, and to publish relevant news of interest to the public about the Project.

6.5.3.4 Community Liaison Officer

KPI have identified a Community Liaison Officer (CLO) who will be responsible for community liaison and arranging communications with ACs. The KPI CLO will be constant throughout the Project and will be largely responsible for implementation of the SEP, particularly receiving and channelling comments and concerns during the ESIA phase and management of the grievance mechanism during the construction and operational phases. If KPI’s CLO is to be assisted or replaced by the main contractor’s CLO during

construction ACs will be made aware in advance. The CLO will also attend and record stakeholder engagement activities and maintain lines of communication with the rural Akims.

http://www.kpi.kz/



6.5.3.5 Consultation and Disclosure Undertaken During ESIA Scoping Visit

Table A.3 in Appendix A, Volume III summarises the consultation activities undertaken between 24 and 26 April 2014 during the ESIA scoping phase. It provides an overview of dates, participants and key issues raised. All of these activities were in the form of face-to-face meetings and involved a representative from the ESIA consultant as well as at least one member of staff from KPI.

The objectives of these engagement activities were to: Disclose information the proposed development of the Project Engage key stakeholders by introducing the ongoing feasibility exercise and ESIA process Identify additional key stakeholders Identify concerns and opportunities to be addressed during the ESIA process

A leaflet was prepared detailing the key information about the Project and explaining that a process of stakeholder engagement would be undertaken throughout. A copy of the text of this leaflet is provided in Appendix A, Volume III.

6.5.3.6 Disclosure of SEP

The SEP was disclosed in Russian in July 2014 on KPI’s website (www.kpi.kz) and will remain available online for the lifetime of the Project, subject to updates as necessary.

6.5.3.7 Disclosure of Draft ESIA

The Draft ESIA was disclosed on August 23, ten days prior to the public consultation event, via a newspaper advert published in the local newspaper ‘Prikaspiyskaya Komunna’ which informed readers that

the ESIA had been disclosed on KPI’s website. The scanned copy of this newspaper advert can be found

in Appendix B. Hard copies were also sent to relevant government departments.

6.5.3.8 Draft ESIA Consultation

The public hearing on the Draft ESIA took place on the 2 September 2014 in Atyrau at the Institute of Oil and Gas and was organised by KPI. The information on the date and location of public consultation was brought to the attention of the public via the announcement that was published in the local newspaper.. Letters of invitations were also sent to stakeholders, an example of which is provided in Appendix C.

The public hearing was attended by representatives of KPI, CB&I, Mott MacDonald, government officials, representatives of local administration, NGOs, residents of the settlements of Karabatan Station and Railway Siding 496; a total of 59 people attended. KPI provided transport to the meeting for the residents of the two villages as they are the most severely impacted by the Project and their involvement in consultations is crucial. A comments box was provided at the meeting to allow for anonymous comments to be raised but it was unused. A representative of KPI opened the meeting by presenting the company and providing an overview of the Project. This was followed by a presentation of the Project ESIA by Mott MacDonald.

http://www.kpi.kz/



Local NGOs were active and raised their concerns regarding emissions and the cumulative impacts of the associated facilities of IPC. Mott MacDonald explained that ESIA included the results of air quality modelling that assessed the cumulative impacts in order to evaluate the impact from all the industries to be located in the SEZ (covered in Section 8 of the ESIA). The NGO highlighted that the total emissions of CO2 presented in the ESIA is a considerable amount, Mott MacDonald explained that the design of the Project will enable the minimisation of emissions and that CO2 has no direct impact on human health. In line with the comment on emissions it was noted that the Republic of Kazakhstan signed the Kyoto Protocol ‘On

Climate Change’ and thus is required to reduce greenhouse gas emissions by 15-25 percent from 2020-2050.

Residents of Karabatan Station expressed their concerns about the impact of the Project during the construction phase, in particular related to dust, and explained that the settlement has limited access to public utilities such as gas and the poor quality roads make it difficult to access the city. Residents pointed out that there are 30 registered houses in the settlement and they would prefer to be resettled to the City of Atyrau. Residents also pointed out that the settlement is now locked between industrial sites which adds to their desire for the whole settlement to be resettled. The residents explained that they have faced challenges as a result of unemployment, lack of water and transport links to the city. Employment opportunities at the Project were discussed and KPI expressed the intention to involve local people in the Project through employment. The prospect of social programmes provided for residents of Karabatan Station by KPI was raised (covered in Section 7 of the ESIA).

The Director of Atyrau Institute of Oil and Gas supported the idea of providing jobs for graduates of the institute. The Deputy Mayor of Geolog Rural District enquired about the grievance procedure and roles and responsibilities related to complaints (the grievance mechanism is detailed in Section 6.6 of the ESIA and in the SEP).

NGOs also raised concerns about the statement on the absence of endangered species of fauna and flora in the area and noted that on the adjacent site there is nesting ground of rare birds and tulip fields. Mott MacDonald responded that environmental studies were carried out in May 2014. During visual inspections no endangered species or species listed in the Red Book of the Republic of Kazakhstan were identified. However, the territory near the project is home for rare species of animals and plants as reflected in the report on the environmental studies which is available on KPI’s website. Here one can find rare bird species, such as steppe eagle (Aquila rapax), imperial eagle (Aquila heliacal) and saker falcon (Falco cherrug). Impacts to ecology are covered in Section 11 of the ESIA.

NGOs asked about the financial structure of the Project, namely about interest rates, guarantors and beneficiaries. KPI responded stating who the guarantors were and that the lender banks were undertaking the appropriate due diligence. KPI closed the meeting by stating that the minutes would be published on the company’s website (www.kpi.kz).

Selected photos of the public consultation event are shown in Figure 6.1 to Figure 6.4 below.

http://www.kpi.kz/



Figure 6.1: Public meeting well attended by both men and women

Figure 6.2: Information about the Project displayed on signboards

Source: CB&I Source: CB&I

Figure 6.3: Provision of comments box for anonymous comments

Figure 6.4: Minutes were taken and published on KPI’s

website

Source: CB&I Source: CB&I

6.5.4 Consultation Planned throughout the Lifetime of the Project

The SEP outlines ongoing stakeholder engagement and implementation of the grievance mechanism throughout the construction, operation and decommissioning stages. Activities include communications as necessary with settlement representatives, community consultation events at key project milestones such



as the beginning and end of construction, regular updating of the Project website and social media, updating the SEP and annual sustainability reporting.

6.6 Project Grievance Redress Mechanism

6.6.1 Overview

A grievance can be defined as an actual or perceived problem that might give grounds for complaint. As a general policy, KPI will work proactively towards preventing grievances through the implementation of impact mitigation measures and community liaison.

Anyone will be able to submit a grievance to the Project if they believe a practice is having a detrimental impact on the community, the environment, or on their quality of life. They may also submit comments and suggestions. The sections below consider confidentiality and anonymity and the project’s grievance

resolution process.

6.6.2 Confidentiality and Anonymity

The Project will aim to protect a person’s confidentiality when requested and will guarantee anonymity in

annual reporting. Individuals will be asked permission to disclose their identity. Investigations will be undertaken in a manner that is respectful of the aggrieved party and the principle of confidentiality. The aggrieved party will need to recognise that there may be situations when disclosure of identity is required and the Project will identify these situations to see whether the aggrieved party wishes to continue with the investigation and resolution activities.

6.6.3 Grievance Reporting and Resolution

Grievances will be logged in a formal logging system for which the CLO will be responsible. People may register grievances using the form in Appendix A, Volume III or by contacting the CLO or reporting to their settlement representative. Contact details for the CLO will be included in appropriate project communication materials such as the non-technical summaries.

The CLO will classify grievances according to Table 6.2. Where investigations are required, project staff and outside authorities as appropriate, will assist with the process. The CLO will collaborate with the KPI management to identify an appropriate investigation team with the correct skills to review the issue raised. The investigation will also aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities.



Table 6.2: Grievance Classification Criteria

Classification Risk Level (to health, safety or environment)

Response

Low No or low CLO will conduct investigation, document findings and provide a response.

Medium Possible risk and likely a one off event

CLO and an appropriate investigation team will conduct investigation. The Site Manager or Occupational Health and Safety Manager may decide to stop work during the investigation to allow the corrective preventive actions to be determined. The CLO will provide a response.

High Probable risk and could reoccur

CLO will get the contractor to organise a Major Investigation Team for prompt investigation and resolution. Work may be stopped in the affected area. The CLO will provide a response.

The CLO will explain in writing to the complainant (or where literacy is an issue, orally) the review process, the results, and any changes to activities that will be undertaken to address the grievance and how the issue is being managed to meet appropriate environmental and social management systems. In some cases it will be appropriate for the CLO to follow up at a later date to see if the person or organisation is satisfied with the resolution or remedial actions.

The CLO will summarise grievances weekly during construction and bi-annually during operations removing identification information to protect the confidentiality of the complainant and guaranteeing anonymity. The procedure will be at no cost and without retribution to project affected persons and stakeholders. The procedure for processing grievances is depicted in Figure 6.5.



Figure 6.5: Flowchart for Processing Grievances


During the planning phase of the project, KPI has nominated Balzhan Mukhambetaliyeva as the CLO and point of contact for grievances and comments. Grievances and comments should be sent to the contacts below, where possible by using the form provided in Appendix A, Volume III.

Name Address Telephone Email Website

Balzhan Mukhambetaliyeva 5 Dossorskaya Street, Atyrau City, 060000

7122 306 589 Balzhan.Mukhambetaliyeva@

kpi.kz

www.kpi.kz



7.1 Introduction

7.1.1 Overview of the Assessment

The Chapter looks at how people and communities may be affected as a result of the Project in terms of the way they live, work and interact with one another on a day-to-day basis. The broad objectives of the SIA are to ensure that key potential socio-economic and community impacts have been identified, assessed, mitigated and managed in a consultative and constructive manner. The primary purpose of the SIA is to safeguard the wellbeing of project Affected Communities (ACs) and where possible, bring about a more sustainable and equitable biophysical and human environment as a result of the Project, including sharing of project benefits with local communities wherever possible.

The Chapter includes a description of the methodology and assessment criteria, the socio-economic baseline, assessment of socio-economic impacts, mitigation and enhancement measures and residual significance. It concludes with proposed monitoring and reporting and a statement of significance and compliance. The remainder of this sub-section provides an introduction to SIA and an overview of the SIA approach including definition of the spatial and temporal scope of assessment.

7.1.2 General Approach

The SIA process followed has been one of analysing, monitoring and managing the intended and unintended socio-economic and community consequences - both positive and negative - of the Project, and any social change processes invoked by the interventions.

The Kazakh regulatory requirements for EIA (OVOS) are being addressed in a separate document. The SIA undertaken for this international ESIA has been carried out to meet the requirements of the Equator Principles, IFC, JBIC, EBRD and OECD. The approach and methodology draws on guidance for SIA by the International Association for Impact Assessment (IAIA)17. The IAIA conceptualises social impacts as changes to one or more of the following:

People’s way of life – how they live, work, play and interact with one another on a day-to-day basis. Their community – its cohesion, stability, character, services and facilities. Their culture – their shared beliefs, customs, values and language use. Their environment – the quality of the air and water people use; the availability and quality of the food

they eat; the level of hazard or risk, dust and noise they are exposed to; the adequacy of sanitation; their physical safety; and, their access to and control over resources.

Their health and wellbeing – whereby health is a state of complete physical, mental, social and spiritual wellbeing and not merely the absence of disease or infirmity; perceptions of safety.

Their personal and community property rights – access issues; how people are economically affected and experience personal disadvantage or advantage.

17 International Association for Impact Assessment, Social Impact Assessment: International Principles, May 2003.

7 Social Impact Assessment



Adverse impacts will be avoided and wherever possible, management and mitigation measures have been identified to reduce their effects on the community. Where impacts are beneficial, measures are designed to enhance the effects and share their benefits more widely, in particular amongst local people who may also be affected negatively by the Project.

7.1.3 Spatial Scope of Assessment

The Project site is located approximately 45km north east of Atyrau City in Atyrau Province, in western Kazakhstan. This SIA has used geographical and administrative boundaries18 to define the local and wider zones of influence, respectively19.

The wider zone of influence consists of Atyrau Province and Kazakhstan as a whole, and it is expected the workforce will all come from this within this area. The local zone of influence has been determined from consideration of communities most likely to be affected (the Affected Communities, or ‘ACs’) and includes

the settlement Karabatan Station and the City of Atyrau. The siding Railway Siding 496 is located between Karabatan Station and Atyrau City. The locations of these settlements are shown in Figure 2.1 and photographs of the two settlements are presented in Figure 7.1 to Figure 7.4.

Both of the settlements in the local zone of influence are railway sidings that have developed after railway workers set up homes in close proximity to the stations. Railway Siding 496 translates as ‘Railway Siding

496’ in English. The number 496 denotes the distance in kilometres the settlement is from the origin of the

railway line. The settlements were originally designed as accommodation for workers of the railways but some people have lived in them for 60 or more years and brought up their children and grandchildren there.

7.1.4 Temporal Scope of Assessment

The Project has been assessed by comparing the existing social baseline conditions with the change expected over time as a result of the Project. The temporal scope of assessment includes the following phases of the Project: Site preparation, which was carried out in 2012 Main construction phase, which is expected to commence in summer 2014, lasting up to three years Operation: expected to commence within 2018 Decommissioning: the plant is expected to have a lifetime of at least 25 years and an assessment of

any works necessary to keep the plant operating will be undertaken at that time

18 Kazakhstan’s administrative territories are divided into provinces (or regions, or rayons), of which there are 14 nationally. The

provinces are divided into 170 districts which are further subdivided into cities and smaller settlements which consist of groups of villages.

19 There is a range of characteristics which can be used to define communities in an SIA, including geographical (defined by specific distances measured for example on a metric scale or by walking distance), administrative (defined by local government boundaries), socio-cultural (defined by shared interests, values or bonds such as religion or class status or family) and economic or business (defined by financial interdependencies and relationships).



The social baseline conditions are those assumed to be prevailing immediately prior to the start of site preparation.

Figure 7.1: House and water supply, Karabatan Station Figure 7.2: Shower facility and fuel supply, Karabatan Station

Source: Mott MacDonald Source: Mott MacDonald

Figure 7.3: Villager and house at Railway Siding 496 Figure 7.4: Passing freight train at Railway Siding 496


7.1.5 Structure of Chapter

The remainder of this Chapter is structured as follows: Methodology and assessment criteria Baseline description Assessment of Project impacts and risks Mitigation and enhancement measures



Residual impacts Proposed monitoring and reporting

7.2 Methodology and Assessment Criteria

7.2.1 Overview

This sub-section presents a description of the national legislation and international standards applicable to the SIA as well as the methodology and evaluation criteria used to identify the significance of effects.

7.2.2 National Legislation and Regulations

7.2.2.1 Overview

This sub-section outlines the key legislation of the Republic of Kazakhstan (RoK) applicable to the SIA. The requirements of the RoK are being dealt with in detail within the OVOS, an update to which is being prepared simultaneously with the ESIA explicitly to meet RoK legislative requirements.

7.2.2.2 Labour Legislation

The labour legal framework in Kazakhstan is based on the Constitution, the Labour Code and a number of other laws and regulations of the RoK. The RoK labour legislation addresses labour and employment, aims to protect the rights and interests of all parties, and establishes guaranteed rights and freedoms of workers. It also provides a framework to balance the interests of the parties engaged in labour relations with the targets of economic growth and welfare.

National fundamental labour provisions are set out in Article 24 of the 1995 Constitution of the RoK (as amended on 02.02.2011) Clause One specifies that everyone shall have the right to work, the free choice of occupation and profession and prohibits any form of forced labour. Clause Two confirms the right to safe and hygienic working conditions, fair remuneration. It also prohibits any kind of discrimination, and guarantees social protection against unemployment. Clause Three describes the right to individual and/or collective employment disputes including the right to strike. Clause Four defines the right to rest and leisure, guaranteed length of a working day, days off and holidays, and paid annual leave.

The main law governing labour, employment and working conditions in the country is the Labour Code No.251-III dated May 15, 2007 (as amended on 17.01.2014). The Labour Code contains provisions that (i) prohibit any restriction of human and civil rights at work; (ii) guarantee freedom of labour; (iii) ban discrimination at work, and any forms of forced labour or the worst forms of child labour; (iv) guarantee the right to safe working environment; (v) set out a priority of individual health and safety to any operational targets; (vi) guarantee the right to fair remuneration; (vii) guarantee the right to rest and leisure; (viii) guarantee equal opportunities for employees; (ix) guarantee the right to associate in trade unions; (x) support social partnership; (xi) define governmental regulation in occupational health and safety; and (xii) establish the right of workers' representatives to control compliance with the labour legislation.



Other key laws that govern labour and employment related issues in the country include: Law No.2107-XII “On Trade Unions” dated April 09, 1993 (as amended on 03.07.2013) Law No.149 “On Employment” dated January 23, 2001 (as amended on 13.01.2014) Law No.105-V “On Pension Provision in the Republic dated Kazakhstan” dated June 21, 2013 (as

amended on 31.03.2014) Law No.126 “On Social Disability, Survivorship and Age Social Allowances in the Republic dated

Kazakhstan” dated June 16, 1997 (as amended on 31.03.2014) Law No.405 “On Compulsory Social Insurance” dated April 25, 2003 (as amended on 13.01.2014)

7.2.2.3 Occupational Health and Safety

As an ILO member the Republic of Kazakhstan has ratified a set of ILO Conventions governing occupational health and safety. These include: Labour Inspection Convention, 1947 (No.81) – ratified on 07.05.2001 Working Environment (air pollution, noise and vibration) Convention, 1977 (No.148) – ratified on

26.06.1996 Occupational Safety and Health Convention, 1981 (No.155) – ratified on 13.06.1996 Asbestos Convention, 1986 (No.162) – ratified on 17.01.2011 Safety and Health in Construction Convention, 1988 (No.167) – ratified on 19.06.2007

The RoK Labour Code as detailed in the above sub-section guarantees the right to safe working environment (Article Four) and governs occupational health and safety (OHS) in Kazakhstan (Articles 306-327), including internal OHS monitoring and control (Articles 339-339). OHS issues during design, construction and operation are also considered in the Labour Code (Article 320). The Government of Kazakhstan as set out in the Labour Code (Article 15) is responsible for developing national OHS policy, defining the size of temporary disability benefits and approval of standard Regulations on OHS Unit in an Organisation.

Another key law that relates to health and safety issues of employees in emergencies is Law No.19-I “On

Environmental and Technological Disasters” dated 05.07.1996 (as amended on 13.01.2014). The law sets forth (Article 5) a number of commitments to be taken by an organisation to prevent and in response to emergencies and disasters.



Other key laws related to occupational health and safety in Kazakhstan include: RK Law No.314-II “On Hazardous Industry Safety” dated April 03, 2002 (as amended on 13.01.2014). RK Law No.30 “On Compulsory Insurance against Occupational Injuries and Accidents” dated

February 07, 2005 (as amended on 05.07.2012). RK Law No.414 “On Special Social Allowances for Workers Engaged in Underground and Open Pit

Mining, and Other Jobs with Hazardous and Harmful Working Conditions” dated July 13, 1999 (as amended on 31.03.2014).

7.2.2.4 Community Health and Safety

Community health and safety is an important driver in the national regulation and is governed by a number of laws, sub-laws, regulations, rules and instructions. Public welfare and health are regulated by the following legal acts: Code No. 193-IV "On public health and healthcare system" dated September 18, 2009 (as amended on

11.04.2014). The Code sets forth (inter alia) key 17 principles of the national health care policy (Article Four), public health monitoring and control and general responsibilities of businesses and organisations in preventive measures and public health control (Article 90).

Law No. 188-V "On civil defence" dated April 11, 2014 of the Republic of Kazakhstan. The main objectives of this law are protection of population, environment and facilities management from emergency situations and the consequences caused by them.

Community health and security provisions are also included in other key laws of the Republic of Kazakhstan as listed below: Law No.314-II “On hazardous industry safety” dated April 03, 2002 (as amended on 13.01.2014) Law No.19-I “On environmental and technological disasters” dated July 05, 1996 (as amended on

13.01.2014)

Sanitary Protection Zone (SPZ) regulations which define the buffer zone around installations within which certain activities (such as construction of residential properties) are prohibited are covered within the national OVOS documentation.

7.2.2.5 Security Provision

In Kazakhstan security provisions are apportioned among a number of national laws and regulations governing secure operation of industrial facilities and population security. Key laws and regulations applicable to the sector in general and the Project in particular include resolutions and laws as detailed below.

RoK Government Resolutions: Government Resolution No.1311 on Approving Qualifications Requirements for Some Industrial

Operations (as amended on 29.12.2012) and Licensing Rules for Some Industrial Operations

Key RoK laws: Law No.214-III “On Licensing” dated January 11, 2007 (as amended on 04.07.2013)



Law No.314-II “On Hazardous Industry Safety” dated April 03, 2002 (as amended on 13.01.2014) Law No.19-I “On Environmental and Technological Disasters” dated July 05, 1996 (as amended on

13.01.2014) Law No.48-I “On Fire Safety” dated November 22, 1996 (as amended on 13.01.2014) Law No.87-I “On Emergency Rescue Services and the Life-guard Status” dated March 27, 1997 (as

amended on 10.11.2011)

In summary RoK laws as listed above govern licensing and security arrangements at industrial facilities, including prevention measures and emergency response action, fire security of industries and operations, and interaction between Emergency Rescue Services and organisations in Kazakhstan.

Key RoK general and sectoral regulations: Order №433 “On approving Industrial Safety Regulations issued by the RoK Ministry for Emergency

Situations” dated September 23, 2013 Industrial Safety Requirements for Explosive- and Fire-hazardous Chemical and Petrochemical

Industries and Oil Refineries

7.2.2.6 Land Code

Land Code No.442-II of June 20, 2003 (as amended on 17.01.2014) of the RoK forms a legal framework for land use and land expropriation (for national and public needs) in Kazakhstan. The RoK Land Code defines seven land categories in Kazakhstan and stipulates the legal requirement to land allocation, use and protection. These categories include: (i) agricultural land; (ii) municipal land; (iii) industrial land (including land for transport, communication, space industries, defence facilities, national security land and other non-agricultural land); (iv) protected land (protected natural areas, recreation and health care facilities, historical and cultural sites); (v) forestry land; (vi) water land; and (vii) national land reserve (Article One). The RoK owns all land in the country however private land plot ownership is allowed (Article Three).

Land relations in Kazakhstan are based on 10 key principles (Article Four): Integrity, inviolability and non-exclusion of the territory of the Republic of Kazakhstan Preservation of land as a natural resource, the basis of life and economic activity of the people in the

RoK Protection and sustainable use of land Provision of environmental security Designated land use Priority of agricultural lands Provision of information on the status of land and its accessibility State support to measures for land use and protection Prevention of any damage to land or rehabilitation of damaged land Chargeable land use

The RoK Land Code determines rights, obligations and responsibilities of state authorities in addressing land ownership and protecting rights of landowners and land users (Articles 13-19). It specifies the legal



procedure to compensate damage to landowners, land users and damage to agricultural and forestry industries. The Land Code also defines principles for maintaining land cadastre and land monitoring in Kazakhstan (Articles 149-163). Responsibilities for non-compliance are also defined (Article 168), including procedures for resolution of disputes (Article 167).

The 1994 Civil Code of the RoK (as amended on 07.03.2014) clarifies the essence of land title, land use mandates, defines and protects rights of land owners and users.

7.2.3 International Standards

7.2.3.1 Overview

The SIA has been undertaken to promote the Project’s compliance with the Equator Principles, International Finance Corporation (IFC), World Bank Group Environment, Health and Safety (EHS) Guidelines, Japan Bank for International Cooperation (JBIC), European Bank for Reconstruction and development (EBRD) and Organisation for Economic Co-operation and Development (OECD). Further detail is given on these standards as far as they relate to social sustainability below. Cultural Heritage is covered in Chapter 16.

7.2.3.2 Equator Principles

As discussed in Section 4, Kazakhstan is defined as a non-designated country by the EPs and as such, the Project is required to demonstrate compliance with the all the applicable IFC Performance Standards and supporting EHS Guidelines. Although the latest Equator Principles III, 2013, mention carrying out ‘human rights due diligence’ in limited high risk environments, we do not consider this requirement to apply

to this Project.

7.2.3.3 IFC Performance Standards and Environment Health and Safety Guidelines

At the Scoping stage, a number of IFC Performance Standards (PSs) were considered to be potentially relevant to this SIA, namely: IFC PS1 – Assessment and Management of Environmental and Social Risks and Impacts IFC PS2 – Labour and Working Conditions IFC PS4 – Community Health, Safety and Security IFC PS5 – Land Acquisition and Involuntary Resettlement

All of these are considered to remain applicable. The requirements of these PSs and further details on the reasons why PS7 is considered non-applicable are summarised below.

PS1 – Assessment and Management of Environmental and Social Risks and Impacts

PS1 establishes the importance of: (i) identifying and evaluating environmental and social risks and impacts of the project; (ii) adopting a mitigation hierarchy to anticipate and avoid, or where avoidance is not possible, minimise impacts; (iii) promoting improved environmental and social performance through the



effective use of management systems; (iv) ensuring appropriate response and management of grievances from ACs and external communications from other stakeholders; and (v) promoting and providing means for adequate engagement with ACs throughout the project cycle on issues that could potentially affect them and to ensure that relevant environmental and social information is disclosed and disseminated.

PS2 – Labour and Working Conditions

PS2 recognises that economic development should be balanced with workers’ rights. PS2 aims to:

promote the fair treatment, non-discrimination, and equal opportunity of workers; establish, maintain, and improve the worker-management relationship; promote compliance with national employment and labour laws; protect workers, including vulnerable categories of workers such as children, migrant workers, workers engaged by third parties and workers in the client’s supply chain; promote safe and healthy working conditions and the health of workers; and to avoid the use of child and forced labour.

PS4 – Community Health, Safety and Security

The two key aims of PS4 are to: anticipate and avoid adverse impacts on the health and safety of the AC during the project life from both routine and non-routine circumstances; and to ensure that the safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimises risks to the ACs.

PS5 – Land Acquisition and Involuntary Resettlement

The main aim of PS5 is to avoid, and when avoidance is not possible, minimise displacement by exploring alternative project designs. Where displacement occurs, PS5 aims to avoid forced eviction or where avoidance is not possible, minimise adverse social and economic impacts from land acquisition or restrictions on land use; improve, or restore, the livelihoods and standards of living of displaced persons; and improve living conditions among physically displaced persons through the provision of adequate housing with security of tenure at resettlement sites. PS5 covers situations where informal land users and users of natural resources are affected by restriction on access which is the case in this Project.

PS7 – Indigenous Peoples

Two of the main objectives of PS7 are to: ensure that the development process fosters full respect for the human rights, dignity, aspirations, culture, and natural resource-based livelihoods of Indigenous Peoples; and, anticipate and avoid adverse impacts of projects on communities of Indigenous Peoples, or when avoidance is not possible, to minimise or compensate for such impacts. PS7 has been scoped out of the SIA as there are no Indigenous Peoples meeting the definition in PS7 within the area of influence of the Project and there are no known nomadic groups traversing the Project area20.

20 Information provided by the Sanitary Body of Atyrau



7.2.3.4 IFC Environment Health and Safety Guidelines

PS2 and PS4 in relation to occupational and community health and safety respectively require reference to be made to the relevant IFC Environmental, Health and Safety (EHS) Guidelines. These are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP). The following IFC EHS Guidelines are considered applicable to the Project: General EHS Guidelines (April 2007) Petroleum-based Polymers Manufacturing (April 2007) Large Volume Petroleum-based Organic Chemicals Manufacturing (April 2007)

This SIA outlines mitigation measures aimed to ensure compliance with these guidelines in Section 7.5.

7.2.3.5 JBIC Requirements

Prior to funding a project, JBIC ascertains whether it complies with the relevant aspects of the IFC Performance Standards (PS). Those that are applicable to the Project are discussed earlier in this Section. In addition, where appropriate, JBIC also uses, as reference points or benchmarks, standards established by other international financial institutions, other internationally recognised standards and/or good practices established by developed countries such as Japan regarding environmental and social considerations.

7.2.3.6 EBRD Requirements

The EBRD Performance Requirements (PRs) 1, 2, 4 and 5 describe EBRD’s social policies applicable to this Project. Their full titles are as follows: EBRD PR1 – Environmental and Social Appraisal and Management; EBRD PR2 – Labour and Working Conditions; EBRD PR4 – Community Health, Safety and Security; and EBRD PR5 – Involuntary Resettlement and Economic Displacement.

The EBRD PRs are very similar in content to the corresponding IFC Performance Requirements. As with IFC PS7, EBRD PR7 on Indigenous Peoples has been scoped out as no Indigenous Peoples have been identified in the Project area.

7.2.3.7 OECD Requirements

The OECD provides guidance on human rights which acknowledges the responsibility of States to protect human rights. OECD also requires enterprises to work within the framework of internationally recognised human rights and the international human rights obligations of the countries in which they operate, as well as relevant domestic laws and regulations. This includes: Respecting human rights, which means they should avoid infringing on the human rights of others and

should address adverse human rights impacts with which they are involved. Within the context of their own activities, enterprises should avoid causing or contributing to adverse

human rights impacts and address such impacts when they occur.



Seeking ways to prevent or mitigate adverse human rights impacts that are directly linked to their business operations, products or services by a business relationship, even if they do not contribute to those impacts.

Having a policy commitment to respect human rights. Carrying out human rights due diligence as appropriate to their size, the nature and context of

operations and the severity of the risks of adverse human rights impacts. Providing for or co-operating through legitimate processes in the remediation of adverse human rights

impacts where they identify that they have caused or contributed to these impacts.

The OECD also has guidance on disclosure of information which is summarised in Chapter 6.

7.2.3.8 International Labour Organisation (ILO) Conventions

The International Labour Organisation (ILO) of the United Nations is responsible for overseeing compliance with international labour standards (‘conventions’ that national governments are signatories to).

The ILO conventions reflect common values and principles on work-related issues and Member States can choose whether or not to ratify them. The ILO regularly monitors the implementation and the application of the conventions as well as developments in countries generally, whether or not they have chosen to ratify ILO conventions.

Kazakhstan has been a member of the International Labour Organisation (ILO) since 1993 and has ratified the ILO’s core labour standards which are comprised of eight conventions: Freedom of association and collective bargaining (conventions 87 and 98) Elimination of forced and compulsory labour (conventions 29 and 105) Elimination of discrimination in respect of employment and occupation (conventions 100 and 111) Abolition of child labour (conventions 138 and 182)

Other ILO Conventions related to labour and employment ratified by Kazakhstan include: Employment Policy Convention Tripartite Consultation (International Labour Standards) Convention Employment Service Convention Workers’ Representatives Convention Workers with Family Responsibilities Convention Maternity Protection Convention

7.2.4 Desk Study and Field Reconnaissance

Information for this SIA has been obtained from a number of sources including the OVOS which was initially undertaken in 2013 as part of the work undertaken by Tetrakon on behalf of Sinopec. Further information has been gained through the consultation activities detailed in Chapter 6 as well as through in-depth structured interviews by Mott MacDonald with KPI human resources and environment managers. These sources have been supplemented with widely available literature, data from websites and other official sources of information, including:



Statistics Department of Atyrau Province Akimat of Atyrau Province Statistics Agency of the Republic of Kazakhstan CIA World Factbook World Health Organisation United Nations

7.2.5 Assessing Impacts

This sub-section presents the methodology and evaluation criteria used in the SIA to assess the significance of social effects. Determining the significance of socio-economic and community impacts and their effects has enabled the identification of necessary mitigation and benefit enhancement measures as well as an indication of the related financial costs associated with the social impacts of the Project. Consideration has been given to identification of both potentially beneficial and adverse social impacts. Impacts have been assessed by comparing the quality of the baseline conditions with the predicted quality of the social environment once the project is in place.

The significance of social impacts has been determined through consideration of two concepts: the sensitivity of social receptors (the Affected Communities, or ACs, and Project workers) and the magnitude of impacts upon them. In the context of Kazakhstan, legal standards and established professional criteria for social impact assessment are not readily available. Therefore sensitivity and magnitude have been determined according to professional judgement, and the classifications ascribed are supported with sound reasoning and factual evidence. The use of these two concepts for this SIA is outlined below.

Sensitivity criteria

The sensitivity of receptors has been estimated through consideration of their socio-economic vulnerability, measured by their capacity to cope with social impacts that affect their access to or control over additional or alternative social resources of a similar nature, ultimately affecting their wellbeing. Sensitive or vulnerable receptors are generally considered to have less means to absorb adverse changes, or to replicate beneficial changes to their resource base than non-sensitive or non-vulnerable receptors.

When considering sensitivity the type of resources in question varies between receptors. For example, a community’s vulnerability has generally been measured in terms of its resilience to loss of community facilities, whereas an individual’s vulnerability has generally been considered in relation to their resilience

to deprivation and loss of livelihood assets or opportunities (such as jobs, productive land or natural resources). Impacts that increase impoverishment risks contribute to vulnerability. Impoverishment risks include landlessness, joblessness, homelessness, marginalisation, increased morbidity and mortality, food insecurity, loss of access to common property resources and social disarticulation. Table 7.1 below presents the guideline criteria that have been used to categorise the sensitivity of receptors.



Table 7.1: Sensitivity Criteria

Sensitivity of receptors Definition

High An already vulnerable social receptor with very little capacity and means to absorb proposed changes or with very little access to alternative similar sites or services.

Medium An already vulnerable social receptor with limited capacity and means to absorb proposed changes or with little access to alternative similar sites or services.

Low A non-vulnerable social receptor with some capacity and means to absorb proposed changes and with some access to alternative similar sites or services.

Negligible A non- vulnerable social receptor with plentiful capacity and means to absorb proposed changes and with good access to alternative similar sites or services.


Magnitude criteria

The magnitude of an impact has been determined by consideration of the extent to which it results in social receptors gaining or losing access to or control over socio-economic resources resulting in a beneficial or adverse effect on their individual and collective wellbeing. Wellbeing is considered as the financial, physical and emotional conditions and quality of life of people and communities.

For beneficial impacts, the extent to which local wellbeing is likely to be enhanced has been considered. This is in accordance with the international movement in SIA practice towards an increased focus on enhancing long-term development benefits for local communities’ sustainability, as opposed to only

considering mitigation of adverse effects. As such, the magnitude criteria include consideration of the extent to which benefits are shared with and or realised by local people and communities.

The assessment of magnitude has been undertaken in two steps. Firstly, key social impacts associated with the project and their related beneficial and adverse, direct and indirect, and cumulative effects have been identified. Secondly, the magnitude of impacts and effects have been categorised as either major, moderate, minor or negligible based on consideration of the parameters listed below along with professional judgement: Likelihood Duration Number of people or groups affected Spatial extent

Table 7.2 summarises the typical varying degrees of impact magnitude.



Table 7.2: Magnitude Criteria

Magnitude (beneficial or adverse)

Definition (considers likelihood, duration, number of people affected, spatial extent and local benefit sharing))

Major A highly likely impact that would have implications beyond the project life affecting the wellbeing of many people across a broad cross-section of the population and affecting various elements of the local communities’, or workers’, resilience.

Moderate A likely impact that continues over a number of years throughout the project life and affects the wellbeing of specific groups of people and affecting specific elements of the local communities’, or workers’, resilience.

Minor A potential impact that occurs periodically or over the short term throughout the life of the project affecting the wellbeing of a small number of people and with little effect on the local communities’, or workers’, resilience.

Negligible A potential impact that is very short lived so that the socio-economic baseline remains largely consistent and there is no detectable effect on the wellbeing of people or the local communities’ or workers’, resilience.


7.2.6 Assigning Significance

The significance of an effect has been determined by the interaction between its magnitude, and the sensitivity of receptors affected, as depicted in the significance matrix shown in Section 5. Professional judgement has been used by appropriately qualified social scientists when assigning significance.

7.3 Baseline Description

7.3.1 Overview

Socio-economic data for Kazakhstan, Atyrau Province, Atyrau City and the settlements of Karabatan Station and Railway Siding 496 are outlined below. Where settlement level data and information are presented, it has been sourced through interviews with community members and can be considered as estimated, but valuable, information.

The following sub-sections review available baseline date in relation to: Demography Ethnicity, religion and language Health Access to services Employment and economy Education Governance Project land status and former use Gender Deprivation and vulnerable groups



7.3.2 Demography

The population of Kazakhstan is 17.95 million people (2014) and growing at a rate of 1.17% annually. Figure 7.5 shows that large parts of the population are under 10 years of age and between the ages of 20 and 30 years. The median age of the population is low at 29.7 years21 and population density is amongst the lowest in the world at six persons per square km. The national birth rate is 19.61 births per 1,000 of the population whilst the death rate is 8.31 per 1,000.

Figure 7.5: Population pyramid for Kazakhstan 2014

Source: CIA World Factbook, May 2014

The total population of Atyrau Province is 555,244 (2013)22 and has been growing steadily since 2002 when the population was 447,600. The average population density for the Province is low at 4.7 persons per square km and approximately 51.7% live in rural areas with the rest living in urban areas. The Provincial population is comprised of 49.0% males and 51.0% females. As shown in Figure 7.6 between 2007 and 2010 there were more people arriving in Atyrau Province than leaving but in 2011 this trend reversed and there was net out-migration (-502 persons).

21 CIA World Factbook, retrieved May 2014 22 Demographic annual publication of Atyrau Province for 2013, Statistics Department of Atyrau Province

http://www.atyrau.stat.kz/publ/demograf2013.pdf

http://www.atyrau.stat.kz/publ/demograf2013.pdf



Figure 7.6: Migration in Atyrau Province

Source: Statistics Department of Atyrau Province, Press release 15/02/2012

The total population of Makatsky District is 30,149, all of whom live in rural areas. The population density is slightly greater than for Atyrau Province, at 6.1 persons per square km. Slightly more than half are males (50.1%) and slightly less are females (49.9%). The population of Makatsky District is increasing naturally through a higher number of births than deaths as shown in Table 7.3 below. The City of Atyrau’s

population has increased from 142,500 in 1999 to 167,902 in 200923. Of the two settlements in the local zone of influence, Karabatan Station has 23 households comprised of approximately 200 people and Railway Siding 496 has 20 households and a total estimated population of 200 people24.

Table 7.3: Population data for Makatsky District

Year Births Deaths Natural increase

2010 778 211 567

2011 853 202 651

2012 820 198 622

Source: Statistics Department of Atyrau Province, 2013

23 UNData, http://data.un.org/Data.aspx?d=POP&f=tableCode%3A240, retrieved May 2014 (latest available information) 24 Villager interviews

-2000

0

2000

4000

6000

8000

10000

12000

2007 2008 2009 2010 2011

Arrived Left Balance of migration

http://data.un.org/Data.aspx?d=POP&f=tableCode%3A240



7.3.3 Ethnicity, Religion and Language

During the Soviet Era when Kazakhstan was part of the Soviet Union ethnic Kazakhs were outnumbered by immigrants from Russia and other nationalities. After the fall of the Soviet Union in the early 1990s and through to the mid-2000s large numbers of non-Muslim ethnic minorities departed Kazakhstan and a national programme has repatriated up to a million ethnic Kazakhs back to Kazakhstan. As a consequence, the largest ethnic group is now Kazakh (63.1%), followed by Russian (23.7%), Uzbek (2.8%), Ukrainian (2.1%), Uighur (1.4%), Tatar (1.3%), German (1.1%) and other (4.5%). The out-migration and repatriation programme have also resulted in a reduction in religious diversity and now approximately 70% of the national population is Muslim. The remaining population is made up of 26.2% Christians (mostly Russian Orthodox), 2.8% are atheists and small percentages are Buddhist (0.1%), ‘other’ (0.2%)

and unspecified (0.5%)25.

The ‘state’ language, Kazakh, is spoken by 74% of people nationally whilst Russian, being the ‘official’

language of everyday business and designated the ‘language of official usage’ is spoken by 94.4% of people. In Atyrau Province, a similar percentage of people (92.0%) understand spoken Russian whereas a comparatively larger percentage (95.5%) also speak Kazakh. There are a large number of nationalities living in Atyrau Province, partly due to the oil and gas industry which attracts foreign workers. The main nationalities present are shown in Table 7.4.

Table 7.4: Nationalities present in population of Atyrau Province and Makatsky District

Nationality Atyrau Province Makatsky District

Kazakhs 509,113 29,417

Russians 33,655 469

Ukrainian 781 9

Korean 3,121 5

Tatars 2,333 35

Germans 467 8

Bulgarians 243 3

Uzbeks 1,245 75

Azerbaijanis 446 1

Belarusians 211 1

Armenians 319

Karakalpakians 486 35

Dargins 260

Chechens 170

Total 552,850 30,058


25 Statistics Agency of the Republic of Kazakhstan, Population Census 2009 http://yka.kz/_ld/0/55_perepic_2009.doc

http://yka.kz/_ld/0/55_perepic_2009.doc



The settlements in the local zone of influence of the Project, Karabatan Station and Railway Siding 496, are made up almost exclusively of Kazakhs with the exception of one person who is a Tatar in Karabatan Station. The preferred language of communication in both settlements is Kazakh.

7.3.4 Health

Life expectancy in Kazakhstan is significantly different for men and women. Females are expected to live 75.17 years whereas for men the life expectancy is only 64.98. At 3.9% of GDP, health expenditure is amongst the lowest in the world.

The estimated adult prevalence rate for HIV/AIDS is low, at 0.1%21 however since 1987 in Kazakhstan there has been an increase in new HIV infection cases every year other than 2009. Kazakhstan has 189 cases of tuberculosis per 100,000 (2013 data), which is higher than the global average of 16926 and is a serious public health issue in the country.

Kazakhstan is a known risk area for an outbreak of bubonic plague and there are four plague sources in Atyrau Province. The main plague carriers are gnawing animals and the main transmitters are their fleas. Each plague source has its own features and characteristics and the Integrated Petrochemical Complex is within the territory of the Uralo-Embinsky desert source of plague. This source is located between Ural and Emba rivers in Atyrau Province. Epizootics27 occur mainly from March to November and in previous years there have been many plague sources in the Project site area. In the period between 1970 and 2013, 24 epizootic cases of plague were registered in the Project area however from 1994 onwards the epizootic activity has been decreasing and currently the plague source is in the weak activity phase. Twice annually the authorities carry out epizootic checks. No plague cases have been detected in the Project area since 2004 however the risk has not been completely eliminated.

Common causes of illness in Atyrau Province are shown in Table 7.5. The most common problems relate to respiratory diseases, diseases of the blood, circulatory system diseases, digestive diseases, diseases of the genitourinary system and injuries/poisoning. Healthcare for the settlements of Karabatan Station and Railway Siding 496 is provided centrally in Atyrau and is a taxi ride28 or ambulance away.

26 WHO Kazakhstan Health Profile, http://www.who.int/gho/countries/kaz.pdf?ua=1, retrieved May 2014 27 Epizootic is when the disease appears in new cases in animal populations and spreads rapidly, similar to the word ‘epidemic’ for

human populations 28 Reported by a villager to be 3,000 Tenge to Atyrau City and back (approximately USD 16.35 as of June 2014)

http://www.who.int/gho/countries/kaz.pdf?ua=1



Table 7.5: Morbidity in Atyrau Province

Name 2008 2009 2010 2011 2012

Infectious and parasitic disease 4,848 4,458 4,869 4,311 4,286

Neoplasms (cancers) 747 736 999 798 821

Diseases of the blood and blood-forming organs and certain disorders involving the immune system

11,085 12,585 12,743 12,993 12,039

Endocrine diseases, disorders related to nutrition and metabolism

3,314 3,909 3,050 2,993 3,280

Mental disorders and behavioural disorders 170 256 371 377 371

Substance abuse disorders 2,298 2,227 2,449 2,761 2,968

Diseases of the nervous system 5,414 7,253 7,362 7,469 6,770

Diseases of the eye and its appendages 6,397 8,029 9,815 9,049 9,256

Diseases of the ear and mastoid process 6,967 6,542 6,441 6,024 6,055

Circulation system diseases 10,373 9,396 10,041 11,967 11,932

Respiratory diseases 55,800 60,058 58,726 61,794 60,263

Digestive diseases 10,351 12,453 9,550 10,171 10,776

Diseases of the skin and subcutaneous fibre 7,162 8,238 6,186 6,943 7,301

Diseases of the musculoskeletal system and connective tissue

2,734 2,520 2,585 2,939 3,000

Diseases of the genitourinary system (STIs) 6,791 7,454 6,897 9,114 9,290

Complications of pregnancy, childbirth and the postpartum period

5,301 4,512 6,037 5,304 4,900

Congenital anomalies (defect development), and strain chromosomal abnormalities

392 544 520 712 558

Injury and poisoning 9,690, 10,551 10,914 11,680 12,859


7.3.5 Access to Services

In urban areas of Kazakhstan 98.7% of the population benefits from an improved drinking water source whereas in rural areas the percentage is lower at 90.4%. Approximately 97% of the population has improved sanitation facilities29. In Karabatan Station and Railway Siding 496 water is piped into the settlements from Atyrau and available from a central location (Figure 7.7). Showers and toilets are located in separate blocks from homes and consist of rudimentary communal structures for showers and long-drops for toilets (see Figure 7.2 and Figure 7.7). The settlements have an electricity supply but neither settlement is connected to the gas supply and residents use scrap wood provided free of charge by nearby companies for heating.

29 An improved drinking water source is defined as a type of drinking water facility or water delivery point where the drinking water

source is protected from external contamination. An improved sanitation facility is defined as one that hygienically separates human excreta from human contact. Data from CIA World Factbook.



Figure 7.7: Toilet in Karabatan Station


7.3.6 Employment and Economy

Kazakhstan is categorised by the World Bank as an upper middle income country. Gross Domestic Product per capita is £14,100 and ranked 96th in the world. GDP is growing at approximately 5% per year and services are the main contributor to (56.9%); industry makes up 37.9%; whilst agriculture generates 5.2% of GDP. Kazakhstan has large fossil fuel reserves as well as abundant supplies of other minerals and metals including uranium, copper and zinc. Important elements of the agriculture sector are livestock, spring wheat and barley. The total labour force is approximately 9.022 million persons, of whom 5.3% are unemployed. Table 7.6 shows the male and female workforce participation as a comparison between 1999 and 2009. It shows that the most increase in female participation has been in rural areas where it has increased from 36% to 43% of the workforce in ten years.

Table 7.6: Male and female workforce participation

Men Women

1999 2009 1999 2009

No. % No. % No. % No. %

All population

2,428,080 58% 3,617,960 55% 1,760,361 42% 2,981,536 45%

Urban 1,316,764 54% 1,926,079 53% 1,135,350 46% 1,722,560 47%

Rural 1,111,316 64% 1,691,881 57% 625,011 36% 1,258,976 43%

Source: Statistics Agency of the Republic of Kazakhstan, Population Census 2009



Unemployment in Atyrau Province has decreased from 27,500 (approximately 13.5%) to 14,500 people (5%) in the years between 2001 and 201230. During the same period average monthly wages for all sectors have increased five-fold from 35,500 Tenge to 180,500 Tenge. Atyrau City is well known for its fishing industry although it is now in decline due to over-fishing. Atyrau City is also the energy capital of Kazakhstan and 50,000 new jobs have been generated in the city over the last decade, largely due to the oil and gas industry31. Oil production in Kazakhstan totalled 26.6 million tonnes in 2009 and 30.1 million tonnes in 2010 whilst 11.9 billion m³ of gas were produced in 2009 and 13.8 billion m³ in 2010.

In the settlements of Karabatan Station and Railway Siding 496 the main sources of income for households are paid work on the railway and at Karabatan oil refinery. Incomes in Karabatan Station are supplemented by keeping cows for subsistence which are allowed to roam freely on the steppe. Interviewees stated that grazing land is decreasing in area due to the proliferation of projects in the vicinity of the settlement. In Railway Siding 496 people keep cows, goats and horses, mainly for subsistence although two households reportedly sell cows’ and goats’ milk. The quality of grazing land in the

settlement’s surroundings is stated to be poor and animals traverse the train track and nearby road to compensate (see Figure 7.8 and Figure 7.9).

Figure 7.8: Goats grazing at Railway Siding 496 Figure 7.9: Grazing land at Railway Siding 496


7.3.7 Education

Kazakhstan achieved Millennium Development Goal Two to provide universal primary education in 2005. Further, Kazakhstan has also made progress in ensuring universal secondary education however unresolved issues related to educational policies, quality of education, human resources capacity and the

30 Statistic Department of Atyrau Province, http://www.oblstat-atyray.kz/din_ryad/4.doc, retrieved April 2014 31 World Energy Cities Partnership, http://www.energycities.org/Atyrau-Kazakhstan, retrieved May 2014

http://www.oblstat-atyray.kz/din_ryad/4.doc

http://www.energycities.org/Atyrau-Kazakhstan



financing of education remain32. In Atyrau Province there are a total of 130 preschool establishments, most of which are provided by the State, as shown in Table 7.7, and 204 secondary schools, only three of which are private as shown in Table 7.8. In general State provided schools are much larger in terms of numbers of pupils than private schools.

Table 7.7: Preschool Education in Atyrau Province

State Private Total

Number of schools 116 14 130

Number of pupils 22,234 446 22,680

Average No. Pupils per school

192 32 174

Source: Akimat of Atyrau Province, 2013

Table 7.8: Secondary Education in Atyrau Province

State

Private Total Rural Urban

Number of schools 137 64 3 204

Number of pupils 48,426 46,469 341 95,236

Average no. pupils per school

353 726 114 1193


Sixty-two settlements in Atyrau Province do not have educational establishments and children are transported to nearby schools by bus. Children from Karabatan Station and Railway Siding 496 are transported by bus for several days at a time to schools outside of the settlements because there are no schools or kindergartens there.

7.3.8 Governance

In Kazakhstan, provinces are headed by an Akim (governor) appointed by the president. At the municipal level, the Akim is appointed by the provincial Akim. Smaller settlements made up of several settlements are also headed by Akims. The two settlements in the Project’s local zone of influence belong to the same Rural Settlement called ‘Geolog’, and have a common Akim who is the head of this settlement.

7.3.9 Project Land Status, Land Use and Ecosystem Services

The land needed for the PDH and PP plants is within a Special Economic Zone (SEZ) created by the Government of Kazakhstan on steppe land just outside of the City of Atyrau. The land is owned by the State (Atyrau Provincial Government) and has been leased to KPI for the purposes of the Project. All of the land inside the SEZ has been fenced off and the part needed for the PDH and PP plants has been cleared

32 UNDP, http://www.undp.kz/en/pages/9.jsp, retrieved May 2014

http://www.undp.kz/en/pages/9.jsp



of vegetation and levelled. The land, whilst being owned by the State, was previously informally used by people living in Karabatan Station settlement for grazing their animals. Aside from animals grazing the steppe, there are no other known uses of ecosystem services by communities on the land needed for the Project (water is piped as detailed in Section 7.3.5).

There are a number of associated facilities needed by the Project for which land has also been leased to KPI by the State (Atyrau Provincial Government). The total area of land needed for the Project is 859.37ha; 147.6ha for the Project itself and 711.77ha for associated facilities. A summary of the former use of this land is provided within Table 7.9.

Table 7.9: Land Summary Table

Project feature Area of land needed (ha)

Inside SEZ

Lease number

Start date of lease

End date of lease Former use

PDH and PP Plant (includes WWTP and gas turbines)

147.60* Yes 203941 28.06.2012 31.12.2032 Informal grazing

Associated Facilities

Wastewater Treatment Plant 9.00 Yes 203941 28.06.2012 31.12.2032 Informal grazing

Gas turbines 9.00 Yes 203941 28.06.2012 31.12.2032 Informal grazing

Zavodskaya Rail Station 95.93 Yes 203938 28.06.2012 31.12.2032 Informal grazing

Rail spur 17.04 Partly 203931 28.06.2012 31.12.2032 Informal grazing

Access road 15.78 Partly 203936 28.06.2012 31.12.2032 Informal grazing

Karabatan Rail Station connection

1.16 No 203942 30.07.2012 30.07.2014 Unused

Evaporator pond 375.02 No 203940 28.06.2012 31.12.2032 Informal grazing

Workers' accommodation (may not be used)

38.00 No 203965 03.07.2012 31.12.2032 Informal grazing

Water pipeline connection 91.01 No 203932 28.06.2012 31.12.2032 Assumed as Informal grazing

Natural gas pipeline connection

59.83 No 203934 28.06.2012 31.12.2032 Assumed as Informal grazing

Total area of land needed 859.37

Source: KPI * 165.6ha of land has been leased under lease number 203941; 9ha of this will be sub-leased to another developer to build and operate the WWTP and a further 9ha will be sub-leased to the gas turbines developer

7.3.10 Gender

Whilst Millennium Development Goal Three on eliminating gender disparity in education has been achieved in Kazakhstan, it should be noted that there remain significant disparities between men and women in the country. The findings of the Gender Gap Index 2013 indicate that women’s health in Kazakhstan is generally better than men’s and that women participate in the workforce and have

opportunities. However, poor rankings were received for educational attainment and political



empowerment33. Unemployment rates among women (6.2%) are higher than for men (4.6%)34 and there are particular gender disparity challenges faced by rural Kazakh women including traditional patriarchal values, greater poverty and fewer opportunities35 for women than in urban areas. In rural settlements household roles tend to be gender-defined with women undertaking most of the cooking and cleaning whilst men more often tend to livestock. Gender roles are clearly defined in both Karabatan Station and Railway Siding 496, where it is generally the men who go out to income-earning jobs and the women look after the home and dependents.24

7.3.11 Deprivation and Vulnerable Groups

The percentage of the population living under the national poverty line in Kazakhstan has decreased significantly in the past decade, from 33.9% in 2004 to 3.8% in 201236. Whilst gains have been made some sections of the population are better off than others, for example inhabitants of rural areas have largely been left behind progress made in standards of living in oil and gas cities. In terms of groups that are particularly vulnerable to Project impacts, the residents of the rural Karabatan Station have been identified as belonging to this category due to their challenging living conditions.

Residents of rural Railway Siding 496 are also identified as vulnerable due to their living conditions. However Project impacts are not expected to be felt as strongly as the settlement is further away. Amongst the reasons for identifying Karabatan Station - and to a lesser extent Railway Siding 496 - as being vulnerable, are: lack of improved sanitation; lack of social services and infrastructure such as healthcare, schools, gas supply and shops; and the informal use of State land for grazing. There are also perceptions, identified through consultation, amongst villagers at Karabatan Station that they are excluded from mainstream society and that State entities do not take responsibility for their welfare.

Women are identified as having increased vulnerability to Project impacts due to pre-defined gender roles. This limits their ability to take advantage of Project benefits such as employment, and to influence or take part in discussions about the Project. More generally other vulnerable groups amongst the local population who, individually, may or may not be impacted by the Project, include the unemployed, the sick, the elderly, the disabled and children.

33 World Economic Forum, 2013 34 UN Stats, http://unstats.un.org/unsd/demographic/products/socind/default.htm, retrieved May 2014 35 Stop Violence Against Women, http://www.stopvaw.org/kazakhstan, retrieved May 2014 36 World Bank, http://data.worldbank.org/indicator/SI.POV.NAHC/countries/KZ?display=graph, retrieved May 2014

http://unstats.un.org/unsd/demographic/products/socind/default.htm

http://www.stopvaw.org/kazakhstan

http://data.worldbank.org/indicator/SI.POV.NAHC/countries/KZ?display=graph



7.4 Assessments of Project Impacts and Risks

7.4.1 Overview

This Section identified the expected social impacts expected to occur as a result of the Project and assesses their beneficial and adverse. Impacts have been considered and assessed for the construction, operation, and decommissioning or rehabilitation phases of the Project. Mitigation and benefit enhancement measures are proposed in Section 7.5.

7.4.2 Construction Phase Impacts

7.4.2.1 Employment Generation

The main construction phase is expected to take place between 2015 and 2017. Throughout this period the average number of workers is expected to be 1,500 and during the peak time of summer 2016 it is expected that up to 2,500 will be needed (see Figure 2.7). During the summer months it is likely that there will be a two shift pattern with workers doing up to a maximum of 11 hours per day. Workers will work on rotation for 28 days on and 28 days off. Workers are expected to be housed either in existing or new purpose-built temporary accommodation nearby, although plans have not yet been finalised. There are a number of existing camps in the area set up for previous projects with a capacity to house up to 8,000 workers at one time.

Whilst there is a local content law in Kazakhstan requiring companies to hire a certain percentage of Kazakh workers (variable depending on the Project) an exception has been granted for the SEZ in order to encourage economic development. There is known to be a shortage of white collar Kazakh workers, hence the Government of Kazakhstan has opened up its borders to workers of this type from Russia and Belarus to help address the shortage. It is not known at this stage where the majority of labourers and semi-skilled workers will be sourced from as this may in part depend on the origin of the main contractor. However consultation with the City of Atyrau Akimat revealed that it has carried out an assessment of the Project’s

workforce requirements, and that the Kazakh workforce will be able to meet the requirements of all except for the design elements of the Project. The Akimat representative also indicated that priority will be given to workers from Atyrau via a Memorandum of Understanding it expects to sign with KPI’s contracting parties.

Furthermore, social unrest may arise if jobs are seen to be given to outsiders over local people from Atyrau and Kazakhstan.

In conclusion, temporary employment generation in the construction phase of the Project has the potential to stimulate the local economy through the provision of income to workers. This includes the opportunity for vulnerable local unemployed people, especially those from Karabatan Station and Railway Siding 496 settlements, to benefit.

Local jobseekers are therefore on the whole considered to be of medium to high sensitivity to employment generation impacts. The magnitude of the impact is considered to be minor as it is certain to occur, but it



will be a temporary impact that will affect a relatively small number of local people. The impact is therefore considered to be a minor beneficial impact to the local population.

7.4.2.2 Loss of Access to Grazing Land

Approximately 708ha of land that is periodically used for grazing by livestock owners from Karabatan Station and possibly Railway Siding 496, will be permanently lost to the Project and its associated facilities. There will also be a temporary loss of 150 ha of land in the pipeline laying corridor during pipeline construction. The pipeline will be laid underground. There will not be any physical displacement as a result of the Project because no-one was or is living on any of the land needed for the Project and no privately owned land has been or will be affected. The loss of access to state-owned grazing land is the only known displacement effect and it is considered here primarily in relation to ecosystem provisioning services37.

The impacts on ecosystem services have been assessed using the World Resources Institute’s (WRI)

methodology38. Table 7.10 below shows our findings.

Table 7.10: Identification of Priority Ecosystem Services

Identification criteria Assessment

Will the Project change the quality or quantity of the service?

Yes, the Project will reduce the quantity of grazing land available. This impact is also cumulative with other projects in the area.

If yes, will the change in quality or quantity affect users significantly, for example by tipping it over a threshold, or making demand outstrip supply, or changing perceptions about availability

Yes, the reduction in grazing land is already perceived by villagers in Karabatan Station.

If yes, is the service important for livelihoods, health, safety or culture?

Yes, the availability of grazing land is important for livelihoods and nutritional health of households keeping livestock for subsistence and income-earning purposes. However the main source of income in Karabatan Station and Railway Siding 496 is from paid work on the railway and nearby oil refinery.

If yes, are affordable and viable alternatives available? There is a large amount of steppe that can be used freely by villagers for grazing their animals and the local government is reportedly developing plans to formalise grazing areas which should improve recognition of the issue and provide more certainty regarding availability of grazing land in future years.

Source: Mott MacDonald, adapted from WRI

As all four criteria should be fulfilled in order for the service to be designated as a priority service, the availability of grazing land is not considered to be a priority ecosystem service and therefore the need for the Project to mitigate impacts on it are limited.

37 IFC PS5 and EBRD PR5 related to Land Acquisition and Involuntary Resettlement cover risks and impacts resulting from change in

land use, land acquisition and leasing and involuntary resettlement. The lenders’ standards apply in situations where there is a restriction of access to land, assets or other natural resources such as grazing areas. Therefore, IFC PS5 and EBRD PR5 are considered to be triggered by the Project. However the impact of lost access to grazing land is limited due to the availability of alternative grazing land.

38 ‘Weaving Ecosystem Services into Impact Assessment’, World Resources Institute, October 2013



The sensitivity of villagers at Karabatan Station to lost access to grazing land is low because they have alternative income sources and alternative land is available. The magnitude of the impact is minor to moderate as it affects a small number of people but is effectively permanent. The overall effect is expected to be a minor adverse effect. Impacts may be felt more by women in the community, because men are likely to have greater control over their incomes generated from paid work. Recommendations for community investment to offset adverse impacts which are likely to be felt but may be challenging to avoid or minimise are discussed in Section 7.5.

7.4.2.3 Disturbance and Altered Sense of Place

For the community at Karabatan Station there will be a number of nuisance and disturbance impacts during the construction phase. One key such impact is likely to be dust, which is known to have caused issues during the Project’s site preparation phase in early 2014. The construction of the rail spur 36 metres from the nearest houses in Karabatan Station has also caused dust and noise impacts (dust impacts are discussed further in Section 8 on air quality). There will also be increased rail movements during construction for the transportation of materials.

There will also be cumulative impacts with other projects in the area related to a change in the sense of place. This which was identified by villagers at Karabatan Station as a concern. Other projects which are already in the vicinity of the settlement had previously promised that the settlement would be resettled. Whilst this has not occurred, it has left an enduring desire for resettlement away from the settlement to somewhere with improved services and out of the industrial zone. The industrialisation of the locality, construction activities and poor relationships with previous projects could lead to deterioration in physical and mental wellbeing of community members.

The sensitivity of residents of Karabatan Station to disturbance and altered sense of place is high as they cannot move away. Some construction impacts may be experienced but will be temporary, whilst the industrialisation of the settlement’s surroundings is effectively permanent. The overall magnitude is therefore considered to be moderate, and the effect is considered to be moderate adverse and is therefore significant.

7.4.2.4 Localised Economic Development

During the construction phase KPI’s contracting parties will need to purchase materials, equipment and services for the Project, thereby creating business opportunities for suppliers. These opportunities will provide economic benefits to suppliers, especially to those who receive longer term contracts. For example, workers’ accommodation supply companies may have contracts throughout the construction phase. This may also be the case for worker transportation, catering, security providers, or providers of construction materials and plant. If these contracts are provided to local and Kazakh companies, as is anticipated, this could help to stimulate the local economy. There are other local businesses, such as a restaurant and a hotel which is under construction near to the Project site and hotels within the City of Atyrau, which are also likely to benefit from increased business during the planning and construction phase.



Overall, the procurement of goods and services by the Project will be a beneficial impact to suppliers, which are considered to be of low sensitivity as they are likely to have access to similar opportunities. The magnitude of this impact is considered to be minor to moderate as it will be largely restricted to the construction phase. Therefore, there is predicted to be a minor beneficial effect.

7.4.3 Operational Phase Impacts

7.4.3.1 Employment Generation and Skills Development

Employment generated during the operational phase will mainly be permanent, of a longer term nature and at a smaller scale than in the construction phase. Once operational, it is expected that approximately 400 workers will be employed. 290 of the positions are expected to be technical or physical roles and 110 will be managerial and administrative. The jobs will generally be for workers of a medium to high skill level.

KPI plans to staff the majority of operational personnel from within Kazakhstan, however staff are likely to originate from outside of Atyrau City due to a shortage of the requisite skills. As of June 2014, KPI has commenced training for some of the operational staff in other petrochemicals facilities in country. The remainder of the required staff are likely to be sourced, if required, from outside of Kazakhstan. As well as maintaining or improving the wellbeing of the staff employed and their families, the creation of these jobs will contribute to the development of specialist skills and experience within the local population.

The existing workforce is considered to be of medium sensitivity, as although unemployment is relatively low in the local area, there are people out of work and workers who may be looking for opportunities to move to alternative employment.. The magnitude of the impact is moderate, as the creation of 400 jobs is a sizeable contribution to the job market and the operational jobs will be long-term. The employment generation from the operational phase of the Project is considered to be a moderate beneficial effect, and is therefore considered to be significant. .

7.4.4 Decommissioning Phase Impacts

7.4.4.1 Employment Creation

If there is a period of rehabilitation works, a number of temporary workers will be employed to upgrade the facilities. The scale of this impact will depend upon the technologies available at the time of rehabilitation. It is likely that fewer people will be employed than in the construction phase, if the plant is rehabilitated without expansion of output. Therefore the magnitude of the impact is rated as minor. Given the knowledge available at this stage, job creation for rehabilitation works is considered to be a beneficial minor effect.

7.4.4.2 Retrenchment of Staff

When the Project is eventually decommissioned there will be retrenchment of the staff employed during the operational phase. This could cause income insecurity for those members of staff affected. Unmitigated retrenchment upon decommissioning is considered to be insignificant, because workers will be of low



sensitivity and a limited number of people will be affected, so the magnitude will be minor. Retrenchment will require careful management in order to minimise the impact on affected individuals.

7.4.5 Cumulative Impacts

The main cumulative social impacts identified are the loss of access to grazing land and the change in sense of place occurring for the settlement of Karabatan Station. These issues are discussed in Section 7.4.2 above.

7.4.6 Project Risks

7.4.6.1 Overview

This section assesses risks that the Project presents. These differ to the impacts discussed in sections 7.4.2 to 7.4.5 by way of their nature, that is, while impacts are expected to occur, risks are features that could occur but are less likely or where a precautionary approach can be taken to address risks through managerial measures.

7.4.6.2 Wellbeing of Workers on Site and in Camps

Site preparation, construction activities and the use of temporary workers’ accommodation pose potential risks to the health, safety, security and therefore wellbeing of construction workers if not managed appropriately. Health and safety issues associated with the use of temporary accommodation sites include those relating to sanitation, disease, fire, cultural alienation, sleeping space, quality and quantity of food, personal safety and security, temperature control and recreation, amongst others. Issues related to food safety are of particular concern following consultation carried out in April 2014 which suggested that salmonella is reasonably common in workers’ accommodation in Atyrau due to un-trained kitchen staff.

Further information gained from discussions with the Labour Ministry shows that there are also risks to workers’ wellbeing through delayed payment of wages, potential for forced labour and people working without contracts specific to the Project’s location.

Similarly, there is the risk of adverse occupational health and safety (OHS) impacts related to personal accident or injury on any construction site. There are also potentially adverse impacts on workers related to their terms of engagement and relationship with their employer. Some of the OHS risks which are likely to arise during the construction phase of the Project, and are typical to construction sites for this type of facility include: exposure to physical hazards from use of heavy equipment and cranes; trip and fall hazards; exposure to dust and noise; falling objects; fire; exposure to hazardous materials including hazardous chemicals. The Project site is commonly very windy which presents particular hazards when working at height and using cranes and exacerbates dust issues which are likely a nuisance for workers. There is also a small risk of bubonic plague outbreak however this will be closely monitored in association with the appropriate authorities.



In addition to some of those risks identified above which will continue throughout the Project, operational health and safety risks to workers include those related to process safety, exposure to harmful air emissions, exposure to chemical hazards, working in confined spaces, and fires and explosions, especially related to chemicals.

Whilst workers on the Project, particularly sub-contracted construction workers, are vulnerable to risks to their wellbeing, health and safety on a daily basis, the Kazakh regulatory standards provide some protection. Appropriate health and safety management planning and execution in line with the EHS guidelines and good international industry practice will be undertaken by KPI to reduce the risks as far as possible.

7.4.6.3 Influx of Workers and Population Changes

A decision has not been made on the sourcing of the contractors and workforce. At this stage the precise origin of the workforce is unknown although it is expected to be largely Kazakh. Influx of workers may need to be further addressed when the relevant information is available. However, preliminary mitigation measures which represent good practice have been identified and are set out in the mitigation section below.

7.4.6.4 Health, Safety, Security and Wellbeing of Local Communities

There are a number of activities in the construction phase which if not mitigated are likely to cause risks to local communities. For example, Project truck and passenger vehicle movements will increase existing traffic volumes and may cause congestion in some locations in Atyrau. It is expected that workers will be housed outside of the City and therefore that this risk will be reduced as far as possible. Increased traffic may also result in road safety risks, especially in areas where there are pedestrians and cyclists on the road, in busy areas in the City and near schools. For further discussion of traffic impacts see Chapter 13.

There will be a health and safety risk to the local community posed by the existence of construction sites and presence of armed security guards. The risk of access to sites is mainly presented by construction of associated facilities such as the pipelines which will involve trenching as the SEZ itself has a secured perimeter fence. The transportation, storage and use of hazardous chemicals all pose health and safety risks to road users which will require effective management. Emergency situations that could occur in the operational phase include for example discharge or spill of hazardous chemicals; fire or explosion; and injuries from road accidents.

7.4.6.5 Risk of Socio-cultural Unrest and Conflict

Largely as a result of lack of attention and acknowledgment from local authorities, members of the local communities of Karabatan Station, and to a lesser extent, Railway Siding 496 feel marginalised and somewhat excluded from the mainstream society of Atyrau. Past experience with an unrelated project in the nearby vicinity of Karabatan Station has added to this feeling as the villagers were told they would be resettled. Eventually the settlement remained outside of the Sanitary Protection Zone and resettlement was avoided. Whilst normally considered best practice to avoid resettlement, in this case villagers were left



disappointed and have sought resettlement ever since. Other promises related to provision of food and benefits were also made but not kept, further exacerbating feelings of mistrust which have created a challenging social environment in which KPI must deliver the Project.

There are also generic risk factors common to many projects which could fuel community unrest or dissatisfaction such as: Jobs being seen to be given to ‘outsiders’ Lack of communication and information Poor timing or planning of engagement activities Expectations being unrealistically high for a number of reasons including rumour, false or misleading

information disclosure or good intentions at the outset being impossible or too expensive to implement Benefits being be slow to materialise due to project delays or other reasons

Community unrest may also result from aforementioned issues related to existing levels of mistrust and the likely impacts of an altered sense of place, and loss of grazing land. There will be a need for the Project to learn from the mistakes of previous projects, to manage expectations and to design mitigation and methods for the inclusion of local communities. This is taken into account in the Project’s Stakeholder

Engagement Plan and in Section 7.5 below.

7.5 Mitigation and Enhancement Measures

7.5.1 Overview

This Section presents the measures that will be taken to avoid, reduce and compensate adverse social impacts, and to enhance the beneficial impacts of the Project in all phases. These measures have been consolidated with mitigation and enhancement measures for other disciplines, and will be implemented through, the ESMP.

7.5.2 Enhancing Employment Generation and Localised Economic Development

The generation of local, and particularly permanent, employment and skills development opportunities has the potential to be one of the key benefits the Project will provide. The cooperation and support of the local community is essential if this benefit is to be realised. In order to maximise the employment benefits to local communities, to manage expectations and to avoid social conflict that might arise in relation to perceived inequity of recruitment approaches, KPI will adopt the following measures:

Disclosure of a Recruitment Policy that specifically includes a requirement to prioritise local

employment for positions that become available. The Policy will consider local literacy levels and gender issues and will be based on the principles of non-discrimination and equal opportunity. The Recruitment Policy should consider job availability and recruitment processes for contracting workers from vulnerable groups, such as those from Karabatan Station and Railway Siding 496, the unemployed, the unskilled, ethnic minorities or people employed in the informal sector. The Policy will



be disclosed in Karabatan Station and Railway Siding 496 to maximise the potential for sharing the Project’s benefits with vulnerable people.

Descriptions of the employment and supply chain opportunities will be provided to local people and businesses for the construction and operational phases of the Project. This will include information about required skill levels, indicative timeframes for recruitment and likely duration of contracts. This will allow prospective local employees and companies to prepare for and make informed decisions about opportunities.

Provision of basic skills development training to allow local people, including women, to take advantage of low or unskilled jobs. Of particular note for training considerations for the Project, are health and safety training, assistance with what to expect in the recruitment process, specific task familiarisation and money management skills.

Provision of transportation for workers from Karabatan Station to the Project site to encourage them to take up work on the Project.

Retrenchment Plan to be developed in the post operation/decommissioning phase, or any other

periods when staff redundancies are required. Retrenchment Plans must be developed in accordance with Kazakh Law and the requirements of IFC PS2 and EBRD PR2.

With the adoption of these measures by KPI and the application of them by all subcontractors, in particular the policy to recruit people from vulnerable groups, then employment generation is expected to become a moderate beneficial effect for the construction phase. For the operational phase it will become minor to moderate beneficial effect.

Localised economic development will be enhanced, resulting in a minor to moderate beneficial effect.

With effective and timely planning, the magnitude of impact on retrenchment is expected to decrease but will remain an adverse minor effect.

7.5.3 Safeguarding the Wellbeing, Health and Safety of Workers

Labour policies and procedures will be developed by KPI to ensure that the wellbeing of its workers and the contractors’ workers are protected in accordance with Kazakh law, ILO core labour standards and international best practice.39 These policies and procedures will cover the following:

Working conditions and management of worker relationships:

39 As exemplified by IFC PS2, EBRD PR2, IFC EHS General Guidelines and IFC EHS Guidelines for Large Volume Petroleum-based Organic Chemicals Manufacturing and those for Petroleum-based Polymers Manufacturing.



– Update of KPI’s Corporate HR Policy to reflect IFC/EBRD requirements. – KPI to Issue all KPI Project staff, with an individual contract of employment detailing their rights and

conditions in accordance with the Kazakh Labour Code and IFC/EBRD requirements. Contracts should cover hours of work, wages, overtime, compensation and benefits such as maternity or annual leave. Update the contract when material changes occur. KPI requires their contractor through does the same and through contract clauses requires the same of sub-contractors.

– Develop a Project Human Resources Policy in line with the requirements of IFC PS2 and EBRD PR2.

– Require, through contract clauses, that contractors and their sub-contractors manage the Project workforce in accordance with the Project Human Resources Policy and their individual contracts of employment.

– Monitor the labour rights of third party employers and keep track of the labour profile on a quarterly basis during construction.

– Quarterly external labour audits. – Provide accommodation in accordance with Kazakh law and the IFC/EBRD guidance document

“Workers’ accommodation: processes and standards, a guidance note by IFC and the EBRD”

(August 2009). A Workers’ Accommodation Plan which will govern the provision of accommodation to similar standards at all camps and will cover: provision of adequate and safe drinking water, adequate space, safe food, power, heating, cooling, ventilation, sanitation, water treatment, waste disposal, fire and noise protection, measures to deal with disease-carrying animals, sanitary washing and laundry facilities, lighting, storage, basic medical services and transport between accommodation and site, and maintenance and management of sites. Particular attention will be paid to management of food safety to prevent salmonella and similar bacteria.

– KPI to develop, formalise and disclose a labour grievance mechanism for complaints related to staff treatment, working or living conditions without reprisal and make this available to all their Project workers.. KPI will also require their contractor to formulate a grievance mechanism for complaints from contractor and sub-contractor staff. The contractor will be required to provide KPI with monthly reports of any grievances and how they have been dealt with as part of KPIs requirement of monitoring contractors performance

– Hold toolbox talks on labour law issues and the labour grievance mechanism twice a year during the construction phase.

– If there is a large number of foreign workers (workers that are sourced from outside of Kazakhstan depending on the final construction arrangements), there will need to be training provided to all workers on cultural awareness.

Protecting the workforce: occupational, health and safety:

– Develop a Worker Health and Safety Plan which covers the hazards identified for the Project site, type of work and other Project activities such as: driving on public roads; provision of preventive and protective measures for all hazards; health and safety training including how to recognise hazards, unsafe areas and occupational disease or injury; information about safe working methods including the production of individual worksheets for discreet hazardous tasks; use of Personal Protective Equipment (PPE); management, storage, handling and movement of hazardous chemicals; and road safety measures such as speed limits on public roads and onsite. The



requirements of IFC PS2, EBRD PR2 and the World Bank General Environmental Health and Safety (EHS) Guidelines as well as the sector specific guidelines will be incorporated into the Plan.

– Develop a Worker Code of Conduct to govern the behaviour of workers on site, in their accommodation and in the local communities. This should cover inter alia: cultural awareness for workers coming from outside of the wider area of influence; a drugs and alcohol policy with information about testing and penalties for contravention; use of PPE and information about safety non-compliances including non-use of PPE; maintaining a safe working area; respect for colleagues and communities; and information about HIV/AIDS and the spread of sexually transmitted diseases.

– Organise a training program and maintain individual training registers for each construction worker which they can have at the end of contract for obtaining future work.

– Maintain up to date records of all Project workers’ next of kin in case of emergency. – Contractors will be required through contract clauses to monitor and enforce the Worker Health and

Safety plans and establish penalties for violations and rewards for good compliance records. Contractors will be responsible for ensuring all sub-contractors also enforce the Worker Health and Safety plans.

– Give HIV/AIDS awareness and prevention briefings, to be undertaken in a culturally sensitive manner.

– Screen workers for tuberculosis. – Develop an Emergency Preparedness and Response Plan covering risks to workers in

emergencies, dealing with fire, explosions, chemical spill or accidental discharge, road accidents, serious personal injury.

– Provide construction site and operational facility Emergency Response Teams. – Maintain monthly contact with Atyrau Plague Control Station to monitor risk of plague outbreak and

act as necessary.

KPI will employ or assign a suitably qualified ‘Environment, Health and Safety’ Manager for the Project and

support staff in order to assess risks to worker health and safety and implement preventive and protective measures. The EHS Manager will carry out daily site walkovers to identify hazards and take action based on their findings. They will record incidents (where personal injury could have occurred but did not) and accidents (where personal injury actually occurred). KPI’s EHS Manager will also be mandated to carry out

monitoring of sites and workers’ accommodation and hold meetings to discuss health and safety improvements, compliance with PPE requirements and other OHS issues as they arise.

All workers on the Project will be given basic health and safety training including use of appropriate PPE such as safety boots, high visibility jackets, hard hats, goggles and dust masks. Training will also be given on how to conduct tasks with specific health and safety risks such as welding, use and storage of hazardous chemicals, working with electrical equipment, working at height, working in adverse weather conditions, road safety and general driver training, use of seatbelts, vehicle checking and dealing with adverse weather conditions on roads such as snow and ice. The contractors’ EHS Managers will retain a

log documenting all health and safety training given to each worker and when refresher courses are due. These logs will be monitored by KPI’s EHS Manager on a regular basis, at least monthly.



KPI’s EHS Manager will maintain a central record of occupational incidents, accidents and diseases and follow these up on all sites to ensure that corrective measures are taken and that recurrence is prevented. KPI’s EHS Manager or representative will also maintain a record of worker grievances including how

grievances were closed out and in what timeframe. Grievance, incident, accident and occupational disease logs will be retained at head office for future analysis and monitoring by lenders or government inspection authorities.

Contractors and sub-contractors will be made aware of their role in ensuring the Project meets international standards related to labour and working conditions. In particular, overtime arrangements and the timely payment of wages will be addressed. The contractors will also be expected to provide all construction workers with a summary of their employment service and training activities at the end of each contract as a means to finding continued employment. Awareness amongst contractors and sub-contractors will be raised through the provision of briefings and enforced through contractual clauses and regular monitoring (internally by KPI and externally by independent monitors) of contractors’ activities and

performance.

Contractors will be required, through their contracts, to supply key personnel for the management of OHS risks who will include an Environmental Health and Safety (EHS) Manager with overall responsibility for ensuring the health and safety of the contractor’s workers, reporting to KPI’s EHS Manager.

Clauses will be inserted in contractors’ agreements to ensure compliance with the following KPI

documentation and procedures: Project Human Resources Policy and Procedures Issuing of individual worker contracts of employment Workers’ Accommodation Plan Retrenchment Plan Labour Grievance Mechanism Worker Code of Conduct Worker Health and Safety Plan Emergency Preparedness and Response Plan Cultural awareness training

KPI will review the likelihood of the use of child or forced labour or the presence of occupational safety issues within their primary supply chain prior to engaging suppliers and will not deal with companies where there are unacceptable risks. KPI will monitor its suppliers at least quarterly to identify any new risks and will take appropriate actions to remedy any significant problems which may be discovered. Where KPI foresees a lack of control over the selection of primary supply chain companies, the responsibility for ensuring compliance with the IFC PS2 requirements in this regard will be passed onto contractors through contract clauses. Records of correspondences or other actions taken to review child or forced labour or OHS problems in the supply chain will be maintained by KPI’s EHS Manager.

In case of an injury to Project workers, trauma provision will be provided at hospitals in Atyrau City. In addition there will be first aid kits and first response facilities at the main construction site and a nurse or ambulance will be on standby at all times to provide first response care in medical emergencies as well as



treating workers for minor medical problems. Any permanent work place injuries will be subject to a compensation scheme.

7.5.4 Managing Influx

During the construction phase, depending on the origin of the main contractor, there is a potential for an influx of workers from outside of Kazakhstan in the local zone of influence. Measures have been identified to prefer local workers in order to prevent conflict and enhance benefits for ACs, however if an influx occurs it will need to be managed. Measures will include: A Code of Conduct for all workers to be developed and included as part of the employment contract -

this should cover norms related to interactions with the local community as well as expectations regarding behaviour.

Cultural awareness training for workers and events for communities. HIV/AIDS and sexually transmitted disease (STI) awareness and prevention briefings, to be

undertaken in a culturally sensitive manner.

7.5.5 Safeguarding the Health, Safety and Wellbeing of Communities

Measures discussed above including the Worker Code of Conduct will entail elements for the protection of local communities, however additional specific measures will include: Provision of adequate site security arrangements, commensurate with the risks posed to the safety of

community members accessing construction or operational sites. This will include securing of all sites with appropriate fencing and locks to prohibit entry by members of the public at any time of day, provision of security services of KPI Project site 24 hours a day and use of signage. All security guards will be vetted prior to recruitment to check for records of historic violence or abuse. They will be trained in the use of force, emergency preparedness procedures, and use of equipment with regular refresher training, which will be recorded in training logs. Security guards will be provided with uniforms and identity badges and a logging system will be used to record entry to and exit of each Project site.

Any reports of unlawful behaviour by security guards will be investigated and reported to the appropriate authorities if necessary.

All vehicles will carry spill kits and fire extinguishers for dealing with spills or small vehicle fires on public or site roads.

Drivers will be equipped with telephones for contacting the emergency services and KPI head office to enact the Emergency Preparedness and Response Plan (EPRP) if necessary.

Drivers will be first-aid trained and equipped with first aid kits which they will regularly inspect and maintain.

The Project will develop an EPRP in collaboration with Karabatan Station and Atyrau City to establish actions and contacts in case of emergency. Review and updating of emergency contact details in the EPRP will be undertaken quarterly.

The community grievance mechanism will remain effective throughout the Project lifecycle.



7.5.6 Offsetting Impacts on Karabatan Station Settlement

A number of effects and risks are likely to be perceived or felt at specifically at Karabatan Station which it will be challenging to avoid or reduce. These include loss of access to grazing land, nuisance and disturbance impacts such as noise and dust, and altered sense of place. In order to offset impacts (real or perceived) and reduce risk of conflict between the Project and the settlement. KPI will undertake a programme of community investment tailored to the specific needs of Karabatan Station settlement. The community investment programme will be based on consultation with the settlement’s Akim and community

members in order to establish priorities. Separate consultations will be held with women to ensure that their needs and suggestions receive equal consideration for investment. Based on interviews with villages during the ESIA scoping site visit in April 2014, some initial ideas for investment could include: Support for livestock husbandry and income generation from livestock products Provision of improved sanitation and showering facilities Screening programme for tuberculosis (TB) and advice about TB in animals and food safety Investigation of causes of TB and investment to help reduce

Community investment should be carefully managed to avoid pitfalls. Firstly KPI will aim to provide infrastructure that is sustainable and transferrable to be managed by the community once complete in order to avoid creating a dependency culture on KPI. KPI will undertake consultation and collaboration with villagers to decide on how infrastructure will be managed and maintained. Secondly, KPI will not make promises that will be difficult to keep and will always maintain a truthful and open discussion with the community in order to create trust. This will help to manage expectations and to avoid hopes being raised unduly. These commitments will be managed through a community investment policy which will be disclosed to the community at Karabatan Station.

KPI will discuss the merits of drawing up a Good Neighbour Agreement with the community at Karabatan Station. The Good Neighbour Agreement could include commitment to key measures in the ESMP and SEP such as development of an EPRP, provision of information to the community, pollution prevention, local hire preferences as well as measures to establish a fund for community investment and organising open days for groups from the community to visit the Project during operation to learn more about how it works and how impacts and risks are managed.

The application of a transparent, fair and well communicated community investment strategy for Karabatan Station is expected to reduce the magnitude of impacts (real or perceived), resulting in a minor adverse effect which is not significant.

7.6 Residual Impacts

Table 7.11 summarises the impacts, risks, mitigations and residual significance of impacts when mitigation is applied.



Table 7.11: Summary of Residual Impact

Activity Potential Impacts and Risks

Sensitivity Magnitude Impact Significance

Mitigation or Enhancement Residual Impacts

Construction Impacts

Recruitment Employment generation

Medium to high

Minor Minor beneficial

Disclosed Recruitment Policy

Job and supply chain opportunities provided to local people

Basic skills programme for job-seekers from ACs

Provision of transportation for workers from the ACs to the Project site to encourage them to take up work on the Project

Contract clauses for contractors and sub-contractors to hire people from ACs

Moderate beneficial

Land leasing, clearance and fencing

Loss of access to grazing land and resultant loss of livelihood

Low Minor to moderate

Insignificant or minor adverse

Gender-sensitive Community Investment Policy, to be disclosed

Gender sensitive Community Investment Programme developed in consultation with men and women at Karabatan Station

Consultation on Good Neighbour Agreement

Insignificant

Construction site activities, industrialisation of locality

Disturbance and altered sense of place

High Moderate Moderate adverse

Insignificant

Procurement of goods and services

Localised economic development


Minor beneficial

Supply chain opportunities provided to local companies Minor to moderate beneficial

Operation Impacts

Recruitment Employment generation and skills development

Medium Moderate Moderate beneficial

Recruitment in line with HR Policy and international standards

Supply chain opportunities provided to local companies

Moderate beneficial

Decommissioning or Rehabilitation Impacts

Recruitment Employment creation for rehabilitation

Medium to high

Minor Minor beneficial

Disclosed Recruitment Policy

Job and supply chain opportunities provided to local people

Basic skills programme for job-seekers from ACs

Minor beneficial

Changes in types of work or end of Project

Retrenchment Low Minor Insignificant Retrenchment Plan Insignificant



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7.7 Proposed Monitoring and Reporting

IFC PS1 and EBRD PR1 require internal monitoring and external or independent monitoring of all Category A projects or projects with significant impacts. Monitoring reports will be disclosed by KPI every six months during construction and annually during operation.

Monitoring of social issues will be important, especially with regards to worker management, workers’

terms and conditions (including accommodation), occupational health and safety and grievances. Internal and external monitoring will need to ensure that the Project commitments to workers’ rights are

implemented and that measures to share benefits and mitigate adverse impacts are effectively employed. The following actions to monitor and record mitigations and enhancement measures will be carried out during the construction phase and during operation (where applicable) by KPI: Records will be kept of people employed from ACs and their pre-project status including their

employment status (whether they were previously employed, unemployed, underemployed, employed in informal sector, skilled, unskilled etc.) which settlement they are from, their ethnicity, their gender, their age and their start and end date of employment.

Copies of job and supply chain opportunity descriptions posted in the local area of influence will be kept on file.

The number of people receiving training, certificates and resultant employment on the Project from the basic skills training programme will be recorded.

Records of numbers of people affected by retrenchment will be kept, if relevant. A list signatures showing that workers have received and understand their contracts and the Worker

Code of Conduct will be maintained. There will be monthly inspections of the construction workers’ accommodation, using the checklist

provided in the EBRD/IFC Guidance which will be kept on record along with an action plan to resolve any issues and timeframes for close-out.

Grievances will be received and recorded via the workers’ grievance mechanism and the log will be

reviewed monthly by KPI’s Human Resources Department to identify patterns or area where actions can be taken to prevent recurrent problems.

Training records will be maintained, especially for: – OHS training and hazardous work training – Emergency drills – Security guards – Toolbox talks – HIV/AIDS awareness sessions – Emergency drills

Accidents, incidents and diseases logs will be maintained to monitor the health and safety of Project workers.

Records of all correspondence with the Plague Control Station. Confidential health records for Project workers will be maintained, including TB test results, medical

results and occupational injury or disease. These records will be aggregated and made anonymous for review by external parties.



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Regular site monitoring of OHS issues and PPE compliance will be carried out and recorded. Records will be kept showing the system, correspondence and actions taken to review the Project’s

supply chain for use of child or forced labour and OHS issues. Personnel files will be kept for each worker and will include: next of kin contact details in case of

accident or emergency, social security number, copy of identity card, certificates and qualifications, internal and external training, leave records, record of past abuse/criminal record for security workers.

Payroll records will be kept. Security records will be maintained logging entries to Project sites by non-employees and any incidents

that occur with regard to security or security guards. Community grievances will be received and recorded via the Community grievance mechanism

detailed within the Stakeholder Engagement Plan and the Community Liaison Officer (CLO), as described within the Stakeholder Engagement Plan, will carry out analysis to identify common or recurrent problems. There will be follow-up of these issues with the Project Manager and contractors to find to deal with the causes and actions to prevent further recurrence.

There will be monitoring of community grievances by the CLO to check for complaints against security guards. These will be followed up with the relevant authorities if necessary.

All stakeholder engagement will be documented and recorded as detailed within the SEP.

All of the above will be regularly monitored during the construction phase and the operational phases as appropriate by KPI’s Project EHS Manager and their team. Monthly reports will be provided to KPI’s

Project Manager and will be made available to external monitors and auditors when required. Frequency of reporting may reduce if appropriate during the operational phase.

7.7.1 Annual Sustainability Reporting

It is important for KPI to be transparent about its Project performance and the impact its activities are having on the physical environment and social context. The Global Reporting Initiative’s (GRI) Sustainability Reporting Framework is one of the mostly widely used reporting approaches that sets out the principles and performance indicators which organisations can use to measure and report their economic, environmental, and social performance. The GRI has been working with the IFC to align some of its reporting requirement with the IFC’s PS.

Sustainability reporting will need to be issued annually addressing the full range of social issues addressed in this SIA, including but not limited to details on: The labour profile and OHS performance Land leasing Contributions to the local economy Social investments, activities and outcomes Stakeholder engagement

Lenders may have specific data they request to be included in annual reporting.



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8.1 Introduction

8.1.1 Overview

This section provides an assessment of the potential effects of the Project on local air quality. This assessment has been carried out in accordance with Equator Principles, IFC, JBIC and EBRD guidelines and addresses the construction and operational phases.

8.1.2 Key Pollutants

The combustion of fossil fuel gives rise to a number of pollutants with the potential to negatively affect sensitive receptors. With respect to natural gas and recovered fuel gas captured from the process (the main proposed fuel sources of the Project), the primary pollutants of concern following combustion are nitrogen oxides (NOx).

The Project will lead to emissions of other pollutants and their inclusion within the assessment is described below. Sulphur dioxide (SO2) has not been considered further in this assessment as SO2 emissions are directly proportionate to the quantity of sulphur in the fuel which will be very low for both natural gas and recovered fuel gas.

8.1.2.1 Nitrogen Oxides (NOX)

Nitrogen oxides is a term used to describe a mixture of nitric oxide (NO) and nitrogen dioxide (NO2), referred to collectively as NOx. These are primarily formed from atmospheric and fuel nitrogen as a result of high temperature combustion. The proportion of each of the two forms varies depending on the combustion technology and the fuel being burnt. In the case of a natural gas fired plant, approximately 90 - 95% of the NOx is present as NO, with the remainder being NO2.

NO is a colourless and tasteless gas. It is readily oxidised to NO2, a more harmful form of NOx by chemical reaction with ozone and other chemicals present in the atmosphere. NO2 is a yellowish-orange to reddish-brown gas with a pungent odour.

The production of NOx during combustion depends on several factors, the principal of which are: Nitrogen in the fuel; Temperature of combustion; Geometry of the combustion chamber; and Ratio of fuel to combustion air.

All NOx produced originates from nitrogen in the fuel or from nitrogen in the air that is used for combustion. NOx from the fuel is referred to as ‘fuel NOx’ and NOx from the air is generally referred to as ‘thermal NOx’.

NOx oxidised directly by the radicals of the combustion reaction is referred to as ‘prompt NOx’ (although

this represents a very small proportion of the total). The proportion of fuel NOx to thermal NOx and other emissions depends on the temperature of combustion. With an increase in combustion temperature, there

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is an increase in thermal NOx emissions, and hence the overall NOx emissions. The formation of thermal NOx is strongly dependent on the maximum flame temperature and the period that the gases remain at that temperature. Impacts from emissions of NOx form the main focus of this assessment.

8.1.2.2 Particulate Matter

Particulates are a complex mixture of organic and inorganic substances present in the atmosphere. Some particulates occur naturally, originating from volcanoes, dust storms, forest and grassland fires. Human activities, such as the burning of fossil fuels in vehicles, power plants and various industrial processes also generate significant amounts of particulates.

Particulates are described in terms of their size; for example the term PM2.5 describes particulate matter that is less than 2.5 microns in aerodynamic diameter and PM10 describes particulate matter that is less than 10 microns.

Increased levels of fine particles in the air are linked to health hazards such as heart disease, altered lung function and lung cancer. The size of the particle is a main determinant of where in the respiratory tract the particle will come to rest when inhaled. Larger particles are generally filtered in the nose and throat and do not cause problems, but particulate matter smaller than about 10 microns can settle in the bronchi and lungs and cause health problems.

Combustion sources associated with the proposed Project will only emit trace amounts of particulate matter due to the type of technology and fuel that is being utilised. Any vents from the production process and those associated with the polypropylene storage silos which could lead to particulate emissions will be carefully mitigated with filters to minimise any potential emissions to the atmosphere. Based on this emissions of particulates from the operation of the Project have not been considered further.

8.1.2.3 Volatile Organic Compounds

VOCs are organic chemical compounds that have high enough vapour pressures under normal conditions to significantly vaporize and enter the atmosphere. A wide range of carbon-based molecules, such as aldehydes, ketones, and other light hydrocarbons are VOCs. The most common VOC is methane. Common artificial VOCs include paint thinners, dry cleaning solvents, and some constituents of fuels (e.g. petrol and natural gas).

Potential fugitive emissions from the Project are mainly associated with emissions from leaking pipes, valves, storage tanks, connections, flanges, pump seals, compressor seals and pressure relief valves.

Potential VOC emissions will be controlled by industry best practice and are therefore expected to be minimal during the operation of the Project and have not been included further within dispersion modelling.



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Carbon Monoxide (CO)

Carbon monoxide (CO) is produced when incomplete combustion takes place. Emissions of CO from a combustion plant such as a gas turbine are limited by optimising the fuel to air ratio to maximise the heat released per unit of fuel. Monitoring of this pollutant is often used as a measure of combustion efficiency and it is therefore in an operator’s interest to minimise emissions.

CO emissions have not been consider further as emissions are expected to be low compared to the relevant air quality standards.

8.2 Legislation and Guidance

8.2.1 Overview

This section outlines national and international legislation and standards relevant to both emissions limits and ambient air quality.


Within the Republic of Kazakhstan there are a number of regulations which establish standards for the ambient and working zones, including the following main documents: RD 52.04.186-89 “Guidelines for the air pollution control”. “Methodology on the determination of the standard emissions to the environment” approved by Order

No. 379-O of the RK Minister of Environment dated December 11, 2013. It determines standard rules for calculation of emissions to atmosphere, water and limits for waste disposal.

GOST 17.2.2.03-87 Standard on “Nature protection. Atmosphere. Rates and methods of measuring

carbon monoxide and hydrocarbons content in exhaust gases of petrol-engine vehicles. Safety requirements”.

“Methodology for the standard payments calculation for the emissions to the environment” approved by Order No. 68-P of the RK Minister of Environment dated April 8, 2009.

SanPiN "Sanitary requirements on air quality in urban and rural areas, soils and their security, conditions of urban and rural settlements areas, working conditions with sources of physical impact factors" approved by RK Government Decree No.168 dated January 25, 2012.

“List of pollution substances and waste types for which emission standards are applied” approved by

RK Government Decree No 557 dated June 30, 2007.

The key types of norms used for the regulation of impact on air quality are described below: Maximum Allowable Concentration (MAC) - concentration which does not have long lasting direct or

indirect adverse impact on the present or future generations and that does not affect human performance or has negative impact on human health or and sanitary conditions.

Maximum Permissible Emission (MPE) – emission limit which is set for each source of air pollution considering that harmful emissions from this source will not create surface concentrations exceeding



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their maximum allowable concentrations taking into account accumulative impact from the pollution sources of a city or town and from the perspective sources coming from the development of industries.

Reference Impact Safe Level (OBUV) - temporary sanitary norm for air pollutants as determined by the calculation method for the design of industrial facilities.

Maximum Allowable Concentration for working zone (MACwz) - the concentration of harmful substances in the air during working hours (except holidays) for not less than 8 hours a week or more than 40 hours a week;

Maximum Allowable Concentration, or maximum single occurrence (MACmso) - the concentration of harmful substances in the air of populated areas, which after 20 minutes does not cause reflex (or sub sensorial) reactions in human health; and

Maximum Allowable Concentration daily average (MACda) - the concentration of harmful substances in populated areas. The levels of pollutants should not influence human health directly or indirectly after inhaling them for an unlimited period of time (years). Thus, MPCda is calculated for all groups in a population, and for an indefinitely long averaging period. They apply to all populated areas and are consequently considered the strictest of the Republic of Kazakhstan standards for air quality.

A summary of relevant national air quality emission limits and ambient air quality standards are presented in Table 8.1 and Table 8.2

8.2.3 International Requirements

8.2.3.1 IFC Requirements

The IFC provide a portfolio of Standards and Guidelines that should be adhered to for any project seeking IFC finance. The IFC Performance Standard 3: Resource Efficiency and Pollution Prevention [Ref 1] aims:

“To avoid or minimize adverse impacts on human health and the environment by avoiding or minimizing

pollution from project activities”

To achieve this, the IFC provides both industry-specific and general guidance on Good International Industry Practice with respect to ambient air quality and emissions to air. The Project will need to comply with the IFC Performance Standards and the standards set out in the IFC Environmental Health and Safety (EHS) Guidelines [Ref 2] (EHS General Guidelines 2007 and EHS Guidelines and Large Volume Petroleum-based Organic Chemicals Manufacturing 2007).

Emissions to Air

The IFC EHS Guidelines advise that, with respect to emission limits, when host country regulations differ from the levels presented in the Guidelines, projects are expected to achieve whichever is more stringent. (It should be noted that the same approach does not apply to ambient concentrations, as described below). Table 8.1 presents the relevant emission limits applicable to the Project.



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Ambient Air Quality

The IFC General EHS Guidelines advise that ‘relevant standards’ with respect to ambient air quality are

national legislated standards or, in their absence, the current World Health Organisation (WHO) Air Quality Guidelines or other internationally recognised sources. As the Republic of Kazakhstan has its own nationally legislated standards, as described above, these have been used to determine significance of potential ambient impacts.

However, for comparison purposes only, Table 8.1 also presents the current WHO and EU ambient air quality standards. The comparison shows that standards are similar; however, the national standards include a 20 minute averaging period for NO2.

The current WHO Guidelines are provided in the Air Quality Guidelines Global Update 2005. These guidelines are intended to support actions for air quality at the optimal achievable level for public health protection in different contexts. The WHO does not formally prescribe how guidelines should be used in air quality management. However, the Air Quality Guidelines Global Update does provide ‘Interim Targets’ to

aid the progression of policy development to bring air quality in line with the proposed guideline values.

The General EHS Guidelines specifically refer to the European Union Directives as being an ‘internationally recognised source’ of ambient air quality standards. Although numerically equal to the

WHO standards for some pollutants, the EU legislation introduces a threshold of tolerance to account for exceptional, worst case episodes. This translates as a limit not to be exceeded more than a certain number of times, and can be expressed as a ‘percentile’.

The IFC General EHS Guidelines suggest that, as a general rule, emissions should not contribute more than 25 percent of the relevant air quality standards to allow additional, future sustainable development in the same airshed. Therefore, the significance of the impact of the Project has been discussed in the context of this approach.

The IFC also requires occupational health and safety to be assessed against appropriate standards. This assessment has used occupational health and safety standards prepared by the UK’s Health and Safety

executive for a comparison against national standards.

8.2.3.2 EBRD Requirements

The Project has been assessed against the guidance provided by the EBRD Environmental and Social Policy PR3: Pollution Prevention and Abatement [Ref 3] the objectives of which are:

“to avoid or, where avoidance is not possible, minimise adverse impacts on human health and the

environment by avoiding or minimising pollution directly arising from projects”

PR3 refers to the EU Directives on emissions and ambient air quality and the Economic Commission for Europe’s Executive Body for the Convention on Long-range Transboundary Air Pollution (ECE CLTAP)



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[Ref 4]. It should be noted that the ECE CLTAP does not apply to this Project due to the combustion technology and its use within the Project.

Emission to Air

The EU Industrial Emissions Directive (IED) (2010/75/EU) [Ref 5] provides standards for emissions to air including for plant with a thermal input greater than 50MW. Of the combustion processes to be installed within the Project only the gas turbines within the Project boundary and the gas turbines within the shared facility are subject to these standards.

Ambient Air Quality

Directive 2008/50/EC on ambient air quality and cleaner air for Europe [Ref 6] was adopted in May 2008. This latest Directive merges the first three existing Daughter Directives and one Council Decision into a single Directive on air quality (it is anticipated that the fourth Daughter Directive will be brought within the new Directive at a later date). It also sets new standards and target dates for reducing concentrations of fine particles. PR3 states that “when host country regulations differ from the levels and measures

presented in EU environmental requirements or requirements agreed pursuant to paragraph 7, projects will be expected to meet whichever is more stringent”.

8.2.3.3 Summary

Table 8.1 presents the lowest (most stringent) relevant Kazakhstan, IFC and EU emission Limit Values for NOx for each of the emission point sources. In the case of the internal steam generation stack there are a number of emissions sources being vented through this stack (including emissions from the gas turbines) and therefore the lowest (most stringent) applicable emission limit has been applied. In this instance due to the Selective Catalytic Reduction abatement system that will be installed this emission limit will be achieved.

Table 8.1: NOx Emission Limit Values

Stack(s) Emission Sources European Union IFC Guidelines Republic of Kazakhstan

Propane Dehydrogenation Reaction stack

PDH reaction process units

100(a)

200(b)

300

255 Internal steam generation stack

Gas turbines >50MWthd)

50(c) 50(c)

Shared facilities gas turbines

Central Gas Turbines >50MWth

50(c) 50(c)

Notes: Units – mg/Nm3

(a) Reference conditions: 3% O2, 273 Kelvin and 101.3kPa when firing gas (c) Reference conditions: 3% O2, 273 Kelvin and 101.3kPa when firing liquid fuel (c) Reference conditions: 15% O2, 273 Kelvin and 101.3kPa (d) there are other sources vented through this stack, only the most stringent emission limit has been presented.



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Table 8.2 presents the ambient air quality standards for the protection of human health for NO2 and are hereafter referred to as the ‘standards’, adopted for this assessment.

Table 8.3 presents relevant VOC limits recommended by the IFC and the Republic of Kazakhstan. Monitored VOC concentrations from the baseline surveys undertaken for the Project will be compared against these standards for the protection of human health.

Table 8.2: Relevant Ambient Air Quality Standards for the Protection of Human Health (µg/m3)

Pollutant Averaging Period

European Union Standards(a)

World Health Organisation (b)

Republic of Kazakhstan Standards(c)

Nitrogen Dioxide (NO2)

20 Minutes - - 200

1 Hour 200 (d) 200 (Guideline) -

24 Hour - - 40

Annual 40 40 (Guideline) -

Notes: (a Ref 6 (b) Ref 8 (b) Ref 9 (d) 99.79th percentile

Table 8.3: Summary of Relevant VOC Ambient Air Quality Standards for Protection of Human Health

Pollutant Applicable International Standards

Kazakhstan Maximum Allowable Concentrations

Annual µg/m3 20 min µg/m3 24 hour µg/m3

Benzene(a) 5 300 100

Toluene(c) 1,910 600 -

Ethylbenzene(c) 4,410 20 -

Xylene(c) 4,410 200 -

Source: (a) EU Limit values

(b) UK air quality regulations

(c) Derived from Health and Safety Executive EH40/2001 occupational limits for 2001

Occupational standards are available from the Republic of Kazakhstan and from a variety of international sources including The National Institute for Occupational safety and Health (NIOSH) and the UK Health and Safety Executive. The NIOSH provides occupational exposure limits for a number of pollutants including NO2. Occupational exposure to NO2 is compared against two averaging periods which include Recommended Exposure Limit (REL) for a 15 minute time weighted average and an 8 hour time weighted Permissible Exposure Limits (PEL) as suggested by the Occupational Safety and Health Administration (OSHA).

Table 8.4 presents the appropriate NO2 occupational standards used as the basis for this assessment.

Table 8.4: Relevant NO2 Occupational Exposure Standards

Occupational Standards Concentration mg/m3

15 minute NIOSH REL 1.8

8 Hour OSHA PEL 9



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Occupational Standards Concentration mg/m3

20 min Kazakhstan MAC 2

Source: www.cdc.gov/niosh

REL - Recommended Exposure Limit PEL - permissible Exposure Limits

Relevant occupational exposure standards for VOCs applicable within the IPC are presented in Table 8.5. These are based on 8 hour averaging periods and have been used as an indication of potential risk to onsite workers who do not live within the industrial area.

Table 8.5: Relevant VOC Occupational Exposure Standards

Pollutant International Standards Kazakhstan Maximum Allowable Concentrations

ppm mg/m3 mg/m3

Benzene 1 3.25 5

Toluene 50 191 50

Ethylbenzene 100 441 50

Xylene 50 220 50

Source: UK Health and Safety Executive EH40/2005 ppm – parts per million Based on 8 hour averaging period


8.3.1 Overview

This section provides an overview of the methodology for assessing the existing baseline and the construction and operational phase effects. It also provides an overview of the key operational emissions sources that have been represented within the air dispersion modelling of the Project.

8.3.2 Baseline Assessment Methodology

A monitoring survey using diffusion tubes was carried out by Mott MacDonald to establish long term average concentrations of NO2, and selected VOCs. Available monitoring data and data collected from the diffusion tube survey have been reviewed in Section 8.5 and the current baseline established.

8.3.3 Zone of Influence for Air Quality

The zone of influence with regard to air quality is the area that could potentially be affected by emissions to air during the construction, operational and decommissioning phases. During construction and decommissioning this is confined to a small area located around the construction site and the main transport routes. Construction and decommissioning effects occur over a temporary time period and are

http://www.cdc.gov/niosh



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located within 500 metres of the construction activity. The operational phase effects will be experienced throughout the life of the Project which in this case is a minimum of 25 years and have the potential to affect an area up to 15km from the Project.

8.3.4 Construction Phase – Public Health

Construction activities can result in temporary effects from dust. ‘Dust’ is a generic term which usually refers to particulate matter in the size range 1-75 microns. The nature of the area and activities to be carried out means that emissions of construction dust are predominantly associated with the movement and handling of subsoil minerals and therefore composed of the larger fractions of this range which do not penetrate far into the respiratory system. Therefore the primary air quality issue associated with construction phase dust emissions is normally loss of amenity and/or nuisance caused by, for example, soiling of buildings, vegetation and reduced visibility.

Dust deposition can be expressed in terms of mass per unit area per unit time, e.g. mg/m2/month. No relevant Kazakhstan, IFC or EBRD standards exist for dust deposition; however, a range of criteria from 133 to 350 mg/m2/month is found around the world as representative of thresholds for significant nuisance.

It is considered that a quantitative approach is inappropriate and unnecessary for assessing particulate emissions associated with the construction phase of the Project. The activities undertaken during the construction phase are likely to increase dust emissions in the area however given the existing natural sandy conditions and the limited duration of construction works and the locations of sensitive receptors a qualitative assessment of dust effects is appropriate.

The first stage of the assessment has involved the identification of construction activities which have the potential to cause dust emissions, and the degree of that potential. Table 8.6 provides a generic list of potential construction activities. Selected information from this table has been used within this assessment to determine the impact of the Project with respect to construction dust.



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Table 8.6: Relevant Generic Dust Generating Activities

Potential Dust Emitting Activities Description Dust Emission Potential

Soil handling Potential to be high, depends on time of year and soil dryness

High

Loading Activities Potential to be high, depends on time of year and soil dryness

High

Storage of materials onsite Potential to be high, depends on time of year soil dryness

Medium

Transport of materials within site Can be high depends on type of transport and nature of road surface

Medium

Drilling and digging activities (Including soil excavation)

Can be high depending on type of drilling and digging activities

High

Transport of material offsite Generally low as transport occurs by surfaced roads

Low

Construction of new buildings Generally low although some activities with high dust raising such as material cutting can occur

Medium-Low

Assembly of plant Generally low as involves assembling already made pieces

Low

In the second stage of the assessment, all sensitive receptors with the potential to be significantly affected by construction dust emissions have been identified. The distances from source at which construction dust effects are felt are dependent on the extent and nature of mitigation measures, prevailing wind conditions, rainfall and the presence of natural screening by, for example, vegetation or existing physical screening such as boundary walls on a site. Research indicates that effects from construction activities that generate dust are generally limited to within 150-200 metres of the activity. However based on the existing conditions in the area and the high winds that can be experienced and to ensure a conservative assessment, the residential receptors at Karabatan station have also been considered , and their sensitivity classification determined in Table 8.7.

Given the location of the Project there will not be any sensitive receptors located within 5 km of the IPC’s

boundary. However during construction the Project will have the potential to affect other parts of the IPC which may have already been constructed. These will include infrastructure associated with the train station and the polymer plant to the south of the Project site.

Table 8.7: Receptor Classification

Distance from Source High Medium Low

Within 200 metres - Other projects and infrastructure in the IPC

Vegetation on the surrounding Steppe

Outside 200 metres - - Vegetation on the surrounding Steppe,

Karabatan Station, existing cafe

At this stage the exact number of vehicle movements required during the construction phase is not known although it is not expected to be more than 100 movements per day. It is planned that where possible



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equipment and materials will be delivered directly to the Project site via the existing railway station. Given the existing numbers of vehicles using the road infrastructure around the Project site is low and there no residential receptors located along the main access roads impacts from construction phase vehicle movements are considered insignificant from an air quality perspective, and have not been considered further. However, general mitigation measures to help reduce emissions have been provided in the relevant sections below.

8.3.5 Construction Phase – Occupational Health

Following the results of the ground investigation surveys potential dust generated during the construction phase are not considered to cause an occupational exposure risk and have not been considered further.

Mitigation measures to minimise emissions from onsite combustion plant have been presented in section 8.1.1.2.

8.3.6 Operational Phase

8.3.6.1 Overview

This section describes the methods used to assess the air quality effects associated with the operational phase of the Project. Modelling has been carried out to identify potentially significant effects on sensitive receptors within the study area.

8.3.6.2 Model Selection

A number of commercially available dispersion models are able to predict ground level concentrations arising from emissions to atmosphere from elevated point sources such as a power plant. A new generation dispersion model - AERMOD (version 7.2.5) was used to inform the basis of the air quality assessment. AERMOD is recommended for use by the IFC as an appropriate method for predicting the emissions from point sources such as those associated with this Project. A model description is included below.

A committee, AERMIC (the American Meteorological Society / Environmental Protection Agency Regulatory Model Improvement Committee), was formed to introduce state-of-the-art modelling concepts into the US Environmental Protection Agency’s local-scale air quality models. AERMIC’s focus was on a

new platform for regulatory steady-state plume modelling. AERMOD was designed to treat both surface and elevated sources in simple and complex terrain.

Special features of AERMOD include its ability to treat the vertical heterogeneity nature of the planetary boundary layer, special treatment of surface releases, irregularly-shaped area sources and limitation of vertical mixing in the stable boundary layer.

AERMOD is a modelling system with three separate components and these are as follows:



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AERMOD (AERMIC Dispersion Model) AERMAP (AERMOD Terrain Pre-processor) AERMET (AERMOD Meteorological Pre-processor).

AERMET is the meteorological pre-processor for AERMOD. Input data can come from hourly cloud cover observations, surface meteorological observations and twice-a-day upper air soundings. Output includes surface meteorological observations and parameters and vertical profiles of several atmospheric parameters.

AERMOD is not capable of calculating ambient concentrations for averaging periods of less than one hour, therefore Mott MacDonald’s approach has been to follow advice from the model developer. Therefore hourly concentrations have been multiplied by a factor of 1.3 to derive 20 minute concentration values and 1.34 to drive 15 minute concentrations to predict concentrations in accordance with national standards.

8.3.6.3 Modelled Sources

The operational emissions sources from the Project are described below: Reaction Section Charge Heaters – These heat the propane feedstock before it is passed to the

reactor. To minimize NOx emissions low NOx burners will be utilised. The heaters will use a mixture of natural gas and recovered fuel gas from the Project.

Waste heat recovery boiler stack – This emits exhaust gases from the regeneration air heater, the Project’s two gas turbines, the catalyst regeneration, reactor evacuation and any additional emissions from any supplementary firing in the waste heat recovery boiler. Selective catalytic reduction (SCR) will be used to reduce NOx emissions by 85%.

2 flares – (one high pressure and one low pressure) - These will be installed to burn any fugitive gas collected from storage tanks and process equipment and for use in an emergency situation should the plant need to undergo emergency shutdown and vent large quantities of gas. Under normal operations it is expected that only small amounts of natural gas will be burnt by the flares pilot flame.

In addition to the emissions from the Project the IPC’s associated facilities will also have operational

emissions sources. These are: 4 Gas Turbines – The central IPC facilities will consist of four gas turbines each of 50 MW electrical

output each. These will supply enough electricity for all activities within the IPC.

8.3.6.4 Meteorology

The most important meteorological parameters governing the atmospheric dispersion of pollutants are wind direction, wind speed and atmospheric stability, as described below: Wind direction determines the sector of the compass into which the plume is dispersed; Wind speed affects the distance which the plume travels over time and can affect plume dispersion by

increasing the initial dilution of pollutants and inhibiting plume rise; and Atmospheric stability is a measure of the turbulence of the air, and particularly of its vertical motion. It

therefore affects the spread of the plume as it travels away from the source. New generation dispersion models use a parameter known as the Monin-Obukhov length that, together with the wind speed, describes the stability of the atmosphere.



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For meteorological data to be suitable for dispersion modelling purposes, a number of parameters need to be measured on an hourly basis. These parameters include wind speed, wind direction, cloud cover and temperature. There are only a limited number of sites nationally where the required meteorological measurements are made.

Dispersion model simulations were performed using five years of meteorological data from Atyrau airport (approximately 40 km to the south-west of the IPC). By using hourly sequential meteorological data the effects of extreme changes in regional temperatures between summer and winter have been accounted for within the dispersion modelling.

Table 8.8 presents the minimum and maximum recorded temperatures from the five years of meteorological data used within the assessment and are an indication of the extreme temperatures in the study area.

Table 8.8: Minimum and Maximum Temperatures used within Assessment (°C)

2009 2010 2011 2012 2013

Minimum -30 -22 -30 -32 -22

Maximum 39 41 41 41 41

Figure 8.1 presents wind roses from the five years of meteorological data used with the assessment. The wind roses indicate that generally wind is either from a westerly or easterly direction and wind speeds are high with the majority above 5 m/s.



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Figure 8.1: Windroses showing Frequency and Magnitude of Wind Data used within Dispersion Modelling



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8.3.6.5 Terrain

The presence of elevated terrain can significantly affect (usually increase) ground level concentrations of pollutants emitted from elevated sources such as stacks by reducing the distance between the plume centre line and ground level and increasing turbulence and, hence, plume mixing.

Terrain in the study area is relatively flat (i.e. there is less than 1 in 10 gradient) and therefore not likely to affect dispersion. On this basis terrain data has not been included in the dispersion model.

Roughness of terrain over which a plume passes can have a significant effect on dispersion by altering the velocity profile with height, and the degree of atmospheric turbulence. This is accounted for by a parameter called the surface roughness length and has been calculated based on the land use around the Project site. The land use around the Project site has been classified as ‘desert’ based on the high level of

exposed sandy soil.

8.3.6.6 Building Downwash

The movement of air over and around buildings generates areas of flow circulation, which can lead to increased ground level pollutant concentrations in the building wakes. Where building heights are greater than about 30 - 40% of the stack height, downwash effects can be significant. The dominant buildings (i.e. with the greatest dimensions likely to promote turbulence) in relation to the emission sources are presented in Table 8.9. It is not expected that onsite structures such as platforms or walkways would have a significant effect on the movement of air in their vicinity and therefore they have not been included within the dispersion modelling. These structures are designed to allow air flow to pass around or through them and therefore minimise negative effects on pollutant dispersion. Where final building dimensions are not known conservative assumptions have been included within the dispersion model.

Table 8.9: Main Building Dimensions

Building Height (m) Length (m) Width (m)

Bag house room 9.4 275 151

Substation 10.3 93 40

Rack room 7.1 30 30

Gas turbine 1 5 43 9

Gas turbine 2 5 43 9

Extrusion building 47.2 47 50

Cooling water building 12.5 54 48

PP plant 30 70 24

Charger block 30 68 21

Waste heat recovery boiler 25 30 7

Shared facilities GT building 30 364 185



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Figure 8.2: Main Buildings Assumed in Dispersion Modelling

8.3.6.7 Emissions to Air

The relevant emissions data for the proposed plant are summarised in Table 8.10. The main pollutant of concern from the combustion sources associated with the Project is NOx, as described in section 8.1.2 emissions of VOCs and CO are expected to be negligible and have therefore not been considered within the dispersion modelling study. In addition under normal operations the flares will only have their pilot flame operating on natural gas. Therefore emissions to air from the flares will be negligible and have not been considered further.

Table 8.10: Emissions Parameters

Parameter Reaction Section

Charge Heater Internal Steam

Generation Stack Shared Facilities

Gas Turbines

Stack Height (m) 50 40 70

Internal Stack Diameter (m) 2.5 6.5 3

Exhaust gas Temperature (°C) 175 160 176.7

Volumetric Flow (Am3/s) 18.6 395 169.1

Exhaust Gas Exit Velocity (m/s) 3.8 11.9 23.9

NOx (mg/Nm3) 219 11 50

NOx (g/s) 4.1 4.2 6



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8.3.6.8 Percentage Oxidation of Nitrogen Oxide to Nitrogen Dioxide

NOx emissions associated with combustion sources such as gas turbines and boilers will usually comprise approximately 90-95% NO and 5-10% NO2 at source. The NO oxidises in the atmosphere in the presence of sunlight, ozone and volatile organic compounds to form NO2, which is the principal pollutant of concern with respect to environmental health effects.

There are various techniques available for estimating the proportion of the NOx that is converted to NO2. A 50% conversion of NOx to NO2 has been assumed for short term averaging periods (20 minutes and 1 hour), and 70% conversion for long term averages (24 hour and annual). This approach is considered appropriate based on guidance from the United Kingdom’s Environment Agency (EA) [Ref 10] and United States Environmental Protection Agency (USEPA).

8.3.6.9 Fugitive Emissions

Fugitive emissions in associated with Projects of this type are mainly associated with emissions from unloading facilities, leaking pipes, valves, connections, flanges, open ended lines, pump seals, gas conveyance systems, compressor seals and pressure relief valves amongst others. Potential VOC emissions will be controlled by industry best practice and are therefore expected to be minimal during the operation of Project and have not been included further within the assessment.

The Project will meet industry best practice to avoid the release of fugitive emissions, methods are in line with those specified within both the General and sector specific EHS Guidelines and are presented within the Mitigation Section, below.

8.3.6.10 Receptors

Human Health – Public Health

Within this section of the ESIA, the phrase ‘discrete receptor’ has been used to refer to a specific identified

location where the dispersion model has been used to predict pollutant concentrations. Additionally a ‘receptor grid’ refers to a dispersion modelling concept where pollutant concentrations are predicted over a grid in uniform arrangement. The discrete receptors allow air quality impacts to be assessed at identified existing receptor locations. The receptor grid aids the assessment of pollutant concentrations over a wide spatial area and, by interpolating between these points, allows the production of pollutant contours which illustrate how pollutant concentrations change across the study area.

In order to assess potential impacts on sensitive receptors, modelling was carried to predict pollutant concentrations across a study area with a 15 km radius grid. This involved modelling a 30x30km grid of receptors with a receptor spacing of 300 m at a height of 1.5 m.

Outputs from the modelled grid have been used to present ground level ambient pollutant concentrations from the Project, referred to as ‘process contributions’. These process contributions have been added to

‘ambient concentrations’ to report the ‘predicted environmental concentrations’.



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Discrete receptors have been modelled at the closest point of Karabatan station and a proposed hotel (which is currently a truck stop café). Modelled discrete receptors are presented in Table 8.11 and Figure 8.3.

Table 8.11: Receptor Locations

Receptor Name X Y Height (m)

Karabatan Station 599392 5236592 1.5

Proposed hotel and Roadside Cafe 598556 5238797 1.5

Note: Projection is WGS 84 UTM 39 North



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Figure 8.3: Receptor Locations

Human Health – Occupational

Elevated concentrations of pollutants can have a negative effect on on-site workers; severe cases can result in respiratory irritation, discomfort or illness. Although the IFC does not specify occupational



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exposure limits for workers, it provides suitable sources where these can be obtained and defines appropriate measures that should be applied to maintain suitable air quality in occupational areas.

On site short term ground level concentrations of NO2 have been modelled using a high resolution 50m grid across the industrial area and compared to relevant standards. Based on the design of the Project it is not expected that there will be a risk of occupational exposure to elevated concentrations of VOC’s and

therefore this has not been assessed within the dispersion modelling. In order to support the assumption that VOC need not be assessed based on design control measures,, best practice mitigation measures in line with IFC EHS guidelines have been included within section 8.8.

8.4 Impact Assessment Criteria

8.4.1 Overview

Determining the significance of impacts identified is one of the main purposes of an environmental assessment and enables the identification of necessary mitigation measures. An environmental impact can be either beneficial or adverse and is assessed by comparing the quality of the existing environment with the predicted quality of the environment once a project is in place.

In order to describe the significance of an impact it is important to distinguish between two concepts; ‘magnitude’ and ‘sensitivity’. The application of these concepts for this assessment is outlined in Chapter 5

of the ESIA and should be read in conjunction with this chapter. This Section describes how the significance criteria for the operational phase has been derived based on assessment of magnitude of the impact and receptor sensitivity.

8.4.2 Construction Phase

A combination of dust emission potential from on-site activities (Table 8.6) and their expected duration has been used to determine the impact magnitude of the construction phase and is presented in Table 8.12.

Table 8.12: Determination of Impact Magnitude – Construction Phase

Dust Raising Potential(a) Duration Magnitude

High Any Major

Medium > 3 Months Moderate

Medium < 3 Months Minor

Low Any Negligible

Notes(a) Dust raising potential defined in accordance with the approach described in Section 8.3.4.

In addition, receptor sensitivity has been based on the type of receptor and the distance from the construction boundary or activity. Table 8.13 presents the criteria on which receptor sensitivity has been based.



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Table 8.13: Determination of Receptor Sensitivity – Construction Phase

Receptor Classification (a)

Distance to Activities

0-50m 50-100m 100-200m >200m

High High High Medium Low

Medium Medium Medium Low Low

Low Medium Low Low Negligible

Notes: (a) Receptors classified based on method described in Section 8.3.4.

In summary, the magnitude of impacts is a product of the types of activities carried out and their durations. The receptor sensitivities are a product of the receptor type and their distance to the construction activities.

Following the definition of magnitude and sensitivity, the significance of impacts and therefore overall risk of dust effects from the construction phase has been evaluated based on the significance matrix presented in Section 5.

8.4.3 Significance Criteria - Operational Phase

Guidance has been issued to assist in determining the significance of operational phase impacts in air quality assessments [Ref 10]. This guidance recommends that significance should be determined by a combination of two aspects: The change in concentrations (Process Contribution (PC)) caused by the Project at sensitive receptors;

and The resulting total concentrations (Predicted Environmental Concentrations (PEC)) at sensitive

receptors as a percentage of the relevant ambient air quality standard(s).

This approach is considered to represent best practice for assessments of this kind and has therefore been adapted for determining the significance of impacts on local air quality from the Project.

Table 8.14 and Table 8.15 present the approach used for determining residential receptor sensitivity and impact magnitude for operational phase impacts which have been determined in light of IFC guidance. Changes in ambient concentrations over 25% of the relevant standards are considered to represent an impact of ‘Major’ magnitude as the General EHS Guidelines note that projects should:

“…prevent or minimize impacts by ensuring that …emissions do not contribute a significant portion to the

attainment of relevant ambient air quality guidelines or standards. As a general rule, this guideline suggests 25 percent of the applicable air quality standards to allow additional future sustainable development in the same airshed.

The General EHS Guidelines classify ‘poor quality airsheds’ as those where relevant standards are

exceeded significantly. Therefore, receptors experiencing baseline ambient pollutant concentrations above the relevant standards are concluded to be of ‘High’ sensitivity.



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For each of the key pollutants and averaging periods assessed, a number of ambient air quality standards are applicable

Table 8.14: Determination of Impact Magnitude – Operational Phase

Change in Concentrations as % of Standard Magnitude

Increase >25% Major

Increase 15-25% Moderate

Increase 5-15% Minor

Increase <5% Negligible

Table 8.15: Determination of Receptor Sensitivity – Operational Phase

Ground Level Pollutant Concentrations in Relation to Standard Receptor Sensitivity

Above Standard High

75 to 100% of the Standard Medium

50 to 75% of the Standard Low

Below 50% of the Standard Negligible

Notwithstanding the above, any non-negligible increases causing a new exceedence of the relevant standards are afforded ‘Major’ adverse significance.


8.5.1 Overview

This section presents available data on existing concentrations of relevant pollutants within the study area. The existing concentrations form the basis upon which the process contributions (PC) from the modelled scenario described in Section 8.3.6 will be added to provide the predicted environmental concentrations (PEC) as a result of the Project. A review of this existing long term data and project specific data is provided below.

8.5.2 Review of Existing Data

Air quality monitoring is undertaken at the Karabatan refinery 16 km from the IPC site. In addition monitoring is also undertaken at three other locations including within Atyrau city which was presented in the OVOS. However data from these sites has not been included within this review as these monitoring locations are either not representative of the existing background conditions at the IPC site (in the case of Atyrau city where air quality will be heavily influenced by traffic) or the locations of the monitoring station are unknown. In the case of the other two unknown stations (Eskene village and station) the monitoring data recorded indicates that pollutant concentrations at these locations are lower than at the Karabatan refinery.



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The monitoring data from the Karabatan refinery is considered representative given the distance from the IPC, the Karabatan refinery is not currently operational and there are no other major emission sources within the study area. A four year, annual average (2007-2011) for Atyrau City was presented within the OVOS and has been presented in Table 8.16. More recent ambient pollutant concentrations, showing annual average pollutant concentrations for 2011 to 2013 are also presented within Table 8.16.

Table 8.16: Monitored Annual NO2 Concentrations for the Project

Air Quality Monitoring Station

Concentrations (µg/m3)

2011 2012 2013

Karabatan 11.9 10.0 7.0

The annual average results for NO2 indicate that concentrations in the area are low and well below national and international ambient air quality standards for NO2.

8.5.3 Site Specific Monitoring

8.5.3.1 Overview

There are various monitoring strategies and equipment that can be deployed to establish a baseline for ambient air quality. Automatic monitoring can provide more accurate data than passive monitoring. However, there is both a large capital expenditure required to rent or purchase equipment and a large labour cost as specialist, routine maintenance is required.

The monitoring undertaken for this Project utilised passive monitoring equipment commonly referred to as diffusion tubes. Diffusion tubes were located at five sites to establish long term ambient pollutant concentrations. Diffusion tubes are a recognised method of carrying out monitoring for comparison against long term ambient air quality standards and given the expected baseline conditions and distance between the IPC and nearby receptors this approach is considered appropriate.

8.5.3.2 Diffusion Tube Description

Monitoring of NO2, Benzene, Toluene, Ethylbenzene and Xylene has been carried out using diffusion tubes. Diffusion tubes are passive samplers and rely on the physical movement of air through the tube (rather than air being drawn in to the apparatus). The tubes contain a chemically active surface at one end coated on a small non-reactive metal grid. Once the active surface is exposed, a concentration gradient forms within the tube. The total concentration can be calculated based on this and period that the tube has been exposed.

8.5.3.3 Temporal Scope

Monitoring of NO2, Benzene, Toluene, Ethylbenzene, Xylene was undertaken for a two month period with each diffusion tube being analysed after one month. Based on the land use around the IPC and that there



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are no other major emission sources in the immediate area a two month diffusion survey is considered acceptable.

8.5.3.4 Locations

Locations of the monitoring sites used for the study are presented in Figure 8.4. Monitoring was undertaken at the Project site and at the nearest settlement. Monitoring was also undertaken at the roadside café along the A27 as there are plans for a hotel to be developed at this location in the future.

Figure 8.4: Location of Diffusion Tubes



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8.5.4 Monitoring Results

Table 8.17 presents the period mean (based on two months of monitoring) monitored pollutant concentrations for all of the monitoring locations.

As noted in Section 8.2, various Kazakh and international standards exist for these pollutants for long term (annual) and short term (1 hour, 24 hour , 20 minute and 8 hour) averaging periods for the protection of public health and occupational health. Direct comparison between the monitoring data presented in Table 8.17 is therefore not possible. However, the data can be used as a basis upon which to make a qualitative comparison with the relevant standards.

Monitored period mean concentrations for all pollutants are all well below the international annual mean concentrations (see Section 8.2) with the exception of Benzene which represents 82% of the EU standard. Based on the meteorological conditions in the airshed and pollutant emission sources affecting it, it can be concluded that ambient concentrations are likely to be below the international annual mean standards.

Actual short term concentrations are likely to vary considerably above and below the period means presented in Table 8.17 due to the meteorological conditions in the airshed and pollutant emission sources affecting it. However, monitored period mean concentrations are well below the Kazakh and international short term mean standards. It can therefore be concluded that ambient pollutant concentrations are likely to be below the Kazakh and international short term mean standards.

Table 8.17: Diffusion Tube Results (µg/m3)

Monitoring Locations NO2 Benzene Toluene Ethylbenzene Xylene

Average monitored concentrations* 2.9 4.1 28.9 6.7 22.6

Notes: * - Two months monitoring assumed as annual mean

8.5.5 Summary

Pollutant concentrations are likely to be below kazakh and international ambient air quality standards. In can therefore be concluded that the airshed is not ‘degraded’ as per the definition within the IFC EHS

Guidelines.40

Following a review of the existing data and the specific monitoring survey the following baseline values presented in Table 8.18 have been assumed within the assessment. These have conservatively been based on the existing monitoring undertaken at Karabatan refinery as this covers the whole year and therefore accounts for any seasonal variation. For short term averaging periods double the annual mean concentration has been assumed.

40 Airshed should be considered as being degraded if nationally legislated air quality standards are exceeded or, in their absence, if

WHO Air Quality Guidelines are exceeded significantly



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Table 8.18: Baseline NO2 Concentrations Assumed within Modelling (µg/m3)

Short Term (1hr) Long term (24hr and annual mean)

NO2 Concentrations 23.8 11.9

8.6 Assessments of Project Impacts

1.1.1 Construction/Decommissioning – Public Health

The construction period is expected to last for approximately 3 years and will consist of major construction works.

8.6.1.1 Construction Activities and Associated Impact Magnitude

At this stage no formal construction plan has been formulated as the final construction arrangement have not been agreed. However based in previous project experience the following generic construction activities have been assumed. Based on these activities, the dust raising potential and overall impact magnitude are presented in Table 8.19. It should be noted that while the site preparation work, top soil removal and levelling and construction of roads and infrastructure has already taken place they have been included for completeness.

Table 8.19: Construction Activities and Associated Impact Magnitude

Section Description of works Key activities

Dust raising potential Duration

Impact Magnitude

Site preparation, top soil stripping and leveling

Excavation and moving soil and fill

Earthmoving

Excavation

High >3 months Major

Roads and infrastructure

Ancillary works and delivery of materials to site, removal of wastes from site

Minor excavation works.

Transport of materials.

Re-suspension of dust on unsurfaced roads.

Medium

>3 months Moderate

Construction of plant

Assembly of the main components of the plant

Storage of materials

Preparation of materials (cutting etc.)

Re-suspension of dust on unsurfaced roads

Medium > 3 months Moderate

Landscaping Landscaping requirements

Earthmoving

Excavation

Transport of materials

Wind

Re-suspension of dust on unsurfaced roads

High < 3 months Major

The activities associated with the construction phase of the Project are conservatively assumed to have a ‘high’ dust raising potential throughout the whole construction period based on the sandy dry nature of the



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soil and the relatively high winds that are experienced at the Project site. Taking the dust raising potential and the duration of the works into account, the magnitude of dust effects is considered to be ‘major’ in

accordance with the significance criteria defined in Section 5.

8.6.1.2 Receptor Sensitivity

As described in previous sections, consideration has been given to all potential receptors within the study area of the construction site boundary of the Project. In accordance with Table 8.13, the receptor sensitivity is classed as ‘low’ as there are no residential receptors within 200 metres, only other industries that will

form part of the IPC.

8.6.1.3 Significance

In accordance with the significance criteria presented in Section 5, the risk of dust effects during the construction phase is described as ‘Minor Adverse’. To reduce this effect further generic good practice dust

mitigations have been presented in the mitigation section below.

8.6.1.4 Decommissioning

The project is expected to have a minimum lifetime of 25 years but may operate for a longer period of time provided that a regular programme of maintenance and upgrades are undertaken. In the event of decommissioning of the Project, it is likely that any potential air quality impacts would be similar to those experienced in the construction phase, as broadly similar activities would be required. Similar to the construction phase these are considered to be of ‘Minor Adverse’ significance.

8.6.2 Operational – Public Health

This section provides a summary of the modelled concentrations and conclusions for changes in air quality as a result of the Project.

Table 8.20 presents the maximum modelled concentrations outside the IPC. Modelled results indicate that impacts from the Project outside the IPC will not be significant.

Table 8.21 and Table 8.22 present maximum ground level 20 minute and 24 hour NO2 concentrations at the identified discrete receptors. In all cases predicted effects are considered to not be significant.

Table 8.20: Maximum Ground Level Concentrations outside the IPC (µg/m3)


PC Impact Magnitude AC PEC Standard Receptor

Sensitivity Significance

NO2

20 Minute max 72.2 Major 23.8 96.0 200 Negligible Insignificant

1 hr Max 42.5 Moderate 23.8 66.3 200 Negligible Insignificant



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PC Impact Magnitude AC PEC Standard Receptor


1hr 99.79 %ile 25.4 Minor 23.8 49.2 200 Negligible Insignificant

24 hr Max 21.6 Major 11.9 33.5 40 Negligible Insignificant

Annual 2.7 Minor 11.9 14.6 40 Negligible Insignificant

Notes: PC – Process Contribution AC – Ambient Concentration PEC – Predicted Environmental Contribution (AC+PC)

Table 8.21: Maximum 20 minute NO2 Ground Level Concentrations at Discrete Receptors (µg/m3)

Receptor PC Impact Magnitude AC PEC Standard Receptor


Karabatan settlement 7.0 Negligible 23.8 30.8 200 Negligible Insignificant

Café/proposed hotel 8.6 Negligible 23.8 32.4 200 Negligible Insignificant

Notes: PC – Process Contribution AC – Ambient Concentration PEC – Predicted Environmental Contribution (AC+PC)

Table 8.22: Maximum 24hr NO2 Ground Level Concentrations at Discrete Receptors (µg/m3)

Receptor PC Impact Magnitude AC PEC Standard Receptor


Karabatan settlement 1.2 Negligible 11.9 13.1 40 Negligible Insignificant

Café/proposed hotel 1.6 Negligible 11.9 13.5 40 Negligible Insignificant

Notes: PC – Process Contribution AC – Ambient Concentration PEC – Predicted Environmental Contribution (AC+PC

Figure 8.5 and Figure 8.6 present the maximum 20 minute and annual mean NO2 concentrations as a result of the Project.



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Figure 8.5: Maximum 20 minute NO2 concentrations (µg/m3)

Source: Contour increments at 10µg/m3, 2012 worst meteorological year



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Figure 8.6: Annual Mean NO2 concentrations (µg/m3)

Notes: Contour increments at 1µg/m3, 2011 worst meteorological year



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8.6.3 Operational – Occupational Health

Table 8.23 presents the maximum modelled 15 minute, 20 minute and 8 Hour NO2 process contributions for comparison with relevant Republic of Kazakhstan and international standards for protection of occupational health. The results indicate that the contributions are well below the occupational standards presented in Section 8.2.3.3.

Table 8.23: Maximum modelled NO2 concentration within the IPC (µg/m3)

Averaging Period NO2

15 Minute 117.6

20 Minute 114.1

8 Hour 54.9

8.7 Cumulative Impacts

This air quality assessment has included emissions from the gas turbines within the shared facilities of the IPC however when fully operational the IPC will have additional emission sources associated with some of the other process plants. The biggest additional source of emissions will be associated with the ethylene plants crackers and any additional boilers required to generate additional steam. Although the final design of these plants is not know it is expected that they would be fired on natural gas and meet all the required national and international emission limits.

The results of the air quality assessment indicate that the maximum 24 hr predicted environmental concentration at the nearest receptor would be 37% of the national standard. Therefore the likely additional emissions released into the study area from any additional sources combined with the distance between the IPC and the nearest receptors would mean that any cumulative effects are considered not to be significant.

8.8 Mitigation Measures


The following mitigation measures (which are in accordance with the EHS Guidelines) for controlling air quality impacts will be incorporated into the construction phase: Development of a dust management plan for the construction phase to minimise dust emissions

including: – Minimizing dust from material handling sources, such as conveyors and bins, by using covers

and/or control equipment such as wind break; – Minimizing dust from open sources, including storage piles, by using control measures such as

installing enclosures and covers, and the use of chemical binding agents; – Dust suppression techniques should be implemented, such as non-toxic chemicals to minimize

dust from vehicle movements on designated haul roads;



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– Manage emissions from mobile sources as per the EHS Guidelines for Air Emissions and Ambient Air Quality including; – Regardless of the size or type of vehicle, fleet owners / operators should implement the

manufacturer recommended engine maintenance programs; – Drivers should be instructed on the benefits of driving practices that reduce both the risk of

accidents and fuel consumption, including measured acceleration and driving within safe speed limits

– Operators with fleets of 120 or more units of heavy duty vehicles (buses and trucks), or 540 or more light duty vehicles (cars and light trucks) within an airshed should consider additional ways to reduce potential impacts including:

Replacing older vehicles with newer, more fuel efficient alternatives Converting high-use vehicles to cleaner fuels, where feasible Installing and maintaining emissions control devices, such as catalytic converters Implementing a regular vehicle maintenance and repair program

– No open burning of solid waste


Dispersion modelling has demonstrated that the existing design mitigation measures incorporated with the Project will result in there not being a significant impact from emissions of NOx. Mitigation measures included within the design to minimise fugitive releases of VOCs are detailed below.

The following key design features have been accounted for and are considered to be incorporated mitigation: Appropriate stack heights for combustion sources conform with Good International Industrial Practice; Emissions vented through waste heat recovery boiler stack will pass through a selective catalytic

reaction (SCR) unit to reduced NOx emissions, and Gas turbines in the shared facilities will be installed with low NOx technology which will include dry-low

NOx burners.

The Project will meet industry best practice to avoid the release of fugitive emissions, these best practice prevention methods are in line with those specified within both the General and sector specific EHS Guidelines. The proposed Project will include the following prevention methods: Regularly monitor fugitive emissions from pipes, valves, seals, tanks and other infrastructure

components through regular inspections and maintenance or replacement of components as needed in a prioritised manner;

Collection of vapours from tanks and the unloading facilities and destruction if required through either the high pressure or low pressure flares;

Maintain stable tank pressure by: – Coordinating filling and withdrawal schedules, and implementing vapour balancing between tanks;

and – Use white or other colour paints with low heat absorption properties on exteriors of storage tanks

for propylene



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Selecting and designing tanks in accordance with internationally accepted standards to minimize storage and working losses considering, for example, storage capacity and the vapour pressure of materials being stored;

Use supply and return systems, vapour recovery hoses, and vapour tight trucks/railcars/ during loading and unloading of propane carts;

Where vapour emissions contribute or result in ambient air quality levels in excess of health based standards, install secondary emissions controls, such as vapour condensing and recovery units, catalytic oxidisers, vapour combustion units, or gas adsorption media;

Optimizing of dryer design; Use of gas closed loop; Instillation of automatic bagging systems and efficient ventilation in packaging operations’ Good housekeeping


The residual effects of the Project contamination impacts are identified in Table 8.24

8.10 References

1. International Finance Corporation Performance Standard 3: Resource Efficiency and Pollution Prevention 2012

2. International Finance Corporation Environmental Health and Safety Guidelines: General Guidelines 2007 and Large Volume Petroleum-based Organic Chemicals Manufacturing 2007.

3. European Bank for Reconstruction and Development, Environmental and Social Policy PR3: Pollution Prevention and Abatement 2008.

4. Economic Commission for Europe, Executive Body for the Convention on Long-range Transboundary Air Pollution, Thirtieth Session, Revised Annex V 30 April-4 May 2012.

5. Industrial Emissions Directive 2010/75/EU Of the European Parliament and of the Council 17/12/2010 6. Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air

quality and cleaner air for Europe 7. International Finance Corporation, World Bank Group, Environmental Health and Safety Guidelines

for Thermal Power Plants, December 2008 based on the World Health Organisation Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulphur dioxide. Global update 2005

8. International Finance Corporation, World Bank Group, Environmental Health and Safety Guidelines for Thermal Power Plants, December 2008 based on the World Health Organisation Air quality guidelines for particulate matter, ozone, nitrogen dioxide and sulphur dioxide. Global update 2005

9. Appendix 1 of SanPiN "Sanitary requirements on air quality in urban and rural areas, soils and their security, conditions of urban and rural settlements areas, working conditions with sources of physical impact factors" approved by RK Government Decree No.168 dated January 25, 2012

10. H1 Environmental Risk Assessment Consultation for the Environmental Permitting Regulations, Annex F – Air Emissions. December 2011



Table 8.24: Summary of Impacts

Activity Potential Impacts Sensitivity Magnitude Impact Significance Mitigation Residual Impacts

Construction Dust from construction activities

Low Major Minor Mitigation measure in line with IFC guidelines, dust management plan.

Insignificant to Minor Adverse

Operation Emissions from combustion plant on potential receptors outside the IPC

Negligible Negligible to Major

Insignificant All combustion activities to have suitable stack and no receptors located with the site boundary

Insignificant

Decommissioning as per construction



9.1 Introduction

This section considers the potential impacts to ground conditions associated with construction, operation and decommissioning of the Project. The assessment framework is set out in Section 5 and the assessment of potential impacts is based on the description of the Project provided in Section 2. Specific objectives of the assessment are to assess: Potential impacts of the Project on geology, soils and groundwater, from the construction phase,

subsequent operation and the decommissioning phase of the Project; Potential impacts on geology, soils and groundwater from existing contaminated land, if present in the

Project Area, and future contamination as a result of the Project; Potential secondary impacts from these contamination sources on other sensitive receptors such as

human health, ecology and water.

Appropriate mitigation measures to avoid or reduce any identified significant impacts are also presented.

Each phase of the Project has the potential to impact on soils, with potential implications on soil quality and land use, and in addition, to groundwater quality if mobilisation of contamination occurs. The geology and soils of an area can also impose constraints on the construction, particularly the presence of contaminated and unstable land. Such constraints will be considered in the Project design as well as in construction and operational procedures.

Sensitive receptors associated with ground conditions comprise key features, such as designated (regionally, nationally or internationally) important geological sites and agriculturally or ecologically valuable soils. With respect to groundwater, key features include aquifers important for their use in irrigation, industry or most importantly drinking water. There is also a potential for secondary impacts from existing or future contaminated ground to sensitive receptors that may be nearby, such as human health (farmers, contractors and site/maintenance workers), wildlife and livestock.

Based on the perceived connectivity between the above receptors and the ground conditions, the effects on these receptors with respect to impacts from contaminated ground are discussed in this chapter.

For this assessment, the study area covers the Project area, including the main Project site and the water and gas pipelines, and their surroundings within approximately 500m of the boundary. Geology, soils and groundwater further away are unlikely to be significantly affected by operations associated with Project activities.

Following a description of the legislation in Section 9.2 and assessment methodology in Section 9.3, subsequent sections provide information on baseline ground conditions (Section 9.4), the impact assessment (Section 9.5) and mitigation measures proposed (Section 9.7). A summary of the impacts and any residual impacts following mitigation are reported in Section 9.8.

9 Ground Conditions




9.2.1 National

The main legal documents regulating ground conditions, pollutants concentrations and ground surveys are, as follows: GOST 17.4.4.02-84 Standard on “Nature Conservancy. Soil. Methods of sampling and preparation of

samples for chemical, bacteriological, helminthological analysis.” SP 11-102-97 Code of Conduct on “Main engineering and environmental surveys for the construction”. “Building in seismic districts”, actualised edition SNiP II-7-81 SanPiN "Sanitary requirements on air quality in urban and rural areas, soils and their security,

conditions of urban and rural settlements areas, working conditions with sources of physical impact factors" adopted by Government Decree No.168 dated January 25, 2012.Law of the Republic of Kazakhstan of July 15, 1997, “On Environmental Protection”

Land Code No. 442-II dated 20 June 2003 (as amended on 17.01.2014) of the Republic of Kazakhstan. The code sets forth the legal basis for the use and conservation of land, provisions of the land law and land relations.

“Instructions on the development of land remediation projects” approved by Order № 57-P of the President of Kazakhstan Agency for Land Management of 2 April 2009

Government Decree No 581 of the Republic of Kazakhstan as of 7 July 2007 “On the land evaluation

environmental criteria” and No 653 of the Republic of Kazakhstan as of 31 July 2007 “On the criteria for

assessing the environmental situation territories” Describe methods for soil evaluation and corresponding assessment criteria.

RK Law № 219-I “On radiation safety of population” as of 23 April 1998 (amended on 13.01.2014). Provides guidance on radon limits in soils in relation to land development.

9.2.2 International

Key standards and documents on international best practice related to the assessment and management of contaminated land, and good practice for pollution prevention and control include the following: IFC Performance Standard 3 Pollution Prevention and Abatement, in Performance Standards on Social

& Environmental Sustainability (IFC, 2012); IFC Guidance Notes: Performance Standards on Social & Environmental Sustainability (IFC, 2007),

specifically Guidance Note 3: Pollution Prevention and Abatement; IFC General EHS Guidelines: Environmental, Contaminated Land (IFC, 2007); Joint E&P Forum/UNEP Technical Publication on Environmental Management in the Oil and Gas

Industry (E&P/UNEP, 1997); IFC Environmental, Health, and Safety (EHS) Guidelines for Petroleum-based Polymers Manufacturing

(IFC, 2007).

IFC guidance (IFC, 2012) outlines the requirement for impact and risk assessment for key stages of a project, before construction, during construction, during operation and during and after the



decommissioning stage. It also provides guidance on pollution prevention and control, waste disposal, handling of hazardous materials and emergency response.

IFC guidance for contaminated land (IFC, 2007) gives a broad outline of the requirement for risk screening, risk management, detailed quantitative risk assessment and risk reduction measures, where risk factors: source, pathways and receptors are likely to co-exist. The risk screening involves identification of contamination; sampling and testing; evaluation of the results; and verification of sensitive receptors and the exposure pathways. Where necessary, a detailed risk assessment builds on the risk screening and involves detailed ground investigation to identify the scope of contamination.

The IFC guidance for Petroleum-based Polymers Manufacturing (IFC, 2007) gives specific guidance on management of environmental and health risks specifically associated with the manufacture of polymers into pellets or granules for subsequent industrial use. The document includes potential environmental issues associated wastewater, hazardous materials and wastes, and recommendations for management of issues most common to this industry during the operation phase.

The assessment also makes reference to the following Integrated Pollution Prevention and Control (IPPC) Best Available Technique (BAT) Reference Notes:

European Commission Reference Document on BAT in the Production of Polymers (August 2007).

The purpose of this document is to provide guidance on the current best available processes and techniques used in the production of polymers, including polyolefins (polyethylene and polypropylene), to help reduce fugitive emissions. This includes generic BAT and those more specific to production of certain types of polymer. Generic BAT includes improvements in equipment design, monitoring and maintenance, recycling, use of flaring and wastewater treatment. This document also includes guidance on generic environmental management tools.

IPPC Reference Document on BAT in Common Waste Water and Waste Gas Treatment / Management Systems in the Chemical Sector (February 2003)

This document considers the environmental impacts caused by discharges to air and water from chemical installations and provides guidance on environmental management systems for dealing with waste releases and suitable treatment options using BAT.


9.3.1 Consultation

The project initial stakeholder consultation, which took place on 24th April 2014, raised the following concerns in relation to water and ground contamination:



What will KPI do with waste water? It was explained that domestic water will be treated and sent to a central waste water treatment (WWT) point. This will be recycled in the closed circuit zero-discharge waste water system.

Concerns regarding a regional problem relating to a number of unattended oil wells from which oil leaks.

Atyrau Oil Extraction Department (organisation) have many tanks of oil at their storage facility (warehouse) near the city, where there are many spills due to improper storage/handling.

The latter two comments relate to wider issues of contamination within the region that are unlikely to be influenced by this Project. However, the general concerns raised by these comments will be addressed where possible in this section.

9.3.2 Evaluation of Baseline Conditions

The evaluation of baseline conditions uses a variety of sources, including information on geology, soils, hydrogeology and the existing contamination status of the soils and groundwater in existing and proposed construction areas of the Project. The baseline conditions for the site have been assessed by Tetrakon on behalf of Sinopec Engineering as part of the national EIA assessment, which itself is based on published literature/studies, and presented in their EIA report (Tetrakon, 2013). An assessment of the baseline conditions has also been undertaken based on ground investigation, designed by Mott MacDonald and carried out by a local sub consultant (Envirs Consulting).

9.3.3 Field Reconnaissance

Field reconnaissance was undertaken in April 2014 by members of the Mott MacDonald project team. The reconnaissance included a visit to the recently cleared Project site.

The visits were undertaken to make a visual assessment of the baseline conditions at the Project sites to determine the potential for future site works to impact on the existing ground conditions, and to determine the extent of ground investigation required to characterise the soil and groundwater conditions at the site.

9.3.4 Ground Investigation and Monitoring

A ground investigation survey was undertaken by Envirs Consulting in May 2014 to investigative the ground conditions at the proposed site of the development. The investigation included sampling of groundwater from three existing monitoring wells, sampling of soils, and testing of soil and groundwater quality in order to establish a baseline of the soil and groundwater conditions across the site and in the immediate surrounding area.

All soil samples were sent for laboratory testing for the following analytes: Inorganics - pH, chloride, fluoride, sulphate, total carbon, ammoniacal nitrogen and sulphur. Organics - Total petroleum hydrocarbons (TPH), total phenols, polycyclic aromatic



hydrocarbons (PAHs) and BTEX (benzene, toluene, ethylbenzene, xylenes). Total metals - Arsenic, barium, beryllium, boron, cadmium, chromium (III), cobalt, copper, iron,

lead, magnesium, manganese, mercury, molybdenum, nickel, selenium, sodium, vanadium and zinc.

A portion of the soils samples collected were also tested for the mobile form of all of the above metals.

Groundwater samples were tested for all of the above and major ions including sodium, calcium, dissolved oxygen, bicarbonate, conductivity, total dissolved solids, biological oxygen demand and total coliforms.

Details of the investigation and the laboratory resting results are discussed in the Ground Investigation report (Envirs Consulting, 2014) (Appendix D).

Since completion of the OVOS report and baseline study (Tetrakon Engineering, 2013), the Project site has been cleared and levelled in preparation for the proposed development. It is also understood that, as part of this work, soils have been imported from surrounding areas and used for filling/levelling activities.

The ground investigation has therefore been designed to investigate both existing conditions on site (following clearance), and conditions prior to clearance. Where possible, this has been achieved by sampling shallow disturbed soils (0.1-0.2m below ground level (bgl)) from within the proposed site boundary, and shallow (0.1-0.2m bgl) and deeper (1m bgl) undisturbed soils from the nearby surrounding area, which are believed to be most representative of the site conditions prior to clearance.

9.3.5 Assessment Criteria

Soil Quality Assessment Criteria

An assessment of potential land contamination has been undertaken by comparison of soil quality data with local and international standards derived for protection of human health.

As a first stage of assessment, to address the risks to human health, the results of the analytical testing on soil samples have been compared to national Maximum Allowable Concentrations (MAC) (Astana, 2004), approved by the Order No.99 of the Healthcare Minister of the RoK as of January 30, 2004 and by the Order No.21-p of Minister of Environmental Protection of the RoK as of January 27, 2004.

The MACs have been derived for a number of heavy metals and organic compounds for the protection of human health and are based on residential and arable land use, taking into account background exposure from the natural occurrence of contaminants in the environment. A number of MACs have also been derived for the mobile metal forms.

There are no official national criteria for oil products in soil.

For comparative purposes, the following standards have also been used in this contamination risk assessment:



Canadian Environmental Quality Guidelines (CEQG) published by the Canadian Council of Ministers of the Environment (CCME, 2011); and

Dutch Intervention Values (DIV) published by the Dutch ministry for social building, regional planning, and environment administration (VROM, 2009).

The generic assessment criteria used in this report for the assessment of risks to human health from the presence of soil contamination are presented in Table 9.1.

The Dutch Standards have been derived by modelling exposure under the following assumed conditions: Residential land uses Temperate climatic conditions Contamination exposure to children through direct and dust ingestion.

The DIV represent contamination thresholds above which the functional properties of the soil for humans, plants and animals are seriously impaired or threatened. Under such circumstances, remediation may be required. The contamination level at which the Intervention Values are set reflects Dutch health and societal policy considerations. Intervention Values for soil are expressed as the concentration in a standard soil (10% organic matter and 25% clay).

For this assessment, the CEQG derived for commercial/ industrial land use have been used. The Canadian CEQG have been derived by modelling exposure under the following assumed conditions: Industrial land use — where the primary activity involves the production, manufacture, or construction

of goods, and public access to the property is restricted. To protect both ecological and human receptors (with the most protective guideline chosen). Taking into account daily background exposure from air, water, soil, food, and consumer products. Contamination exposure to adults through direct contact, ingestion and inhalation, for 10 hours per day,

5 days per week and 48 weeks per year (CCME 2007).

More comprehensive polycyclic aromatic hydrocarbon (PAH) soil quality guidelines have also been derived by CCME for protection of human health and the environment. Details of the assessment methodology can be found in the CCME guidelines (2010).

By considering childhood exposure in a residential setting, the Dutch Standards assume exposure of the most sensitive human receptor groups in society. This has a negative effect on the thresholds potentially making the risk assessment more conservative than the CCME thresholds which were derived for adult staff on a commercial site. However, the Dutch and Canadian values, based on generic assessment criteria, are considered to represent a sound, scientific and internationally recognised basis for reviewing the contamination levels on a comparative basis against the contamination assessment based on the National MACs.



Table 9.1: Generic Assessment Criteria for Soils

Parameter Units

National CCME CEQG Dutch*

MAC[1] (industrial) Intervention Value

Arsenic mg/kg 2# 12 76

Barium mg/kg - 2000 920

Beryllium mg/kg - 8 -

Cadmium mg/kg - 22 13

Chromium (III) mg/kg 6## 87 (Cr total) 180

Cobalt mg/kg 5## 300 190

Copper mg/kg 3## 91 190

Fluoride mg/kg 2.8

Lead mg/kg 32# 600 530

Manganese mg/kg 1,500# - -

Mercury mg/kg 2.1# 50 4**

Molybdenum mg/kg - 40 190

Nickel mg/kg 4## 50 100

Selenium mg/kg - 2.9 -

Sulphur mg/kg 160 - -

Vanadium mg/kg 150 130 -

Zinc mg/kg 23##- 360 720

Benzene mg/kg 0.3# 0.0068 1.1

Toluene mg/kg 0.3# 0.08 32

Ethylbenzene mg/kg 0.3# 0.018 110

Xylenes (sum)**** mg/kg 0.3# 2.4 - 11***** 17

Total PAH mg/kg - See below 40 (sum of 10)***

Benzo(a)pyrene mg/kg 0.02# See below -

Mineral Oil mg/kg - 1700-2500 5000

* for a 'Standard Soil' with 10% organic matter ** for organic mercury *** Sum of 10 PAHs (naphthalene, phenanthrene, anthracene, fluoranthene, benzo(a)anthracene, chrysene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(123-cd)pyrene and benzo(ghi)perylene) **** Sum of xylenes (m-xylene, o-xylene and p-xylene) ***** Depending on soil grain size (fine-coarse) # - Total content ## - Content of mobile compound [1] – MAC Maximum Allowable Concentration (Astana, 2004)

CCME Soil Quality Guidelines for PAHs

There is no single guideline for protection of human health and the environment from all PAHs, instead there are three steps to assess individually: the carcinogenic effects on humans in direct contact with contaminated soils (Total Potency Equivalent or TPE); the non-carcinogenic effects on protected potable



water resources (Index of Additive Cancer Risk or IACR); and the non-carcinogenic effects on the environment.

The carcinogenic effects on humans in direct contact with contaminated soils can be assessed by calculating the benzo(a)pyrene B[a]P TPE, which is ‘the sum of estimated cancer potency relative to

benzo(a)pyrene for all potentially carcinogenic PAHs (benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(ghi)perylene, chrysene, dibenzo(ah)anthracene and indeno(123 cd)pyrene). The B[a]P TPE for a soil sample is calculated by multiplying the concentration of each PAH in the sample by its B[a]P Potency Equivalence Factor (PEF) and summing the products’

(CCME, 2010, p3). The B[a]P TPE is then compared with the soil quality guideline for direct contact, which for industrial landuse is 5.3 mg/kg.

The IACR ‘assesses potential threats to potable groundwater quality from leaching of carcinogenic PAH

mixtures from soil. The IACR is calculated by dividing the soil concentration of each carcinogenic PAH by its soil quality guideline for protection of potable water component value to calculate the hazard index for each PAH, and then summing the hazard indices for the entire PAH mixture’ (CCME, 2010, p3). The IACR is then compared with the soil quality guideline for the protection of potable water, which for industrial landuse must be ≤1 mg/kg.

Details of the calculations for both the B[a]P TPE and IACR can be found in the CCME guidelines (2010).

In addition to the soil guidelines for protection of human health, the CCME have published soil quality guidelines (SQG) for protection of the environment. The SQG for industrial landuse are as follows: anthracene (32 mg/kg); benzo(a)pyrene (72 mg/kg); fluoranthene (180 mg/kg); naphthalene (0.013 mg/kg); phenanthrere (0.046 mg/kg); benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenzo(ah)anthracene and indeno(123 cd)pyrene (all individually 10 mg/kg); and pyrene (100 mg/kg).

Groundwater Quality Assessment Criteria

An assessment of potential groundwater contamination has been undertaken by comparison of groundwater quality data with local and international standards derived for protection of human health.

As a first stage of assessment, in accordance with the National guidance, to address the risks to human health the results of the analytical testing on groundwater samples have been compared to National MAC values derived in accordance with sanitary requirements for water resources, drinking water intakes, drinking water supply systems and places of cultural and household water security and water bodies, approved by the Government Decree of the RK No.104 as of 18 January 2012.

For comparative purposes, in the absence of international guidance levels for the assessment of impacts to groundwater quality and environmental receptors, the groundwater samples have also been compared to guidelines for drinking water quality published by the World Health Authority (WHO, 2011).

The generic assessment criteria used in this report for the assessment of risks to human health from the presence of contamination in groundwater are presented in Table 9.2. It is understood that groundwater



within 500m of the site is not currently used for either domestic, drinking or industrial use. All process and drinking water for the IPC will be taken from the Kigach River via a new pipeline connecting to the existing Astrakham to Mangyslak water pipeline. Whilst it is unlikely that the groundwater will be used for human consumption, in the absence of quality guidelines to assess environmental impacts, it is considered that the internationally recognised WHO drinking water quality guidelines provide suitably conservative values for reviewing the contaminant levels on a comparative basis against the contamination assessment based on the national MACs.

Table 9.2: Generic Assessment Criteria for Groundwater

Parameter Units National MAC WHO Drinking water guidelines

General Inorganics

pH - 6-9 -

Chloride mg/l 350 -

Fluoride mg/l 1.5 1.5

Ammoniacal nitrogen mg/l 2 -

Nitrate mg/l - 50

Sulphate mg/l 500 -

Metals

Arsenic mg/l 0.05 0.01

Barium mg/l 0.1 0.7

Beryllium mg/l 0.0002 -

Boron mg/l 0.5 2.4

Cadmium mg/l 0.001 0.003

Chromium (III) mg/l 0.5 0.05(P)

Cobalt mg/l 0.1 -

Copper mg/l 1 2

Iron mg/l 0.3 -

Lead mg/l 0.03 0.01

Mercury mg/l 0.0005 0.006

Nickel mg/l 0.1 0.07

Magnesium mg/l 20 -

Manganese mg/l 0.1 -

Molybdenum mg/l 0.25 -

Selenium mg/l 0.01 0.04(P)

Sodium mg/l 200 -

Vanadium mg/l 0.1 -

Zinc mg/l 5 -

Organics

Benzene mg/l 0.01 0.01

Toluene mg/l 0.5 0.7 (C)

Ethylbenzene mg/l 0.01 0.3 (C)



Parameter Units National MAC WHO Drinking water guidelines

Total Xylenes mg/l 0.05* 0.5 (C)

Benzo(a)pyrene mg/l 0-0.005 0.0007

Naphthalene mg/l 0.01 -

Total Petroleum Hydrocarbons mg/l 0.1 -

Total Coliforms mg/l absence -

Key : MAC – Maximum Acceptable Concentration (RK No.104, 18/01/12) WHO – World Health Organisation ‘Guidelines Drinking Water Quality’ (Annex 3) (WHO, 2011) C – based on taste P – provisional

9.3.6 Determination of Impact Significance

Potential impacts of the Project on geology, soils and groundwater are identified through consideration of: Any site investigation of land/water contamination; Construction activities, such as ground clearance, road construction, piling and excavations; Operation of the Project; and Decommissioning of the Project.

There will be no discharges of industrial process wastewater from the Project therefore this is not considered further in this section.

Based on the assessment framework set out in Section 5 the following section provides further information regarding the proposed methodology to determine the significance of impacts related to ground conditions. The significance of potential impacts is a function of the sensitivity of the receptor associated with ground conditions, and the magnitude (duration, spatial extent, reversibility, likelihood and threshold) of the impact.

Table 9.3 presents the criteria for determining the sensitivity of geological, soil and groundwater receptors.



Table 9.3: Criteria for Determining Sensitivity of Features

Importance/Value of soil

Definition

High Agricultural Land (soil of excellent quality with no limitations, can support a very wide range of agricultural crops); or nationally or internationally important for its geology; or groundwater resources used for major potable supplies with limited potential for substitution.

Medium Agricultural Land (soil of good quality with minor limitations, can support a wide range of agricultural crops); or regionally important for its geology. Groundwater quality suitable for industrial/agricultural use without treatment (abstraction point/s within 1km of the site boundary)/slightly saline groundwater which requires treatment for use as drinking water; and/or moderate level of substitution.

Low Agricultural Land (soil of good to moderate quality with moderate to moderately severe limitations, can sometimes support a wide range of agricultural crop, or cereals and scrubland); or locally important for its geology. Limited groundwater supply or moderate salinity groundwater suitable for industrial use following treatment; and/or high level of substitution.

Negligible Agricultural land (soil of poor quality with severe limitations, supports mainly scrubland), not important for its geology. No groundwater present beneath the site or groundwater highly saline and unsuitable for use.

All human health receptors are considered to be of high value.

Table 9.4 presents the criteria for determining the magnitude of impacts on geology, soils and groundwater.

Table 9.4: Criteria for Determining Magnitude of Impact

Magnitude of Impact

(positive or negative)

Criteria

Major Negative Fundamental change to the specific environmental conditions resulting in loss of feature.

The Project (either on its own or with other projects) may result in physical removal or degradation (including loss of structure and contamination) of a large area of soil.

May affect the integrity of the groundwater body either in terms of quality or quantity and could render it permanently unusable.

The function of the groundwater body is impacted such that there is a substantive and permanent change in function (i.e. changes in flows/ availability for abstraction).

Moderate Negative Detectable change to the specific environmental conditions resulting in impact on integrity of feature or loss of part of feature.

Physical removal or degradation (including loss of structure and contamination) of a moderate area of soil.

The quality or quantity of the groundwater body would be reduced such that moderate works would be required to ensure continuity of its existing use or function.

The function of the groundwater body is impacted such that there is a moderate and measurable change (+ve/-ve) in function (i.e. changes in flows/ availability for abstraction).

Or, a major impact that only affected the groundwater body for a limited time frame and was reversible and could be mitigated by some temporary works.

Minor Negative Detectable but minor change to the specific environmental conditions resulting in minor impact on feature.

The impacts result in the physical removal or degradation (including loss of structure and



Magnitude of Impact


Criteria

contamination) of a minor area of soil.

The quantity or quality of the groundwater feature and a measurable change would be seen but the manner of change would not materially affect the use or function of the feature.

Negligible Results in an impact on feature but of insufficient magnitude to affect the use or integrity.

The impact would lead to no observable change in the features.

Minor Positive Detectable but minor change to the specific environmental conditions resulting in minor positive impact on feature.

Physical permanent improvement of the condition of a moderate area of soil either through remediation of soil contamination, replacement with high quality soil or removal of potential contamination source. Improved agricultural/ ecological value.

No physical improvement in soil quality but introduction of a permanent barrier to migration of contaminants preventing impacts to receptors such as groundwater, humans etc

Temporary or minor positive change in groundwater quality, flow or availability for abstraction, but the manner of change would not materially affect the use or function of the feature.

Moderate Positive Detectable change to the specific environmental conditions resulting in partial recovery of feature.

Physical permanent improvement of the condition of a moderate area of soil either through remediation of soil contamination, replacement with high quality soil or removal of potential contamination source. Improved agricultural/ ecological value.

Moderate permanent change in groundwater quality, flow or availability for abstraction such that it becomes usable to a greater degree than previous.

Major Positive Fundamental change to the specific environmental conditions resulting in complete recovery of feature.

Physical permanent improvement of the condition of a large area of soil for example through remediation of soil contamination, replacement with high quality soil or removal of potential contamination source. Substantially improved agricultural/ ecological value.

Substantive permanent change in groundwater quality, flow or availability for abstraction such that it becomes usable to its full capacity.

The magnitude of the impact and value of the features impacted are combined to determine the likely significance of each impact (see Section 5). The predicted effect may be modified by professional judgement. If the impact is negative then the effect is adverse, if the impact is positive then the effect is beneficial.

9.3.7 Assessment of Environmental Effects With Respect to Contaminated Land

The Project area is located on previously undeveloped green field land that is unlikely to have historically been affected by contamination. However, baseline surveys of the ground and groundwater conditions have been undertaken to confirm the existing soil and groundwater quality. This assessment identifies and assesses the potential impacts that contamination risks, if present, may pose on the geology, soils and groundwater sensitive receptors. Where mobilisation of contamination occurs, contamination may spread and affect a larger area and such mobilisation may have secondary impacts on human health and ecological receptors. The assessment addresses the impacts related to the existence of, and/or creation of contaminated land as a result of the construction, operation and decommissioning of the Project.



This assessment follows the standard ESIA methodology for assessment of impacts from existing contamination and potential future contamination from the Project to the defined ground receptors (primarily soil, geology and hydrogeology with consideration of secondary receptors such as human health and ecology).

9.3.8 Data Limitations

To the extent that some of the assessment in this report is based on information obtained in ground investigations, persons using or relying on this report should recognise that any such investigation can examine only a fraction of the subsurface conditions. As such, unexpected contamination could be encountered during the course of the construction work, although significant contamination is not expected on this green field land.

Much of the baseline geology and hydrogeology used for this assessment has been sourced from the national OVOS. Where possible, surveys have been undertaken to confirm the conditions described.


9.4.1 Overview of Existing Site Conditions

The Project site is located on previously undeveloped land. The land is currently flat (following recent clearance activities) with the exception of a large Sur (shallow depression with salt crust) in the eastern half of the site, which will remain undeveloped. The Project site is surrounded by desert directly to the north, east and west. A large area of land has also been cleared adjacent to the south of the site for future development of the butadiene and polymer production plant. A railway line has been constructed along the eastern edge of the Project site, and a new station is located to the northwest.

Within the Project boundary, the soil cover has recently undergone significant changes associated with the filling and levelling activities which have been undertaken in preparation for the various developments. Any previous vegetative cover has been completely removed. Land immediately surrounding the site has also undergone significant disturbance as a result of vehicle movements on unsurfaced ground, associated with land clearance and rail construction activities.

Three groundwater monitoring wells have historically been constructed in the area of the Project site, two within the eastern half of the site, and one approximately 150m to the east of the site boundary.

9.4.2 Geology

Regional Geology

Atyrau province is located within the North Caspian Basin, a flat lowland encompassing the northern end of the Caspian Sea and a large plain to the north of the sea between the Volga and Ural Rivers, and further east to the Mugodzhary Highland, as shown in Figure 9.1 below. The basin is bounded by the Palaeozoic



carbonate platform of the Volga Ural Province to the north and west and by the Ural, South Emba and Karpinsky Hercynian foldbelts to the east and south. The basin was formed by pre-Late Devonian rifting and subsequent spreading of the oceanic crust (Ulmishek, 2001).

Figure 9.1: North Caspian Basin, Kazakhstan

Source: Figure 1 from Ulmishek (2001)

The North Caspian Basin is one of the deepest basins in the world and is thought to be underlain by oceanic or thinned continental crust in the central basin areas. The overlying sedimentary strata are



understood to be more than 20 km thick and generally comprise a sequence of Proterozoic to Lower Permian sub-salt complex, overlain by a thick salt-dome complex of highly deformed Kungurian age saliferous sediments, which in turn are overlain by Upper Permian to Tertiary supra-salt strata. The sub-salt complex is comprised of sequences of carbonates on the basin margins and deep water shale facies in the centre of the basin. Shallow water carbonate rocks along the basin margins contain significant hydrocarbon reserves in reef reservoirs. The latter supra-salt sediments are comprised of Triassic continental clastic rocks overlain by mixed continental and marine rocks. (Shlezinger, 1984, Dyman et. al, 2001, and Ulmishek, 2001) The upper 2.5 km of the basin is comprised of carbonate sediments which are unconformably overlain by Quaternary clays, sands, silts and minor limestone in the western part of the basin.

At the surface, the North Caspian Basin is generally occupied by desert ridges and sand dunes which cover an area of more than 200,000 km2.

Geology of the Development Area

Land within the development area is characterised by gently undulating marine terraces of Pleistocene age. The shallow sedimentary geology comprises the dried base of the relatively recently receded Caspian Sea characterised by a broadly level surface with traces of the former coastlines and beach ridges. The surface is covered with dried lakes and shallow depressions of varying sizes, aligned along the former coastlines associated with different levels of the retreating Sea. Areas between the Ural and Volga rivers and their tributaries are generally formed of flat plains covered with small drainage basins as well as individual salt lakes.

The Engineering Geological Map for the study area (as referenced in the OVOS baseline study undertaken by Tetracon Engineering) reportedly shows that the proposed development area is surfaced with marine sand, sandy loam and loam sediments, underlain by clays and sands. Investigation undertaken by the Caspian Institute of Exploration Geophysics in 2006 and 2009 identified subsoils in the area of the proposed development comprising layers of sand, clay and loam, over silts containing carbonates and shells.

Seismicity

The seismic zoning map of the Atyrau region (as referenced in the OVOS) indicates that the seismicity of the area is estimated to be at an intensity of 5 on the Medvedev-Sponheuer-Karnik (MSK-64) seismic scale. This is also reported in the OVOS to be supported by the general seismic zoning map of North Asia.

The MSK-64 seismic scale is a macroseismic intensity scale used to evaluate the severity of ground shaking on the basis of observed effects in an area of the earthquake occurrence. The scale has 12 intensity degrees. A value of 5 on the MSK-64 scale constitutes a fairly strong intensity earthquake, which could cause slight damage to poorly constructed buildings. In accordance with Building Regulation SNIP 1.22.95 (Geophysics of Natural Hazard Processes) a seismic intensity value of less than 6 constitutes a moderately hazardous degree of danger (the least hazardous category).



The WHO Seismic Hazard Distribution Map for Kazakhstan (WHO, 2010) indicates that much of the central, northern and western areas of Kazakhstan, including the Atyrau region, have a seismic hazard rating of between 0-0.2 Peak Ground Acceleration (PGA) m/s2

, classified as ‘very low’.

These classifications broadly characterise the seismicity of this region. However, an assessment of the local seismicity should be undertaken to support detailed building design, to ensure that buildings provide the correct level of protection for seismic risk in the Project area.

9.4.3 Soils

Soil Type

The Atyrau region is characterised by a semi desert landscape covered with brown desert-steppe soils with scarce vegetation, and interspersed with salt marshes.

A distinctive feature of the soil forming processes in the Caspian region is the widespread formation of salt accumulations at the surface and within the upper soil horizons. Due to high temperatures experienced in summer, and the resultant significant evaporation of precipitation and highly mineralised groundwater (associated with the geology of the region), water-soluble salts accumulate in shallow soils (Teng EIA) forming Solonchaks. Solonchak are defined as soils having a salic horizon within 0.5m from the soil surface, and are formed when salts dissolved in the soil moisture are left behind during evapotranspiration (Food and Agriculture Organisation - http://www.fao.org/docrep/003/y1899e/y1899e09.htm). Within the project area, soils can therefore be broadly defined as poorly formed saline soils. Typical soils are presented in the following pictures:

Figure 9.2: Soil on the Project site Figure 9.3: Project site Sur


Much of the project area is also covered with shallow depressions, known as ‘Sur’. These are natural relief

depressions and low lying areas where water collects when it rains or snows. During dry periods evaporation of surface water and shallow mineralised groundwater leaves a saline crust. A large Sur is located within the eastern boundary of the Project Site which will be retained as part of the works.

http://www.fao.org/docrep/003/y1899e/y1899e09.htm



The main soil types within the Project area comprise desert brackish soils and brown solonetic-brackish soils (Envirs Consulting, 2014). The upper organic horizons of desert brown soils vary in composition, depending on the parent rock, but are generally defined as loamy soils found up to 0.3-0.4m in depth and sandy loam, up to 0.5m in depth. The humus content of these soils is low, <1.5% in the loam soils and <0.5% in the sand loam soils. A carbonate crust is generally present at the surface, although the highest concentrations of carbonate are found below the organic horizon.

Brown solonetic-brackish soils, with occur more frequently in the Project site area, comprise a more solonetic horizon, salt accumulation horizon and are more clayey. An elevated water soluble salt content (>0.25%) is also a characteristic of the upper 0.3m of these soils.

Due to their low fertility these soils are considered to have little agricultural use.

Local Soil Conditions

Based on ground investigation undertaken in 2014 (Envirs Consulting, 2014), soils across the Project site reportedly generally comprise brown saline loam. The shallow soil profile was found to comprise a thin loamy crust at the surface overlying thin (~0.1-0.2m thick) well defined inter-bedded layers of loam. Rootlets were encountered in the upper soil layers, generally above 0.4m, but deeper in places. Small salt inclusions were identified in the deeper soil horizons below ~0.3m bgl. Within the top metre, the soils generally become heavier and moist with depth, and the salt inclusions become more frequent. In many areas the upper layers have been disturbed by anthropogenic activities, most likely to be related to vehicle movements within and surrounding the site.

The Sur, located in the eastern part of the site, has not been included in the levelling and site preparation activities. The Sur was found to generally comprise a thin salt crust over a very thin layer of loam, which is in turn underlain by interlayers of blue-green moist clayey loam with rust spots and significant salt inclusions. Below 0.6m the soil is a dark brown moist compact loam with salt accumulations.

Results of the intrusive survey show that topsoil has been removed and replaced with compacted made up ground across the Project site. Here, the upper imported soil layer generally comprises sandy loam with some salt inclusions. This overlies the existing subsoil horizons described previously. The boundary between these layers is uneven and in places the horizons are intermixed.

Soil Quality

An assessment of soil quality at the Project site has been undertaken based on a ground investigation, including soil testing, undertaken by Envirs Consulting in May 2014. Testing was undertaken on soils samples collected from the Project site and nearby surrounding area. A plan showing the location of the sampling points is presented in Figure 9.4 below.



Figure 9.4: Map of Soil and Groundwater Sampling Points



Source: Envirs Consulting, 2014



Fourteen soil samples were collected, for the purpose of laboratory testing, from a total of 13 locations (P1-P13) within the Project site boundary, to support an assessment of the potential risks to the health of future construction and site workers who may come into contact with the soil. Six samples were taken at a depth of 0.1-0.2m bgl and six from 1m bgl. Two samples were also collected from the centre of the Sur (P9) in the eastern area of the proposed Project site at depths of 0.1-0.2m bgl and 1m bgl. Sampling was based on a systematic (non-targeted) sampling strategy using a herringbone grid pattern, using an approximate sample spacing of 400m.

Since the soils within the site boundary have been disturbed and in places replaced for levelling and filling activities, soils within the site boundary (with the exception of soil in the Sur, which have remained undisturbed) are not considered to be representative of the baseline ground conditions at the site. To assess the likely environmental baseline conditions at the Project site, 16 samples were also taken from undisturbed soils at nine locations (P14-P22) in the nearby surrounding area to the north (P14-P16), south (P18 and P19), east (P17) and west (P20-P22) of the Project site boundary at depths of 0.1-0.2m and 1m bgl. These are believed to be most representative of the site conditions prior to clearance.

Testing for pH, inorganics, heavy metals, TPH, phenols, PAHs and BTEX was carried out on all samples. Testing for mobile metal compounds was also undertaken on eight shallow and seven deeper soil samples from across the Project area and from the surrounding area. A summary of the testing results compared with national (MAC) and international human health guidance levels (CCME and DIV) where available is presented in Table 9.5.

The testing results for both the shallow (0.1-0.2m bgl) and slightly deeper (1m bgl) soils from within and surrounding the Project site indicate that soils are neutral to slightly alkaline, and have a high salinity, with chloride levels recorded between 32-12194 mg/kg (87% above 700 mg/kg) and sulphate levels between 60-6111 mg/kg, in the top 1m of soil;

The results indicate that low concentrations of metals were identified in shallow soils (<1m bgl) across the site and surrounding area, but the majority do not exceed the relevant national MACs. Slightly elevated concentrations of mobile chromium (III) were found exceeding the respective national MAC in the majority of samples (13 out of 15) tested. Low concentrations of TPH, PAHs and benzene were detected in all soils but these were well below the relevant MACs. Phenols were not detected above the laboratory detection limits in any of the soil samples tested.

By way of comparison, the concentrations have also been assessed against CCME and Dutch Intervention Values (DIV) (see Section 9.3.3 for more information on the international guidance values). Only one exceedance was noted for metals, nickel was found at a concentration slightly exceeding the CCME CEQG in shallow soils (0.1-0.2m bgl) at P20 located off-site to the southwest of the Project site. Low concentrations of benzene were detected exceeding the CCME CEQG in thirteen shallow soil samples (between 0.1-0.2m bgl) from across the Project site and surrounding area. Concentrations do not exceed the Dutch guidance criteria in any sample.



The calculated sum of 10 PAHs for all samples were not found exceeding the DIV of 40 mg/kg. The concentrations of carcinogenic PAHs have been compared with CCME soil guideline values for risks to human health, and all PAHs have been compared to environmental health guidelines. The results of the assessment indicate that the cumulative concentration of carcinogenic PAHs benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(ghi)perylene, chrysene, dibenzo(ah)anthracene and indeno(123 cd)pyrene (1.4 mg/kg) were well below the CCME human health-based soil quality guideline of 1 mg/kg for industrial land use. None of the samples exceed the environmental guidance values for industrial land use.

In summary, the results indicate that concentrations of metals and organics (TPH, PAH and VOCs) in soils are generally low. Slight exceedances of the MACs for mobile chromium (III) have been identified. Concentrations of these metals do not vary widely and are all within the same order of magnitude. Based on the absence of any current or historical local sources of contamination, and the similarity of the measured concentrations both vertically in shallow soils and spatially across the Project area, it is considered that these are broadly indicative of natural ground conditions.

Slightly elevated concentrations of benzene in shallow soils between 0.1-0.2m bgl exceed the CCME CEQG but not the MAC or Dutch guidance values.



MAC Intervention Values (DIV) (Industrial)

Minimum (mg/kg)

Maximum (mg/kg)

(mg/kg) Number of exceedances



Mobile 15 5.64 8.95 6* 13 - - - -

Mobile 15 0.52 0.986 3* 0 - - - -

Mobile 15 0.6 1.71 4* 0 - - - -

Mobile 15 0.83 2.69 23* 0 - - - -

Analyte Total samples tested

Concentration National Dutch

CCME CEQG

Metals

Arsenic (tot) 30 0.33 1.45 2 0 76 0 12 0

Barium (tot) 30 185.6 458.9 - - 920 0 2000 0

Beryllium (tot) 30 <0.001 <0.001 - - - - 8 0

Cadmium (tot) 30 0.36 0.9 2 0 13 0 22 0

Chromium (III)

Total 30 15.7 42.1 - - 180 0 87 (tot) 0

Cobalt (tot) 30 4.96 12.5 - - 190 0 300 0

Copper Total 30 3.84 19.7 - - 190 0 91 0

Lead (tot) 30 4.8 13.5 32 0 530 0 600 0

Manganese (tot) 30 170 585 1500 0 - - - -

Mercury (tot) 30 0.04 0.18 2.1 0 4 0 50 0

Molybdenum (tot) 30 1.05 2.78 - - 190 0 40 0

Nickel Total 30 17.2 53 - - 100 0 50 1

Selenium (tot) 30 0.012 0.34 - - - - 2.9 0

Vanadium (tot) 30 45.3 79.2 150 - - - 130 0

Zinc Total 30 27.9 69.4 - - 720 0 360 0



Data Source: (Envirs Consulting, 2014) Key: * Sum of 10 PAHs (naphthalene, phenanthrene, anthracene, fluoranthene, benzo(a)anthracene, chrysene, benzo(k)fluoranthene, benzo(a)pyrene, indeno(123-cd)pyrene and

benzo(ghi)perylene) (tot) - total

Concentrations exceed National MAC

Concentrations exceed the MAC, DIV and/or CCME

Organics

TPH (mineral oil) 30 5.06 14.06 1500 0 5000 0 1700 0

Benzo(a)pyrene 30 1x10-7 0.00017 0.02 0 - - - -

PAH (sum of 10)* 30 0.0047 0.11 - - 40 0 - -

Benzene 30 <0.005 0.057 0.3 0 1.1 0 0.0068 13

Toluene 30 <0.005 <0.005 0.3 0 32 0 0.08 0

Ethylbenzene 30 <0.005 <0.005 0.3 0 110 0 0.018 0

Xylenes (sum) 30 <0.005 <0.005 0.3 0 17 0 2.4 - 11 0



9.4.3.1 Radiation Survey

An assessment of gamma radiation was undertaken at the Project site during ground investigation undertaken by Envirs Consulting in May 2014. Testing was undertaken at each of the soil sampling locations on the Project site and in the nearby surrounding area (P1-P22). A plan showing the location of the sampling points is presented in Figure 9.4 above. Details of the testing are presented in the Envirs Consulting survey report (2014).

The results of the testing show that gamma radiation levels vary between 0.041 and 0.054 µSv/h (0.359 and 0.47 mSv/y). According to UNSCEAR (2000) the typical effective dose world wide of Terrestrial gamma rays (background) is 0.5 mSv/y with a typical range of 0.3 – 0.6 mSv per year.

9.4.4 Hydrogeology

9.4.4.1 Groundwater

The IPC is located within the Caspian hydrogeological region which comprises lowland filled with sedimentary deposits of the Paleozoic, Mesozoic and Cenozoic. Groundwater aquifers are present in permeable Quaternary and Cretaceous sediments across the Caspian Basin. Groundwater is found in layers of more permeable sands, separated and confined by layers of clay. According to the OVOS, Upper Quarternary aquifers include the Novokaspiysk aquifer, which comprises a dense loam and fine sand with a depth of 5-9m. Groundwater level is 2.4-3m bgl. This aquifer is separated from the underlying Khavalynsky aquifer by dense brown clay. The deeper aquifer comprises fine sends and loam and the groundwater level is reportedly 10m bgl. The aquifer is recharged by limited precipitation (mainly snow melt) collecting in Surs and possibly inflow from deeper aquifers. Regional groundwater flow is understood to be towards the Caspian Sea.

Within the site area shallow groundwater is reportedly present in sandy loam soils at depths between 3.4 and 6m bgl. Groundwater levels fluctuate seasonally by 0.5-0.7m (OVOS).

Shallow groundwater salinity varies between 50-120 g/l with a general chloride-sulphate-sodium composition. Based on the general composition groundwater is understood to be highly aggressive to concrete structures.

There are three existing groundwater monitoring wells located within the eastern area of the Project site. These wells monitor groundwater to a depth of 15m bgl. Groundwater levels were recorded at 4.7m bgl (Well 1), 5m bgl (Well 2) and 4m bgl (Well 3) during the field survey in 2014. Based on these results groundwater levels are considered to be in the region of 4-5m bgl, although these are expected to be subject to seasonal fluctuations.



9.4.4.2 Groundwater Quality in the Project Area

An assessment of groundwater quality at the proposed development site has been undertaken based on a sampling and testing of groundwater from existing monitoring wells within the Project area, undertaken in May 2014. Testing was undertaken on groundwater samples taken from three groundwater monitoring wells, in the eastern half of the proposed development site. The location of these monitoring sites is presented in Figure 9.5 below.

Figure 9.5: Location of Groundwater Monitoring Wells (1 – 3)

Source: Envirs Consulting, 2014

Testing for major ions, total coliforms, pH, heavy metals, petroleum products, BTEX and PAHs was undertaken on all three groundwater samples on one occasion. A summary of the testing results (where detected above the laboratory method reporting limit) compared with national and international human health guidance levels is presented in Table 9.5.

The water quality testing generally indicates that groundwater beneath the site is slightly alkaline and highly saline, with chloride concentrations measured between 65000-73000 mg/l and sulphate between 10000-12000 mg/l. The groundwater would be unsuitable for drinking or technical water without treatment.



The results indicate that very low concentrations of some organic contaminants (TPH and PAHs) were identified in groundwater samples, but none of these exceed the available national MAC values or the WHO guidance levels for drinking water. No BTEX were found at concentrations above the laboratory detection limits.

Very low concentrations of some heavy metals (barium, chromium (III), copper, iron and zinc) were also identified in groundwater samples but none of these exceed the national MAC or the WHO guideline values, with the exception of iron which was found at concentrations exceeding the national MAC in all samples. There is no WHO guidance level for iron in drinking water. Elevated concentrations in groundwater are considered to be natural, relating to naturally high concentrations in soils. All other metals tested were below the laboratory detection limits. No coliforms were identified in the groundwater samples tested.

Table 9.5: Contamination Concentrations in Groundwater

Analyte MAC (mg/l) WHO (mg/l) Well 1 (mg/l) Well 2 (mg/l) Well 3 (mg/l)

pH 6-9 - 7.74 7.85 7.94

Potassium - - 275 250 370

Calcium - - 6380 6400 5000

Chloride 350 - 72520 73046 64666

Ammoniacal nitrogen 2 - 4.47 4.35 2.22

Bicarbonate - - 331 336 345

Nitrate - 50 20.77 20.51 21.00

Fluoride - 1.5 0.051 0.048 0.052

Sulphate 500 - 11859 11927 10446

Alkalinity - - 5.69 5.5 5.65

Barium 0.1 0.7 0.0165 0.0154 0.0123

Chromium (III) 0.5 0.05 0.006 0.004 0.003

Copper 1 2 0.005 0.003 0.001

Iron 0.3 - 4.15 4.93 4.48

Magnesium 20 - 6550 6400 4900

Manganese 0.1 - 0.003 0.004 0.002

Sodium 200 - 4300 42000 38500

Zinc 5 - 0.022 0.018 0.013

Total PAH - - 0.146 0.459 LD

TPH 0.1 - 0.01 0.04 0.02

Source: Envirs Consulting, 2014 Key : LD – Less than the laboratory detection limit

MAC – Maximum Allowable Concentration (RK No.104, 18/01/12) WHO – World Health Organisation ‘Guidelines Drinking Water Quality’ (Annex 3) (WHO, 2011)

Concentrations exceed National MAC

Concentrations exceed the MAC and WHO guidelines



9.4.5 Historic and Potential Future Contamination Sources

The Project site and surrounding area (within 500 m) has not previously been developed or used for industry and therefore is unlikely to have been subject to significant contaminating activities. Groundwater within the Project area is therefore unlikely to have been significantly impacted by contamination caused by industrial activities. However, the groundwater is naturally highly mineralised and is not considered to be suitable for human consumption or most industrial uses without treatment.

The results of groundwater testing on the site indicate that neither, on-site or off-site activities have significantly impacted the groundwater quality beneath the Project site. Due to the highly mineralised composition of groundwater, the water may be corrosive to building structures, particularly foundations, and any buried services in contact with groundwater.

Low concentrations of metals have been found in soils across the Project area, but the majority do not exceed the national or international guideline values for protection of human health. Slightly elevated concentrations of mobile chromium (III) have been found in soils exceeding the national MAC and a slightly elevated concentration of nickel (53mg/kg) in one sample exceeded the CCME guidance value. Background ‘Clark’ bulk earth concentrations have been published for all metals (Voyitkevich, 1970). The concentrations of chromium recorded on site are well below the respective Clark concentration of 90mg/kg. The majority of nickel concentrations are below the respective Clark concentration (40mg/kg) with the exception of one sample. The Agency for Toxic Substances and Disease Registry (ATSDR) report that background levels of nickel in soils in the United States (US) are between 4-80 mg/kg. The World Health Authority report that agricultural soils across the world contain nickel at levels between 3-1000 mg/kg (WHO, 2000). This would indicate that the concentration of nickel found in soils at the Project site are within the US and global range. These exceedences are not considered to present a significant risk to human health receptors.

Slightly elevated benzene concentrations have been detected in shallow soils across the site. Based on the understanding that there have been no historical industrial activities at the site and the site has not been previously developed, it is considered that these concentrations may be related to recent ground work activities on site. These concentrations slightly exceed the international CCME guidance values but do not exceed the local MACs or the international Dutch guidance values. A report published by the UK Environment Agency on the derivation of benzene guidance criteria reported that the European Central Bank (ECB) estimate that the background concentration of benzene in soils across Europe is 0.02mg/kg on the basis of known releases to the environment and its modelled behaviour (Environment Agency, Science report SC050021). The majority of concentrations recorded in soils across the site fall below this value. Benzene is a volatile substance which dissolves in water. It is expected that low concentrations of benzene in soil will be subject to volatilisation and degradation such that, based on the understanding that there is no ongoing source, they would not present a future risk to site workers. The risks to construction workers from benzene in soils will require further assessment, but could be mitigated by the use of suitable personal protection equipment (PPE). Additional testing and assessment will be undertaken prior to development of the site.



Potential sources of contamination from the future construction and operation of the Project are mainly associated with the transport, storage and use of hazardous materials. A full list of hazardous materials used in the operation of the Project is presented in Section 12. However, the main contaminants are considered to be: propane, propylene, ammonia, phosphate, catalysts, oil, lubricants, fuels and other chemicals related to the site processes, such as those for water treatment.

9.4.6 Value of Geology, Soils and Groundwater

The geology in the Project area is assessed as having a negligible geological value, as there are considered to be no sensitive geological features in this part of the Project area.

Soils within and surrounding the Project area are understood to be highly saline, have a low fertility and water content, and are generally considered to be unsuitable for agriculture. Based on the results of the soil quality testing, the soils within and surrounding Project area contain slightly elevated concentrations of chromium (III) and nickel but these are not considered to present a significant risk to human health receptors. Slightly elevated concentrations of benzene have been detected in soils. The soils are considered to have a negligible value / sensitivity based on the criteria for determining sensitivity of features (Table 9.3).

Similarly the geology and soils located along and surrounding, the route of the new water pipeline are considered to have a negligible value / sensitivity. A survey of soil quality along the water pipeline route has not been undertaken at this stage. Due to the targeted nature of ground investigation it would not be possible to survey soil quality along the entire length of the route. It is not considered necessary to undertake an intrusive survey at this stage of the Project. However, it is possible that localised areas of contamination or aggressive ground conditions could be encountered, associated with current or historic industrial activities or natural ground conditions, during the construction works. It may be necessary to undertake targeted geotechnical and contamination intrusive investigations at a later stage to support detailed design of the pipeline.

Across the region, groundwater in the upper aquifer is understood to be present at depths 6-10 m below ground level. Water quality testing indicates that groundwater this aquifer is highly saline and would not be suitable only for industrial use without prior treatment. There are no known abstractions from this aquifer within 500 m of the site. Groundwater beneath the site is therefore considered to be a low sensitivity receptor


9.5.1 Potential Impacts of the Project

9.5.1.1 Overview

The main Project components which may impact on soil and groundwater quality are considered to be: Site preparation including levelling ground preparation within the Project area.



The construction and operation of the PDP and PP and associated infrastructure, including: – A new road connecting the IPC with the existing A27 highway; – A new railway line with station connecting the IPC with the existing railway line to the south; – Warehouse for storage of the polypropylene pellets; – Waste water treatment plant; – Flares; and – New gas pipeline.

Construction and operation of 27km buried water pipeline between the IPC and the existing Astrakham to Mangystalk pipeline.

The following assessment also covers seismic risk in relation to potential contamination impacts.

Potential impacts relating to the above components are discussed separately in the following sections. Based on an initial assessment for this Project, the principal potential impacts to soil and groundwater during all phases of the Project include: Storage and handling of soils, and subsequent loss or degradation of soils via erosion as a result of

ground works. Degradation of soil or groundwater quality as a result of leaks and spills of hazardous materials

(including waste) during their transport, storage, handling and disposal.

Soil and groundwater are potentially at risk of contamination from the construction, commissioning and operational activities of all of the Project facilities, including the management of wastewater and other fluids generated by the Project and the storage and handling of other hazardous materials. There is also the potential for secondary impacts to human health as a result of soil and groundwater contamination.

There will be no discharges to ground or groundwater of industrial process wastewater from the Project as the Project will operate a closed circuit zero-discharge waste water system. This is not considered further in this chapter.

The potential for impacts to soil and groundwater from contamination resulting from construction and operation of the Project are discussed below. For all aspects of the construction, operation and decommissioning works, there is the potential for secondary impacts to construction and site workers from the handling of hazardous materials including contaminated soils. Where relevant, these impacts are also discussed in the sections below. However, the Project will be constructed and operated following International Standards which include use of appropriate Personal Protective Equipment (PPE) and adherence to standard construction methods. The possibility of construction workers being impacted by contaminated land is low.


9.5.2.1 Site Preparation

Parts of the IPC has already been levelled and prepared for the Project. Movement and reworking of soils could lead to degradation, erosion and/or loss of soil cover. Compaction of soils can cause secondary



impacts on soil drainage. The soils in the Project area are considered to have a negligible value. However the area affected is considered to be significant in size (165ha) and the effect will be permanent, therefore the magnitude is considered to be major negative. Impacts to the soil are assessed as insignificant.

Prior to undertaking the levelling works, the upper 0.1m of topsoil was removed for off-site storage. It is proposed to re-use this material for re-cultivation of the Project area when the construction is complete, although it is unclear to what degree re-cultivation is possible, considering the poor vegetative status to the site prior to clearance. Construction of the buildings and hard surfacing, and re-vegetation (if possible) of undeveloped areas will act to reduce erosion.

Site levelling activities included importing soils from the surrounding area to fill depressions and provide a level surface for building construction. The provenance and quality of the imported material is not known. However, testing of the imported material was undertaken during the intrusive field survey in 2014. The results of the testing indicate that the quality of the imported soils does not vary significantly from the natural soils in the areas surrounding the site. These soils contain slightly elevated concentrations of mobile chromium, but based on comparison with the respective international guidance values, these are not considered to present a significant risk to human health receptors. Benzene concentrations detected in shallow soils are considered unlikely to present a significant risk to future site users.

The site levelling will have a significant impact on the soil properties and drainage properties which will in turn affect the drainage of potential melt water and precipitation run-off and infiltration. This will have a moderate effect on groundwater recharge in the area.

Impacts to the shallow groundwater will be limited to the Project area and will not significantly change the regional groundwater regime. Groundwater is considered to have a low value/ sensitivity. The magnitude is considered to be minor-negligible. This impact is therefore assessed to be insignificant.

9.5.2.2 Construction within the IPC

Physical Loss or Degradation of Soil

Construction of the Project and associated infrastructure will be undertaken on previously undeveloped greenfield land (recently levelled to enable development). This will lead to the loss of approximately 165ha of land for the development. The magnitude of this effect is considered to be major negative. However, Soils on the site of the Project are considered to have a negligible value due to their poor quality and low agricultural value. The impact is therefore considered to be insignificant.

Disturbance of soils during construction, particularly due to movement of vehicles, may lead to erosion of the upper soil layers. A subsequent secondary effect of erosion includes creation of dust. Based on the soil survey results, soils within the Project area contain slightly elevated concentrations of copper, nickel and zinc, but based on comparison with the respective international guidance values, these are not considered to present a significant risk to human health receptors. However, creation of dust may have implications for human health and ecological receptors near to areas where construction activities are to be



carried out. The potential impacts from the creation of dust are discussed in more detail in the Air Quality Chapter (see Section 8).

Contamination of Soil

During construction, a range of potentially hazardous substances would be used, such as oils, lubricants, fuels and cement. These materials will also require transport to the site. Accidental spills or leakages of hazardous substances may result in local contamination of soils, with potential implications for groundwater. However, with current best practice construction site management the probability is considered low enough as to present an insignificant risk.

The magnitude of contamination impacts to soils would be minor to moderate negative. However, based on the negligible value of soils in the Project area, impacts to soils are assessed as insignificant.

Impacts to Groundwater

Based on our understanding of the hydrogeology in the immediate Project area, groundwater quality is understood to be poor and is considered to have a low sensitivity / value.

Soils will be exposed to site activities for at least some of the construction work, due to the absence of any hard cover. There will be little or no protection of soils, and therefore groundwater, from leaks and spills. There is the potential for contamination from the construction activities to affect groundwater quality in the shallow aquifer. The magnitude of this environmental effect is assessed as being minor and the impact is therefore considered to be insignificant. In the event of a large scale contamination event such as a tanker spill, the impacts to groundwater quality could potentially be minor adverse.

Depth to groundwater level is between 4-5m bgl. Shallow foundations are unlikely to interact with the groundwater. Construction of deep piled foundations has the potential to impact groundwater quality although the impacts will be localised. In this instance the magnitude of impacts to groundwater quality would be minor negative. Due to the low value of groundwater this impact is considered to be insignificant. Conversely, naturally aggressive ground conditions have the potential to impact building structures including foundations (discussed below) and buried utilities.

Groundwater is not currently abstracted for potable, domestic or industrial use and it is not proposed to use groundwater for the water supply during construction works on the Project. There is not anticipated to be any impact from the construction work on groundwater level, flow rate or flow direction. Construction on the site will have an effect on infiltration and evapotranspiration, due to changes in the ground profile, compaction of the soils and the presence of impermeable hard surfacing. However, due to the low level of precipitation, this is unlikely to have a significant effect on groundwater quality.

Wastewater

A range of potentially contaminated waste liquids will also be produced during construction activities including: concrete wash water; sewage effluent; surface runoff and waters for hydrotesting, washing and



cleaning (particularly during facility start up). All wastewater and liquid waste streams for the Project will ultimately be treated at the dedicated IPC WWTP for re-use within the plant. However, during construction, particularly prior to construction of the site drainage system, it is anticipated that some run-off, particularly due to ice and snow melt in Spring, will not be captured by the sites drainage.

If uncontrolled or untreated, discharge of waste waters could have a minor magnitude of impact on soils and groundwater due to the composition of the water and potential presence of pollutants. Based on the negligible value of soils and low value of groundwater in the Project area, impacts to soils and groundwater are assessed as insignificant.

Impacts relating to wastewater sludge and liquid waste streams are discussed in more detail in Section 10 Water Resources and Water Quality.

Buildings and infrastructure

Due to the recorded naturally high salinity of groundwater and soils beneath the site, ground conditions could be highly corrosive to concrete and metal structures, for example reinforced concrete, buried foundations and any piled foundations constructed below the groundwater level. This is particularly significant soils where the groundwater level fluctuates. This presents long term issues relating to the condition and safety of structures, including buried tanks containing hazardous materials, and buried drainage and pipes carrying hazardous materials.

Impacts to structures from corrosive ground conditions are considered to be significant and could lead to secondary impacts to groundwater and soil quality, and human health, if not suitably managed.

9.5.2.3 Water Pipeline

Physical Loss or Degradation of Soil

Construction of the water pipeline will involve disturbance of soils within a narrow corridor over 27km. Excavation of soils and the movement of traffic along the route could lead to erosion of the upper soil layers. As the work would be confined to a narrow corridor along the 27km route, this would have a minor magnitude of impact on soil conditions. Soils on the site of the Project are considered to have a negligible value due to their poor quality and low agricultural value. The impact is therefore considered to be insignificant.

Creation of dust may have implications for human health and ecological receptors near to areas where construction activities are to be carried out. The potential impacts from the creation of dust are discussed in more detail in the Air Quality Chapter (see Section 8).

Contamination of Soil

During construction, a range of potentially hazardous substances would be used, such as oils, lubricants, fuels, cement, and chemicals for water treatment. These materials will also require transport to the site.



Accidental spills or leakages of hazardous substances may result in local contamination of soils, with potential implications for groundwater. However, with current best practice construction site management the probability is considered low enough as to present an insignificant risk.

The magnitude of contamination impacts to soils would be minor to moderate negative. Based on the negligible value of soils in the Project area, impacts to soils are assessed as insignificant.


Based on our understanding of the hydrogeology in the immediate Project area, groundwater quality is understood to be poor and is considered to have a low value.

There will be little or no protection of soils, and therefore groundwater, from leaks and spills. There is the potential for contamination from the construction activities to affect groundwater quality in the shallow aquifer. The magnitude of this environmental effect is assessed as being minor and the impact is therefore considered to be insignificant.

Groundwater level is considered to be between 3-6m bgl. It is considered unlikely that construction works for burial of the pipeline will interact with the groundwater as it will be buried just below the surface.

Due to the recorded naturally high salinity of groundwater and soils in the area, ground conditions could be highly corrosive to the buried pipeline and associated structures. This presents potential long term issues relating to the condition of the pipeline.

9.5.3 Operation Phase

9.5.3.1 The Project and associated infrastructure

Similarly to the construction phase, the main potential contamination impacts for the Project are associated with the use, transport and storage of hazardous materials, and liquid waste disposal. Pollutants associated with the Project activities include propane, propylene, ammonia, phosphate, catalysts, oil, lubricants, fuels and other chemicals related to the site processes, such as those for water treatment (biocides and de-scalers). Impacts may result from leaks and spills from the storage and use of hazardous materials at the PDH plant and PP plant. However due to the design of the Project and the mitigation measures inbuilt this is very unlikely.

Many of the chemicals used at the sites are highly mobile and can potentially contaminate a large area. Without mitigation, chemicals encountering groundwater may migrate laterally, presenting risks to groundwater resources further afield. Some liquids may also migrate vertically in groundwater presenting a risk to deeper aquifers.

Water treatment chemicals used for conditioning cooling water, treatment of drinking water and wastewater, and cleaning of equipment could present a risk to the environment if present in discharge waters, runoff, or if introduced to the environment via leaks and spills.



Raw compressed liquid propane feedstock will be stored in buried ‘bullet’ tanks. Because of its low boiling point, compressed propane will vaporise on release to air. It is not therefore considered to present a risk to groundwater. Other materials will be stored in above ground tanks on the site. In accordance with local legislation and international guidance, all hazardous materials will be stored in bunded containers or on lined surfaces with surface drainage to the waste water treatment system. All wastewaters will be treated in the dedicated wastewater treatment plant for reuse on site and therefore there will be no wastewater discharges.

Seismic Impacts

The Project site reportedly has a low to moderate seismic risk. Further assessment will be required to establish the site specific risk to the development from seismicity in the area, to ensure that the structures are designed to a suitable standard to withstand earthquakes.

Earthquakes not only present a risk to building structures and human health, but also have the potential to damage drainage structures and containers for storage of hazardous materials. Impacts may result from resultant leaks and spills of hazardous materials and site drainage and process waste.

Impacts to Soil

Contamination has the potential to affect soil quality locally at the Project site. Depending on the extent of contamination (small or large spill/ leak) the magnitude would be minor to moderate. Soil is considered to be a negligible value receptor. Based on its low value, the significance of impacts to soils is assessed as insignificant.

Storage and handling of hazardous materials onsite will be undertaken in accordance with the site environmental health and safety plan to minimise the risk of leaks and spills and therefore the potential for impacts to the environment and human health.

If not suitably controlled soil contamination has the potential to impact groundwater, human health and ecology. There are no residents and there is no agriculture within the study area. The most likely receptors include site operatives and visitors who may come into contact with contaminated dusts, most likely via inhalation and ingestion. Human health receptors have a high value. Based on the most likely exposure route (inhalation and ingestion of dust) and the likely contamination related to the processes (organics mainly comprising hydrocarbons), health impacts could be short-term or chronic and therefore the magnitude would be moderate adverse. Taking into account the potential impact to human health, the significance of this effect is assessed as moderate adverse without mitigation.

Waste waters will be collected and treated for re-use on site. Accidental releases of contaminated waste water could occur due to poorly maintained drains or damage to the drainage system/ treatment works. The magnitude is assessed as minor negative. Potential impacts to soils from accidental wastewater discharge are assessed as insignificant due to the negligible value/ sensitivity of soil.




Despite the measures put in place for suitable transport, handling and storage of hazardous materials, and effective drainage of waste waters from the operation of the Project, there remains a potential risk of accidental spills, due to both small scale and large scale incidents. There is the potential for contamination, resultant from operational activities, to affect groundwater quality in the shallow aquifer. Groundwater in this aquifer is considered to be a low sensitivity receptor. The magnitude of this environmental effect is assessed as being minor negative depending on the scale of event, and the significance is therefore assessed as insignificant. In the event of a large scale contamination event such as a tanker spill, the magnitude would be moderate and therefore the impacts to groundwater quality would be minor adverse.

The potential impacts to groundwater from accidental wastewater discharge are assessed as insignificant.

It is not currently proposed to abstract groundwater for potable, domestic or industrial use. However, groundwater could be used for the water supply (with appropriate treatment) during the operational lifetime of the Project in the future. There is not currently anticipated to be any impact from operation of the plant on groundwater level, flow rate or flow direction. The impact to groundwater from abstraction, if required in future, has not been assessed in this document.

9.5.3.2 Water Pipeline

There are not considered to be any potential contamination impacts to soil or groundwater from the operation of the water pipeline as no potentially contaminating materials will be used in the operation of the pipeline. As the pipe will be buried, there are not considered to be any physical impacts to soil or groundwater from the operation of the pipeline.

9.5.4 Decommissioning Phase

Decommissioning phase activities are likely to be very similar to the construction phase. Good practice should be adopted to manage surface runoff in the winter months.

Areas where large scale buildings are to be decommissioned and deconstructed will be compacted as a result of the historic land use. This may lead to erosion, especially via rainwater or snow melt run-off, and transport of contaminated soils following deconstruction.

The area that would be affected by erosion as a result of these activities is considered to be significant in size, therefore the magnitude is considered to be major negative. However, due to the negligible value of the soils in the Project area, the potential impacts of decommissioning will be insignificant.

Where decommissioning involves deconstruction and removal of buildings, equipment, pipes and tanks, there is a potential for leaks and spills if not undertaken carefully and safely.



Depending on the scale of contamination, the magnitude of impacts to groundwater would be minor to moderate adverse. Due to the respective negligible and low value of the soils and groundwater in the Project area, the potential impacts of decommissioning will be insignificant.


The ethylene and polyethylene plant, butadiene production plant and polymer production plant also form part of the IPC site. These plants will be support by the same utilities and associated infrastructure presented in Section 2.4.

The impacts to soil and groundwater quality, and soil structure, during construction and operation is likely to remain the same as that presented in Section 9.5. Any impacts will be local to the IPC and would not have a significant regional effect.


9.7.1 Overview

The main impacts on soils for all aspects and phases of the Project are considered to be erosion and contamination. This is particularly significant during the early construction phase when ground disturbance, leaks and spills are more likely.

Contamination impacts from leaks and spills will be mitigated through use of best practice construction methodology in line with local regulations and international guidelines. Impacts from waste can be suitably mitigated by following a project specific waste management plan. For all aspects of the Project a comprehensive Health, Safety and Environment (HSE) Plan will be implemented in accordance with international standards, aimed at preventing accidents, injuries and work-related diseases through the identification of the causes of physical, chemical and biological hazards and by prioritising hazard elimination, hazard control and hazard minimisation.

The mitigation measures identified below are incorporated into the following sections of the assessment to identify any residual impacts after mitigation.

Mitigation of Risks to Human Health

Impacts to human health can be prevented by following good site practice and use of appropriate PPE in accordance with the IFC EHS General Guidelines (2007). Suitable PPE includes: eye protection; body/leg protection; foot protection; hand protection; hearing protection; lung protection and head protection.

Physical exposure to soil and dust can result in a risk to site workers. Good site practice and appropriate use of PPE in line with the IFC EHS General Guidelines will be maintained during construction works. Such requirements should be reviewed on a regular basis and PPE should be maintained and replaced



when worn out. Occupational monitoring of workers will be undertaken in order to confirm the effectiveness of use of PPE and if required the PPE requirements will be revisited.

Other measures for protection of human health include: communication of potential hazards to workers; safe storage of hazardous materials; provision of suitable welfare facilities including clean water for washing and drinking; provision of suitable ventilation systems in workers accommodation; environmental monitoring (e.g. gas and vapour monitoring) and emergency preparedness and response plans.

An emergency response plan will be prepared, detailing procedures, response personnel, medical support, equipment, evacuation procedures and measures for limiting or stopping potential events.

9.7.2 Construction Mitigation Requirements

A Construction Environmental Management Plan (CEMP) will be developed for the site in accordance with international standards, prior to construction. This document will outline the practices and procedures during the construction phase and will be further developed for the operation phase, to ensure minimal associated environmental impacts.

Mitigation measures required for operation of the Project are summarised in Table 9.7 below:

Table 9.6: Mitigation Measures Required During the Construction Phase

Process/Activity Impact Mitigation

Earthworks/ intrusive construction works

Mobilisation of dust and secondary impacts on human health

Use best practice construction methodology in line with local regulations and international guidelines.

Undertake earthworks during suitable weather conditions i.e. low wind strength to minimise the level of windblown dust, which may be potentially contaminated. Contractors to wear suitable PPE to protect against inhalation of dust. A risk assessment will be carried out to identify the level of PPE required in line with site specific risk factors.

Leaks and spills of Hazardous Materials

Soil quality with secondary impacts on groundwater quality and human health.

Baseline values have been established for some of the site. These values will be used for comparison with future monitoring results and to identify the conditions the site should be returned to in future when the Project has closed and is decommissioned.


Hazardous materials will be suitably stored to prevent leaks and spills. Drip trays will be used to intercept leaks and spills from equipment and during refuelling. Adequate bunding will be provided for all fuel and chemical storage.

Undertake routine groundwater monitoring to monitor impacts to groundwater quality (by comparison with baseline levels) - providing an early warning system for impacts to groundwater down gradient of the site

Develop and implement an Emergency Response Plan and a separate Spill Contingency Plan in accordance with local Emergency Response regulations and IFC and HSE guidance. Clean-up contaminated material in case of fuel



Process/Activity Impact Mitigation leaks.

Waste water from construction, integrity testing and cleaning



All waste water requiring treatment will be processed in the dedicated WWTP if it is operational or collected and treated off site.

There is a potential for impacts to the health of contractors and site workers during construction activities when handling hazardous waste materials. A comprehensive Occupational Health and Safety Plan aimed at preventing accidents, injuries and work-related diseases through the identification of the causes of physical, chemical, biological and radiological hazards and by prioritising hazard elimination, hazard control and hazard minimisation would be implemented.

9.7.3 Operation Mitigation Requirements

Mitigation measures required for operation of the Project are summarised in Table 9.7 below:

Table 9.7: Mitigation Measures Required During the Operational Phase

Process/Activity Impact Mitigation

Leaks and spills of Hazardous Materials


Use best practice in line with local regulations and international guidelines for operation of the Project.

Drip trays will be used to intercept leaks and spills from equipment and during refuelling.

Develop and implement an Emergency Response Plan and a separate Spill Contingency Plan in accordance with local regulations and IFC and HSE guidance. Clean-up contaminated material in case of fuel leaks.

Hazardous materials will be suitably stored to prevent leaks and spills. Bunding at least 110% of largest container will be provided for all fuel and chemical storage.

Site drainage Soil and groundwater quality All drainage and process water will be collected, treated at the WWTP and re-used on site. Treatment will include separation of oil from the water, pH adjustment and biological treatment.

On-going monitoring and maintenance of the drainage system will be undertaken.

As with the construction phase there is a potential for impacts to the health of site workers when handling hazardous materials. These will be addressed through the implementation of Health and Safety systems.

9.7.4 Decommissioning Mitigation Requirements

Most of the mitigation requirements required for the construction phase also apply to the decommissioning phase. This is particularly with respect to management of contamination, and the handling of hazardous materials.



At the end of the Project, all hazardous wastes will be removed from the site for safe disposal. A full ground investigation will be undertaken to establish the soil and groundwater conditions. Comparison will be made with the baseline conditions established prior to construction of the Project (presented in this document) and if necessary, remediation may be undertaken.

A dedicated decommissioning and restoration plan will be developed to apply throughout the lifetime of the Project and should identify deconstruction, disposal, pipeline decommissioning, aftercare and monitoring. Progressive rehabilitation should be undertaken throughout the Project as equipment is decommissioned and/or ceases to operate.

A ground investigation survey and groundwater monitoring should be undertaken as part of the decommissioning process, to assess any changes in the soil and groundwater quality compared with the baseline values presented in this report. Risk assessment would then be undertaken to assess the level of risk and requirement for remediation. Appropriate remediation of contaminated areas should be undertaken according to international best practice and local regulatory requirements. Following the decommissioning works, groundwater quality monitoring would be required to demonstrate that the Project area had not been detrimentally impacted by the decommissioning activities.


The significance of identified and assessed impacts can change through the implementation of mitigation enhancement measures. The residual effects of the Project contamination impacts are identified in Table 9.8.

Concerns were raised during consultation regarding groundwater pollution associated with poorly managed oil wells and fuel storage in the Atyrau region. The Project and other developments within the IPC will follow strict environmental and health and safety guidelines and practices in accordance with national regulations and international guidelines. The environmental impacts from the new Project are considered to be insignificant and would not add to the issues currently experienced in the region.

9.9 Additional References

CCME (2007) Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health, Summary of A Protocol for the Derivation of Environmental and Human Health Soil Quality Guidelines, Canadian Council of Ministers of the Environment 2007

CCME (2010) Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health, Polycyclic Aromatic Hydrocarbons, Canadian Council of Ministers of the Environment, 2008, revised 2010.

CCME (2011), Canadian Environmental Quality Guidelines and Summary Table, http://st-ts.ccme.ca/

Dyman, Thaddeus S., Litinsky, Vadim A., and Ulmishek, Gregory F (2001) Chapter C – Geology and Natural Gas Potential of Deep Sedimentary Basins in the Former Soviet Union. In Dryman, Thaddeus S.

http://st-ts.ccme.ca/



and Kuuskraa, Vello A. Geological Studies of Deep Natural Gas Resources, USGS Digital Data Series 67, Version 1.0. http://pubs.usgs.gov/dds/dds-067/

KAZECOPROJECT LLP (2011) Future Growth Project – Feasibility Study for Construction – Preliminary Environmental Impact Assessment, document ref 015-0000-RGL-RPT-CER-KEP-00001-00_B03. http://tengizchevroil.com/docs/FGP/PreEIA/FGP%20PreEIA_eng.pdf

Ministry of Housing, Spatial Planning and Environment (VROM), 2009, Soil Remediation Circular, Directorate General for Environmental Protection, Government of the Netherlands, http://international.vrom.nl/Docs/internationaal/ENGELSE%20versie%20circulaire%20Bodemsanering%202009.pdf

Shlezinger, A.E (1984) Deep Structures of the North Caspian Basin. In Episodes, Vol. 7, No.1, dated December 1984.

Tetrakon Engineering (2013) Integrated petrochemical complex in Atyrau region – EIA Report, project 108184-0001-TTC/RK-OBOC, Volume 21

Ulmishek, Gregory F (2001) Petroleum Geology and Resources of the North Caspian Basin, Kazakhstan and Russia, USGS Bulletin 2201-B, Version 1.0, dated 24 May 2001. http://geology.cr.usgs.gov/pub/bulletins/b2201-b/

UNSCEAR (2000) Report Vol. 1 United Nations Scientific Committee on the Effects of Atomic Radiation UNSCEAR 2000 Report to the General Assembly,with scientific annexes. Volume 1: Sources. Annex B: Exposures from natural radiation sources

World Health Organisation (WHO) (2011), Guidelines for Drinking-water Quality, Fourth Edition Annex 3 Chemical Summary Tables, http://whqlibdoc.who.int/publications/2011/9789241548151_eng.pdf?ua=1

World Health Organisation (WHO) (2010) Kazakhstan: Seismic Hazard Distribution Map http://www.who-eatlas.org/europe/images/map/kazakhstan/kaz-seismic.pdf

Zonn, Igor S., Kostianoy, Andrey G., Kosarev, Aleksey N., and Glantz, Michael M (2010) The Caspian Sea Encyclopaedia, Springer. http://f3.tiera.ru/1/genesis/580-584/582000/06fb1774e46cf3cf121359bcd7f724af

http://pubs.usgs.gov/dds/dds-067/

http://tengizchevroil.com/docs/FGP/PreEIA/FGP%20PreEIA_eng.pdf

http://international.vrom.nl/Docs/internationaal/ENGELSE%20versie%20circulaire%20Bodemsanering%202009.pdf

http://international.vrom.nl/Docs/internationaal/ENGELSE%20versie%20circulaire%20Bodemsanering%202009.pdf

http://geology.cr.usgs.gov/pub/bulletins/b2201-b/

http://www.who-eatlas.org/europe/images/map/kazakhstan/kaz-seismic.pdf

http://www.who-eatlas.org/europe/images/map/kazakhstan/kaz-seismic.pdf

http://f3.tiera.ru/1/genesis/580-584/582000/06fb1774e46cf3cf121359bcd7f724af





Construction

Earthworks/ intrusive construction and deconstruction works

Mobilisation of dust with potential secondary impacts to human health

High Minor adverse Minor adverse A CEMP will be developed for the site.

Best practice construction techniques (see section 9.7.1)

Implementation of a comprehensive Occupational Health and Safety Plan.

Good site practice and appropriate use of PPE in line with the IFC EHS General Guidelines.

Insignificant

Leaks and spills of hazardous materials

Soil quality Negligible Minor Insignificant A CEMP will be developed for the site.

Best practice construction techniques (see section 9.7.1)

Compliance with local and international guidance

Develop and implement an Emergency Response Plan and a separate Spill Contingency Plan in accordance with local regulations and IFC and HSE guidance.

Insignificant

Groundwater quality

Low Minor Insignificant

Potential secondary impacts to human health

High Minor Minor adverse

Waste water from construction, integrity testing and cleaning

Soil quality Negligible Minor Insignificant A CEMP will be developed for the site.

All waste water to be

Insignificant




processed WWTP.

See chapter 10: Materials and Waste Management for further details.

Operation

Leaks and spills of hazardous materials (and site drainage/ waste waters if damage occurs)

Soil quality Negligible Minor to moderate

Insignificant Compliance with local and international guidance

Develop and implement an Emergency Response Plan and a separate Spill Contingency Plan in accordance with local regulations and IFC and HSE guidance

Undertake routine groundwater monitoring to monitor impacts to groundwater quality (by comparison with baseline levels) - providing an early warning system for impacts to groundwater down gradient of the site.

Insignificant to minor adverse

Groundwater quality


Insignificant to minor adverse


High Minor to moderate

Minor to moderate adverse

Decommissioning

Leaks and spills of hazardous materials (and site drainage/ waste waters if damage occurs)

Soil quality Negligible Minor Insignificant Best practice construction techniques (see section 9.7.1)

Removal of all hazardous wastes

Insignificant

Groundwater Low Minor Insignificant




quality Implementation of a comprehensive Occupational Health and Safety Plan.

Good site practice and appropriate use of PPE in line with the IFC EHS General Guidelines.

Preparation and implementation of a dedicated decommissioning strategy

Full ground investigation, risk assessment and remediation if required


High Minor Minor adverse



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10.1 Introduction

This section addresses the potential impacts of construction and operation of the Project on hydrology, water resources and flood risk.

The assessment framework is set out in Section 5 and the assessment of potential impacts has been based on the Project description given in Section 2. The objective of this assessment is to predict the potential impacts on the water environment, associated with the development, and propose measures to mitigate the effects as appropriate.

The potential impacts of construction and operation of the Project on groundwater resources and groundwater quality are assessed in Section 9, Ground Conditions.

Assessment has been based on available web-based information. Where deficiencies in available information have been identified, these have been highlighted.


10.2.1 National

Water resources management, allocation and use are under the control of the Constitution of the Republic of Kazakhstan (1995) which regulates the protection of the environment and human health, including the use and conservation of water bodies under the supervision of the Ministry of Natural Resources and Protection of Environment (MNREP) and Ministry of Environment Protection (MEP). Water preservation and conservation are key issues in the RoK due to the greater part of the territory being located in arid areas where access to water resources is limited.

Kazakhstan water legislation uses the concept of a water object, which is a natural or artificial water body, water stream or any other water feature, which has constant or temporary waters with characteristics of water regime , i.e. which covers all types of natural and artificial water body including the marine environment, estuaries, rivers, canals, lakes, reservoirs and groundwater.

The base law that determines the legal, economic and social grounds for protecting the environment is the Environmental Code No. 212-III dated January 9, 2007 (as amended on 11.04.2014) of the Republic of Kazakhstan. It covers environmental aspects, environmental norms and approvals as listed in Section 3. The Environmental Code is the primary legislation that sets out the principles of resource management and facilitates secondary legislation and regulations. Of relevance to this section, Chapter 33, Article 224 ‘Environmental Requirements Applicable upon Use of Water Bodies’ which states: General water use at water bodies shall be in accordance with the procedure established by the water

legislation of the Republic of Kazakhstan. Individuals and legal entities must comply with the rules of general water use established by local

representative bodies of oblasts (of the city of national significance, or of the capital city).

10 Water Resources and Water Quality



193

Placement of plants and factories and other structures that impact the condition of water bodies shall be made in compliance with the requirements and rules of environmental protection, subsoil protection, sanitary and epidemiological and industrial safety, reproduction and efficient use of water resources as well as with consideration of environmental effects of operations carried out at the said facilities.

Construction, upgrade, operation, closing-down and abandonment of plants and factories and other structures that impact the condition of water bodies shall be carried out provided there are affirmative statement of opinions of the environment protection authority, authorised government agencies for use and protection of water resources, for industrial safety, and the government agency of the sanitary and epidemiological service.

The Water Code No. 481-II dated July 9, 2003 (as amended on 11.04.2014) of the RoK introduced a catchment scale and ecosystems approach to regulating water resources and based largely on the use and conservation of water bodies. The objectives of the Water Code are to regulate rational and sustainable water use, the protection of water resources from pollution and over abstraction, and the improvement of the legal framework with respect to water relations (Article 1). In summary, the general provisions of the legislation include: Responsibility of state agencies, physical and legal entities for implementation of measures to prevent

and mitigate negative water effects from floods, water-logging, destruction of banks, protection dams and other structures, that refer to emergencies of natural and anthropogenic nature.

Ensuring a legal framework for support and development of sustainable water use and protection, including from natural and man-caused pollution by harmful chemical and types of pollution;

Definition of basic principles and directions of water fund use and protection; State account and water use planning Solution of water disputes and responsibility for violation of water legislation; and International agreements with regards to use and protection of transboundary waters. Transboundary water use between Russia and Kazakhstan is regulated and managed through the

“Agreement between the Government of the Russian Federation and the Government of the Republic of Kazakhstan on joint use and protection of transboundary waters” issued on September 07, 2010

(based on the Convention of March 17, 1992). The transboundary water objects in this Agreement are: any surface waters or ground waters which mark, cross the State Borders between the countries or are located on the border

State Borders (Article 1). The local water flow is divided on the basis of a protocol on joint use and protection of the cross-border water bodies of the Ural River basin. Of relevance to this Project, is the proposed water use from the Kigach River located across the Kazakhstan/Russia border near Astrakham.

RoK water regulations concern procedures for obtaining water use permits, classification of water bodies, defining special patterns of use for water bodies, description of maximum allowable discharge limits calculations and water quality standards. Additionally, several key standards are applied in order to elaborate and specify water use regulations: RND 211.2.03.02-97 Guidelines on application of rules surface waters protection of the Republic of

Kazakhstan.



194

RND 211.2.03.01-97 Instructions rationing discharge of pollutants into water bodies of the Republic of Kazakhstan.

“Methodology on the determination of the standard emissions to the environment” adopted by Order

No. 379-O of the RK Minister of Environment dated December 11, 2013. It determines standard rules for calculation of emissions to atmosphere, water and limits for waste disposal.

“List of pollution substances and waste types for which emission standards are applied” adopted by

RK Government Decree No 557 dated June 30, 2007. SP 11-102-97 Code of Conduct on “Main engineering and environmental surveys for the construction”.

Key definitions applied for wastewater discharge used are Maximum Allowable Concentration (MAC) and Maximum allowable discharge (MAD). MAD is a limit (g/s and t/year) of maximum allowable amount of pollutant in the considered measuring point of a water body per unit of time in order to provide required water quality at the checkpoint. The current Project does not envisage wastewater discharge to a river, thus, MAD will not be applicable and no permits for water body usage should be obtained. Nevertheless, special requirements regarding water quality should be achieved and this will be monitored against the corresponding national standards.

10.2.2 International

International legislation and guidance includes the International Finance Corporation’s Sustainability

Framework. The Framework includes: Performance Standard 1 (Assessment and Management of Environmental and Social Risks and

Impacts) which amongst other things provides a standard for integrated assessment to identify the environmental and social impacts, risks, and opportunities of projects;

Performance Standards on Environmental and Social Sustainability, including Performance Standard 3 (PS3) (Resource Efficiency and Pollution Prevention) which provides direction on the avoidance or minimisation of adverse impacts on human health and the environment by avoiding or minimising pollution from project activities. PS3 also aims to promote more sustainable use of resources, including energy and water; and

Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.

PS 3, as the most relevant standard in relation to water use and discharge, requires developers to: make sustainable use of resources through consideration of technically and financially feasible and

cost effective measures for improving efficiency in the consumption of energy, water, and other resources and material inputs, with a focus on areas that are considered core business activities.

reduce and recycle water so that the project’s water consumption does not have significant adverse impacts on others.

avoid, or at least minimise, the release of pollutants to water due to routine, non-routine, and accidental circumstances, with the potential for local, regional, and transboundary impacts.



195


10.3.1 Consultation

The KPI project stakeholder consultation which took place on 24th April 2014 raised the following concerns in relation to surface water: Complaints received from the local population on water in connection to H2S; Whether KPI has fully considered the capacity of the existing Astrakhan-Mangshlak water pipeline

(supply) and the conditions of the pipeline itself. This pipeline is scheduled to be repaired and expanded – this could be an issue in terms of planning;

The water supply in the region is not considered reliable via this pipeline water supply. It was suggested that ground water should be considered. There is a political concern about this water main (because it is from Russia);

It was asked what will KPI do with waste water produced from the Project? It was explained that domestic water will be treated and sent to a central WWT point along with waste water from the process plants.

These comments will be addressed where possible in this section.

10.3.2 Assessment Methodology

The methodology adopted for this chapter is consistent with the generic methodology described in Section 5.

Four types of impact are assessed in this chapter: Abstraction and effects on surface water flow patterns during construction and operation; Potential for activities to contaminate surface waters during construction; Pluvial and fluvial flood risk during construction and operation; and The operational use of the new railway and road (already constructed).

There will be no discharges to surface water of industrial process wastewater from the Project or its associated facilities and therefore this is not considered further in this section.

The impacts and potential effects of abstraction and any discharges to ground on groundwater resources and groundwater quality and the potential for groundwater flooding are assessed in Section 9, Ground Conditions.

The ethylene and polyethylene plant, butadiene production plant and polymer production plant are to be constructed separately to the Project but located within the IPC boundary. The new water supply for the entire IPC site will require an increased abstraction, new 27 km pipeline and additional pumping station. These developments will be included in the assessment of cumulative effects.



196

The magnitudes of potential impacts of abstraction on surface water resources are assessed in terms of the scale and timing of proposed abstractions relative to the baseline water resources. The sensitivity of a specific receptor is based on the available water resource information described in the baseline section.

As described in Section 5, the significance of any effect (adverse or beneficial) is determined in relation to the sensitivity of the receptor and the magnitude of the impact (see Section 5). For the hydrology and water quality assessment the sensitivity and magnitude are set out in Table 10.1 and Table 10.2 respectively.

Table 10.1: Sensitivity of Receptor

Sensitivity Definition

High Receptor is of high ecological importance or National or International value (e.g. RAMSAR, Sites of Special Scientific Interest, Special Areas of Concern, habitat for protected species);

Water body classified as “Specially Protected” under Article 66 of the Water Code;

Receptor is assessed using guidance from the European Union’s Water Framework Directive as ‘good’

Receptor is used for public and/or private water supply;

Designated as a Bathing Water;

Medium Receptor is assessed using guidance from the European Union’s Water Framework Directive as ‘improving’

Water body used for private water supply but not public water supply

Low Receptor is assessed using guidance from the European Union’s Water Framework Directive as ‘poor’

Receptor not used for water supplies (public or private);

Negligible Receptor lies outside the sphere of influence of the proposed Project.

Table 10.2: Magnitude of Impact

Magnitude of Impact


Definition

Major Fundamental change to the hydrological conditions assessed resulting in temporary or permanent change.

Moderate Detectable change to the hydrological conditions assessed resulting in non-fundamental temporary or permanent change.

Minor Detectable but minor change to the hydrological conditions assessed.

Negligible No perceptible change to the hydrological conditions assessed.

Flood risk impacts address the potential effect of the proposed development on the frequency, magnitude and impact of flooding to infrastructure and adjacent communities. The magnitude of flood risk is measured in terms of the flood hazard, while the sensitivity reflects the capacity of a receptor to accommodate an increase in flood risk (i.e. its vulnerability to flooding).



197

The assessment assumes that good international industry practice41 (GIIP), as set out in EHS Guidelines, will be adopted as the minimum level of mitigation in the absence of international or national legislation or guidance. GIIP is regarded as embedded mitigation and as such these measures are not explicitly identified as mitigation measures, although are set out in this section in order to confirm the measures that are considered relevant for this aspect.

Following the consideration of appropriate mitigation measures, a final assessment of the residual impacts is made such that the ESIA can conclude with a statement of significance.

10.3.3 Study area

The assessment study area includes all surface water features within the Zone of Influence (ZoI). For this Project, the influential range has been taken to include:

The Project Site and within 500m radius around the Site; and Within 500m of the new potable water and gas pipeline.

Due to a lack of historic flooding and flood extent information, the study area considering pluvial and fluvial flood risk will be extended to consider the nearest surface water bodies (Ural River and Caspian Sea).


10.4.1 Surface water bodies

The location of surface water bodies in relation to the Project Site are shown on Figure 10.1.

41 GIIP is defined as the exercise of professional skill, diligence, prudence, and foresight that would reasonably be expected from

skilled and experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally or regionally



198

Figure 10.1: Surface Water Bodies in Relation to the Project Site

Source: Insert source text here

The Project Site is within the Ural Basin and located 28 km east of the Ural River. The Ural River starts in the Southern Ural Mountains in Russia, flows through Kazakhstan and discharges to the Caspian Sea to the south of the Project Site. Atyrau is the main harbour city of Kazakhstan on the Caspian Sea at the delta of the river Ural. 78 percent of the water resources of the Ural River are formed in Russian territory, with the lower part of the river flow fully dependant on the volumes of water entering from the neighbouring country and therefore the potential to abstract water is determined by water use upstream..

The Caspian Sea is located approximately 45 km south of the Project Site. The level of the Caspian Sea is now 28m below the level of the world’s oceans

42. The Project Site is likely to be located on the old basin bed of the Caspian Sea, where surs (partly dried saline shoals) formed but have now dried out. Most of the water flowing into the sea comes from coastal rivers (currently supplying 300 to 310 cubic km a year), from

42 Souce: Freshwater Ecoregions of the World http://www.feow.org/ecoregions/details/volga_delta_northern_caspian_drainages

http://www.feow.org/ecoregions/details/volga_delta_northern_caspian_drainages



199

the Ural, Volga, Terek and Kura Araks Basins. The Volga alone accounts for 80% of inflow. Inflow has changed over the last decade due to various climatic factors and human activities such as dams built for hydroelectric energy production.

Minor valleys (sorami) and natural, relict relief depressions and low-lying area (surs) are located around the Project Site as shown in Figure 10.2. There is one sur towards the eastern boundary of the Project Site which will be retained as part of the works (see Figure 10.3). These are likely to be dry apart from the winter months and during and following ice and/or snow melt. Water entering this sur will infiltrate or evaporate, and the water entering the dry valleys is likely to do the same, leaving behind the mudplains and saline areas. There does not appear to be a pathway between the dry valleys and the Caspian Sea or other surface water body.

Figure 10.2: Undulations and Valleys around the IPC



200

Figure 10.3: Sur at the Eastern Boundary of the Project site


The Kigach River is located 320 km south-west of the IPC. Water supply to the IPC will be sourced from this river via existing pipe distribution networks within Kazakhstan. The river has a mean flow of 150 m3/sec. The average annual volume is 13 billion m3 and in 2009 it was 9 - 10 billion m3 (taken from the gauging point at Kotyaevka settlement) according to “Strategic plan on the natural resources management for 2011-2015” approved by Atyrau city Akimat Decree No.358 dated December 24, 2010.

10.4.2 Flood risk

The climate of the region is typically continental, with cold dry winters and hot dry summers. In the south, average temperatures vary from minus 3 °C in January to 30 °C in July43. The continental climate is characterized by high evaporation levels and precipitation is insignificant (annual average 175mm). In this region the number of days with precipitation intensity> 5mm is only 8 to 9 days a year, and the intensity of > 30 mm is 0.1-0.5 days per year, with the annual maximum rainfall occurring between May and July44. Snow fall mainly occurs from December to March. During this period, the district has a relatively stable snowpack with a snow depth of 10-15 cm. Due to the low precipitation the risk of pluvial flooding and high surface water runoff rates are considered to be negligible.

43 Source: http://www.fao.org/nr/water/aquastat/countries_regions/KAZ/index.stm 44 Integrated petrochemical complex in Atyrau region Client LLP, Kazakhstan Petrochemical Industries Inс. EIA Report, Project

ref108184-0001-TTC/RK-ОВОС, Volume 21, 2013.

http://www.fao.org/nr/water/aquastat/countries_regions/KAZ/index.stm



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During flooding the Ural River widens to several tens of kilometres near the mouth. Water level is highest in late April for upstream sections and in May for downstream parts. Its fluctuation is 3–4 m in the upper stream, 9–10 m in the middle of the river and about 3 m in the delta. The average water discharge is 104 m3/s near Orenburg, 400 m3/s at the Kushum village (76.5 km from the mouth); maximum discharge is 14,000 m3/s and the lowest is 1.62 m3/s45. Average turbidity is 280 g/m3 at Orenburg and 290 g/m3 near Kushum. The river freezes at the source in early November and in the middle and lower reaches in late November. The ice melts in the lower reaches in late March and in early April in the upper reaches and the ice drift is relatively short.

The area around the IPC is arid so no floods are generally observed. However, a comparison of river levels versus the IPC level is required, both in relation to the Ural River and the Caspian Sea. Levels monitored in the Ural River nearest the Site are presented in Table 10.3.

Table 10.3: Ural river levels, metres (Baltic estimation system)

Level of water 1971-1974 1975-1980 1981-1989 1990-2004

Medium -27.8 -28.3 -27.4 -26.6

Max -24.5 -25.7 -25.1 -23.99

Minimum -28.8 -29.5 -28.9 -26.6

Levels in the Caspian Sea have varied over the last few decades. As explained in Section 10.4.1 the level of the Caspian Sea is now situated around 28m below the level of the world’s oceans. Due to the fluctuating levels in the Caspian Sea, there is no certainty on the potential climate change impacts in the Caspian region. However, the IPC is located 8m above the Caspian Sea level therefore it is unlikely that there would be a significant change in level of 8m which could result in a risk of flooding of the Project site.

10.5 Assessment of Project Impacts

10.5.1 Construction phase

There are four primary activities that can potentially impact on the surface water environment: Use of vehicles and machinery on Site and along the new road and railway; Works within the flood extent of the Ural river or Caspian Sea; Increase in impermeable areas (pluvial flooding); and Temporary water supplies (for construction activities).

As explained in Section 10.4.2, the high evaporation levels and low precipitation (annual average 250mm) characteristic of the continental climate suggest the risk of pluvial flooding from surface water runoff to be negligible (insignificant) both during construction and operation. However, during any ice and snow melt conditions that may occur (end of Spring), it is expected that excess surface water (storm runoff) will be routed via a new drainage system to the new process water treatment plant (PWTP) to manage and

45 Encyclopaedia Britannica



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minimise the risk of on-site flooding and the risk of impacting on the other production facilities within the IPC site. Any potentially contaminated water will be directed to the appropriate pre-treatment facility within the PWTP e.g. the oil water separator. Oil interceptors may need to be considered in locations where fuel is to be stored, refuelling takes place and vehicles are parked. Any runoff allowed to infiltrate has the potential to impact groundwater (see Section 9).

Water required for construction will be delivered by tankers and stored in tanks onsite. Potable water will be piped from the existing pipe network running alongside the A27. Once constructed all waste water will be directed to the new PWTP for treatment, prior to this waste water will be stored onsite and removed by licensed contractors and treated offsite at an existing facility. Water demand will vary during construction although it is estimated that the peak monthly total water demand will be 1,130,62 m3 and occur between month 7 to twelve of the construction schedule.

The elevation of the proposed IPC is 20m below sea level. The highest levels observed between 1971 and 2004 in the Ural River are estimated at 23.99m below sea level. The site is therefore unlikely to be at risk of fluvial flooding from the Ural River. Caspian Sea levels are noted to be 28m below sea level. The presence of surs and other depressions between the river and the IPC provide storage for flood flows. There is also a lack of a flow pathway between the river and Sea, and the IPC. It is therefore assumed the IPC is not at risk of fluvial flooding both during construction and operation.

The new gas, service water and potable water pipelines do not cross any surface water bodies and none exist within 500m of the pipeline routes. As with the IPC, surs and dry valleys do exist within the study area. The laying of pipes underground will therefore not affect surface water bodies, but has the potential to impact groundwater as discussed in Section 9 (Ground Conditions).

In conclusion, it is assessed that the magnitude of the potential impacts on surface water resources, quality and flood risk will be negligible. The sensitivity of the surs and dry valleys to construction related impacts is deemed to be low with respect to water quality and negligible for water resources and flood risk. Therefore the significance with respect to all potential impacts during construction is assessed as being insignificant and, as a result, additional mitigation measures beyond use of good construction practice is not required.

10.5.2 Operational phase

10.5.2.1 Flood risk

There is no risk of river or tidal flooding from the Ural River and Caspian Sea respectively as described in Section 10.5.1. New service water, potable water and gas pipelines are to be constructed underground therefore resulting in no change to the susceptibility of flooding along its route.

Within the Project site areas of permeable land will be replaced by impermeable areas estimated to be approximately 250,000m2 (hard standing and roofs of buildings). Surface water runoff will be managed on site using on site drainage systems that connects to the new WTP. Surface water runoff is only likely to



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occur following any snow and ice melt in April to May. The drainage system will have the capacity to take the higher flows during this time therefore the potential for surface water flooding is considered low.

10.5.2.2 Abstraction and effects on surface water flow patterns

Process water for the IPC site will be provided from a central water supply unit fed by the existing Astrakham to Mangyshlak pipeline. This pipeline abstracts water from the Kigach River, one of the tributaries of the Volga in Astrakham, Russia (see Figure 10.1). The pipeline distribution network from the existing abstraction point and pumping stations on the Kigach River passes the IPC approximately 25km to the south-west. As part of the IPC development a new water pipeline will be constructed to connect the Astrakham to Mangyshlak pipeline to the IPC (see Section 2)

KazTransOil own the Astrakham to Mangyshlak pipeline and have committed to increasing the pipeline capactity from 50-60,000m3/day to 260,000m3/day to serve the IPC site and other developments in the area. The capacity of the existing 1200mm pipe will be increased through the upgrade of existing pumping stations along the pipeline route. A new pumping station will also be constructed at the 300km mark, where the new 27km long, 630mm diameter pipeline feeding the IPC site connects to the Astrakham to Mangyshlak pipeline. KazTransOil have the permission to transport the water in the pipeline although abstraction takes place from the Russian Federation under the transboundary water use agreement between Russia and Kazakhstan. KazTransOil are responsible for the construction of the 27km pipeline and the pipeline supplying the water supply unit located on Site.

Water supplied to the PDH and PP plant will be purchased by KPI at the required water quality for use within the process (see Section 2). The raw water will be imported to the water supply unit and will be treated further to the individual requirements of each process plants that the water will be used in. The raw water will be treated to the required limits specified by KPI for use in the PDH and PP plants.

The Project will have a normal water demand of 712 m3/hr and a peak water demand of 2,005 m3/hr as described in Section 2. There will be no discharge of waste water to either surface water or groundwater. All the process water used within the PDH and PP plants will be recycled back into the plant via the new PWTP that serves the IPC site, reducing the water demand for the Project and in so being in accordance with IFC EHS guidelines. Only solid waste products from the PWTP will be a by-product of the treatment process and disposed of offsite as described in Section 12.

Potable water will be supplied to the Project via a new pipeline connecting the IPC to the existing potable water supply pipeline running from Atyrau to Makat which runs adjacent to the A27. The new 8 km pipeline will tie in with the main water supply pipeline and is being constructed as part of the plastic bag production plant to the South of the Project that forms part of the IPC site. An agreement has been reached with the water supply provider of Atyrau (Atyrau Sy Arnasy) to provide 15,000m3/year of potable water for the whole IPC. The peak potable water demand for the Project is 17.5m3/day and therefore normal consumption would be expected to be much lower.



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The increased abstraction from the Kigach River to serve the Project during normal operation (727m3/hr) is extremely small compared with the known mean flow of 150 m3/sec (540,000 m3/h) in the Kigach (~0.1%). The total abstraction for the whole IPC will be approximately of 45,000 m3/day compared to a daily flow of 12,960,000 m3/day in the Kigach. Such a small change is less than the level of detection typical for discharge measurement in large rivers, and insignificant compared to the influence of upstream flow regulation. Therefore the magnitude of the impact of the increase in abstraction on flows in the Kigach River is assessed as being negligible. Give the typical flow of the Kigach river any short term peak in water demand due to increased fire water requirements would not have a significant impact on the flow in the Kigach river.

There is no available information on downstream abstractions and water users and as such it is not possible to assign a sensitivity class to the Kigach river. However, it is likely that any impact on downstream water users would be assessed as insignificant given the negligible magnitude and the closeness to the Caspian Sea (high salinity).

10.5.2.3 Potential for surface water contamination from rail and road use

The new rail spur and station, and the new access road are now either constructed or nearly complete. No surface water bodies are crossed by or located within 500m of these routes, therefore any potential contamination from accidental spillage of chemical or contaminated material being delivered to or from site or runoff from the tracks or roads are unlikely to reach surface waters. The impact of the operation of the rail and road is therefore considered negligible and therefore not significant.

10.5.3 Decommissioning phase

Decommissioning phase activities are likely to be very similar to the construction phase. Good practice should be adopted to manage surface water runoff in the winter months.

The most likely contamination hazard is from storage tanks and pipelines which contain toxic or hazardous materials. Invariably, residual or possibly large quantities of toxic or hazardous materials may remain when a site is abandoned or require removal as part of the demolition activities. Contamination often occurs when storage tanks are punctured, or when pipelines are damaged during demolition and ground clearance activities. Due to the distance of surface water bodies from the site any risks associated with dismantling plants and the potential for contaminants to be released will be covered by the groundwater risk assessment presented in Section 9 (Ground Conditions).

The magnitude of the potential impacts of decommissioning on water resources, water quality and flood risk will be negligible and therefore not significant.



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The ethylene plant, polyethylene plant, butadiene production plant and polymer production plant also form part of the IPC site. These plants will be supported by the same utilities and associated infrastructure presented in Section 2.

The flood risk and risk to surface water quality during construction and operation is likely to remain the same as that presented in Section 10.5.

The total water demand for the IPC site is unknown at this stage. However, the increased capacity within the Astrakham-Mangyshlak pipeline from 50-60,000m3 to 260,000m3/day will significantly increase its current capacity after approximately 45,000m3/day is removed for the IPC. The increased abstraction from the Kigach river to serve the IPC site with the maximum capacity 45,000m3/day is still relatively small compared with the known mean flow of 12,960,000 m3/day) in the Kigach river (~0.35%). The impact on the surface water flows within the Kigach river is considered negligible to minor (insignificant). It is not known if there are any other future regional plans to abstract additional water from the Kigach River and therefore it is not possible to consider the cumulative effects of their abstraction in addition to that for the IPC.


10.7.1 Construction phase

No additional mitigation measures are required, provided that the construction follows local construction norms and rules, good environmental practice and pollution prevention measures, set out in the ESMP.

Management of surface drainage and site runoff, particularly during any ice melt in the late spring, to minimise localised temporary flooding during the construction phase.

10.7.2 Operation phase

No mitigation measures are required, provided that the plant operates within the the design parameters and in accordance with good international industry practice as set out in the ESMP . It is important that the abstraction rates remain within the design and consent limits held by KazTransOil as described above. A series of contingency measures, such as emergency response plans, should be devised to allow prompt action to be taken should there be any deviation from the normal operating standards.


Mitigation is only required to protect surface water if works undertaken during the winter months and if the valleys become wet and provide a pathway to other sensitive water systems or users. Specific mitigation is required to address the impact of demolishing or removing storage tanks and pipelines which contain toxic



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or hazardous materials. Appropriate mitigation will need to be established on a case by case basis depending on the location of the component, its operational use, physical state and the proximity to surface water receptors (in the wetter months). The measures must be designed to minimise the risk of spills and to ensure that, should a spill occur, the release can be controlled and either treated or removed.

A decommissioning plan should be developed that includes the surface water management and pollution control measures required for each component.


There are no residual impacts provided best practice measures are implemented during each phase and that mitigation is put in place during decommissioning.

A monitoring programme should be implemented to assess the level of any residual contamination in surface water receptors, and to identify any source of contamination (for example from contaminated soils disturbed during re-development).





Construction Flood Risk Negligible Minor Insignificant N/A Insignificant

Operation Abstraction Negligible Negligible Insignificant N/A Insignificant

Flood Risk Negligible Minor Insignificant N/A Insignificant

Decommissioning Flood Risk Negligible Negligible Insignificant N/A Insignificant



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11.1 Introduction

This section represents the Ecological Impact Assessment (EcIA) of the Project. It identifies the relevant framework of legislation and identifies and assesses potentially significant adverse impacts, before defining appropriate mitigation and enhancement measures that will be implemented as part of the Project. The baseline includes protected areas, habitats and species, with information being used from primary and secondary sources.

The structure of this chapter reflects the ESIA process. Section 11.2 provides background information on legislative and policy framework for biodiversity, while details on how the baseline information was obtained and the assessment criteria are provided in Section 11.3. The biodiversity baseline is summarised in Section 11.4, with further detail being provided in Appendix D in Volume III of the ESIA. An assessment of the likely impacts of the Project on biodiversity is provided in Section 11.5; cumulative impacts are presented in Section 11.6. The proposed mitigation and monitoring measures are presented in Section 11.7 and a summary of the residual impacts in Section 11.8.


11.2.1 Relevant National Legislation and Policy

11.2.1.1 Ratified International Policies and Conventions

The following international conventions and biodiversity agreements have been ratified by Kazakhstan and are relevant to this Project: Convention on Biological Diversity (CBD) 1992 – signed by Kazakhstan in 1992 and ratified in 1994; Bonn Convention on the Conservation of Migratory Species of Wild Animals (CMS) 1979 (as amended)

– Kazakhstan is a Party of the CMS since 2006.

The CBD defines biodiversity as “the variability among living organisms from all sources including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part; this includes diversity within species, between species, and of ecosystems” (CBD, 1992). As a signatory,

Kazakhstan has a responsibility to safeguard its biodiversity and, in accordance with Article 14 of CBD, as far as possible and as appropriate to introduce procedures requiring environmental impact assessment of proposed projects likely to have significant impacts on biological diversity and to introduce arrangements to ensure environmental consequences of its policies and procedures are duly taken into account.

As part of the CMS, Kazakhstan has signed four Memoranda of Understanding (MoU) on the conservation of Siberian Crane (Leucogeranus leucogeranus), Saiga Antelope (Saiga tatarica), Bukhara Deer (Cervus elaphus bactrianus) and Slender-billed Curlew (Numenius tenuirostris).

11 Ecology



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11.2.1.2 Kazakh Legislation and Policy on Biodiversity

The overall framework for environmental protection in Kazakhstan is based on the Environmental Code of RK No. 212-III of 09.01.2007 (as amended on 2.07.2014). The overall purpose of this law is to prevent pollution and encourage the rational use of the environment through the involvement of local communities and stakeholders in natural resource management. The Ministry of Ecology and Natural Resources and Environmental Protection is responsible for framing and implementing Kazakhstan’s environmental and

natural resource policy.

There are two pieces of legislation that regulate biodiversity conservation in Kazakhstan: The Law on Protection, Reproduction and Use of Fauna (2004 #593-II), which requires wildlife to be

sustainably utilised; and, The Law of the Republic of Kazakhstan of July 7, 2006 No. 175-III "On protected natural territories" (as

amended on 03.07.2013) which specified the categories of protected areas in Kazakhstan based on international standards, ranging from conservation areas to natural monuments. The protected area system is organised under thirteen management regimes depending on purpose, level of protection and special features.

The Forestry Codes and Regulations, Land Regulations and Mineral Resources Codes were also adopted nationally in 1997. These regulations are enforceable by law under the Civil and Criminal codes (1997). Finally the ‘Licencing Activities on the Use of Natural Resources’ regulations came in to effect in 1998.

Other national legislation relevant to biodiversity includes: The Law of the President, 1999 #372-1 “On Kazakhstan joining the Convention on International

Trading Endangered Species of Wild Fauna and Flora (CITES)”. Government Decision, 2004 #1330 “On Approval of Regulations on the Red Book of the Republic of

Kazakhstan”. Government Decision, 2006 #1034 “The list of rare and endangered plant species”. Decree of the Government, 2005 #1. “Terms of reference of public accounting, inventory and

monitoring of animal life in the Republic of Kazakhstan”. Government Decision, 2004 # 622 approved the second part of the Red Book of Kazakhstan (Vol. 1.

Animals. Part 2. Invertebrates).

Government Decision, 2006 #1034 approved the list of rare and endangered animal species. Law No. 175-III “On special protected territories” dated June 07, 2006 (as amended on 03.07.2013) of

the Republic of Kazakhstan sets forth the systems of protected areas and details the pattern of their use and protection of species pool.

Law No. 593-II “On protection, rehabilitation and use of wildlife” dated July 9, 2004 (as amended on

03.07.2013) of the Republic of Kazakhstan regulates the protection and use of wildlife, conservation and restoration of wildlife habitats in order to ensure biological diversity

Government Decree No. 969 dated July 25, 2012 “On prohibition of the saiga antelope usage or their parts but research usage on the territory of the Republic of Kazakhstan until 2020 year”.



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11.2.1.3 Kazakhstan National Biodiversity Strategy and Action Plan

The development of a National Strategy for the Conservation and Sustainable Use of Biological Diversity began in Kazakhstan in 1996, which culminated with the publishing of the National Report for the Republic of Kazakhstan on Conservation and Sustainable Use of Biological Diversity in 1998.

To address biodiversity conservation in a global context, Kazakhstan developed a National Biodiversity Strategy and Action Plan (NBSAP) in 1998, and incorporated its targets in the national Development Strategy for the Republic of Kazakhstan up to the year 2030. The main objective of the national strategy is to conserve biological diversity and to achieve economic gains through the balanced use of its components, and includes biodiversity restoration. Habitat destruction and/or degradation has been thought to occur in over 60% on the republic’s territory, and many of Kazakhstan’s species (whether Red

Listed or not) fall outside the national reserves network. One important objective of the NBSAP is to more than double the surface of existing reserves, adding 13 new sites (Convention on Biological Diversity, 2014).

The main objectives of the National Strategy are: to assess the status and trends of biodiversity, to promote the in-situ conservation of biodiversity, to account for and assess socio-economic benefits of biodiversity, to allow additional resources to the genetic fund that helps achieve national biological security, the development of a national legal framework, the reduction of threats affecting biodiversity, ecological restoration on infringed ecosystems, and the promotion, through awareness campaigns, of the sustainable use of biodiversity by local

populations.


11.2.2.1 Overview

The Project is required to meet the following international third party and lender standards and requirements: The Equator Principles III 2013 International Finance Corporation (IFC) Performance Standard 6: Biodiversity Conservation and

Sustainable Management of Living Natural Resources (IFC, 2012a, 2012b) European Bank of Reconstruction and Development (EBRD) Performance Requirement 6: Biodiversity

Conservation and Sustainable Management of Living Natural Resources (EBRD, 2014) Japan Bank for International Cooperation (JBIC) - Guidelines for Confirmation of Environment and

Social Considerations’ Organization for Economic Co-operation and Development (OECD) Recommendations on Common

Approaches on the Environment and Officially Supported Export Credits (2007) – the ‘Common

Approaches’



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IFC Environmental, Health and Safety (EHS) Guidelines: – General EHS Guidelines (IFC, 2007) – Petroleum-based Polymers Manufacturing (IFC, 2007) – Large Volume Petroleum-based Organic Chemicals Manufacturing (IFC, 2007) – Environmental, Health, and Safety Guidelines for Thermal Power Plants (IFC 2008)

The general environmental requirements are presented in Section 4.3 of this document. The standards that include specific requirements to biodiversity and ecosystem services are IFC PS6 and EBRD PR6. These requirements are described in more detail below.

11.2.2.2 International Finance Corporation Performance Standard 6

The impact assessment for this ESIA follows the revised IFC Performance Standard 6 (PS6) (IFC, 2012a, 2012b) on biodiversity conservation and sustainable management of living natural resources. IFC PS6 objectives are: To protect and conserve biodiversity; To maintain the benefits from ecosystem services; and To promote the sustainable management of living natural resources through the adoption of practices

that integrates conservation needs and development priorities.

As part of the IFC PS6, it is a requirement that a conservation value is allocated to the ecological features (protected areas, habitats and species) which are likely to be directly or indirectly impacted by the Project within an area of influence. Under the IFC guidance, the requirements of PS6 apply to projects in all habitats, whether or not those habitats have been previously disturbed and whether or not they are legally protected.

In accordance with IFC PS6, habitats are divided into modified, natural and critical habitats. Critical habitats can be either modified or natural habitats supporting high biodiversity value, including: habitat of significant importance to critically endangered and/or endangered species (IUCN Red List); habitat of significant importance to endemic and/or restricted-range species; habitat supporting globally significant concentrations of migratory species and/or congregatory species; highly threatened and/or unique ecosystems and/or; and areas associated with key evolutionary processes.

Habitat destruction is recognised as a major threat to the maintenance of biodiversity and to assess likely significance of impacts, PS6 makes the following recommendations depending on habitat status:

Modified Habitat: exercise care to minimise any conversion or degradation of such habitat, depending on scale of project, identify opportunities to enhance habitat and protect and conserve biodiversity as part of operations.

Natural Habitat: developer will not significantly convert or degrade such habitat unless no financial/technical feasible alternatives exist (or overall benefits outweigh cost), stakeholders have been



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consulted, and conversion or degradation is suitably mitigated following the mitigation hierarchy. Mitigation measures need to achieve no net loss of biodiversity where feasible.

Critical Habitat: in areas of critical habitat the developer will not implement project activities unless: there are no alternatives; there are no measurable adverse impacts on the critical habitat triggers; project does not lead to a net reduction in the populations of critically endangered or endangered species; and a robust, appropriately designed and long-term monitoring and evaluation programme is implemented. Developers must achieve net gain in biodiversity if critical habitats are affected. The preparation and implementation of a Biodiversity Action Plan (BAP) is required where critical habitat is affected.

The IFC PS6 now recognises the importance of ecosystem services. Where a project is likely to adversely impact on ecosystem services, as determined by the impact assessment process, a systematic review to identify priority ecosystem services must be carried out, any impacts on Affected Communities must be identified and impacts on the ecosystem services minimised.

11.2.2.3 European Bank for Reconstruction and Development (EBRD) Standards

As part of its Environmental and Social Policy, EBRD (2014) has adopted a comprehensive set of specific Performance Requirements (“PRs”) that projects are expected to meet. Furthermore, EBRD is committed

to promoting EU environmental standards as well as the European Principles for the Environment, which are reflected in the PRs.

The PR6 “Biodiversity Conservation and Sustainable Management of Living Natural Resources” is the

relevant requirement for the Project. PR6 applies to projects in all types of habitats, irrespective of whether they have been disturbed or degraded previously, or whether or not they are protected or subject to management plans. The objectives of PR6 are: To protect and conserve biodiversity using a precautionary approach; To adopt the mitigation hierarchy approach, with the aim of achieving no net loss of biodiversity, and

where appropriate, a net gain of biodiversity; and To promote good international practice (GIP) in the sustainable management and use of living natural

resources.


11.3.1 Zone of Influence for Biodiversity

Current guidance on ecological assessments recommends that all ecological features that occur within a zone of influence (ZoI) around the proposed development are investigated (IEEM, 2006). The potential ZoI includes: Areas directly within the land take for the proposed development and access; Areas which will be temporarily affected during construction; Areas likely to be impacted by hydrological disruption; and Areas where there is a risk of pollution and noise disturbance during construction and/or operation



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With regard to biodiversity and nature conservation, the ZoI for the Project includes the following The Project footprint and surrounding habitats to 500m Designated areas within 20km from the Project and Protected and or notable species within 2km of the Project.

11.3.2 Desktop Study

A review of the ecology section in the national EIA or OVOS (Tetrakon Engineering, 2013) has been carried out. Additional information on biodiversity, ecology and nature conservation has been reviewed from a range of organisations, publications and internet sources including: Convention on Biological Diversity website (http://www.cbd.int/) UNESCO database on World Heritage Sites (http://whc.unesco.org/en/interactive-map/) International Union for Conservation of Nature and Natural Resources (IUCN) Red List of Threatened

Species (http://www.iucnredlist.org) The Red Data Book of Kazakhstan (summarised at http://www.redbookkz.info/en/index.html) BirdLife International Data Zone (http://www.birdlife.org/datazone/home).

Information on the following biodiversity and nature conservation areas within or near the ZoI has been collected and reviewed: Ramsar Sites Biosphere Reserves World Heritage Sites (WHS) Important Bird Areas (IBA) Endemic Bird Areas (EBA) Important Plant Areas (IPA) National conservation areas in Kazakhstan:

– Strictly Protected National Reserves (zapovedniks) – National Parks – State Nature Reserves – Conservation Areas (zakazniks) – Natural monuments/Natural areas/Nature Parks

11.3.3 Field Surveys

No specific biodiversity surveys were conducted as part of the national EIA (Tetrakon Engineering, 2013). To inform this ESIA, surveys were conducted for habitats and flora, birds, mammals, reptiles and amphibians at the end of May 2014. The survey methodologies are described below.

11.3.3.1 Habitats, Vegetation and Flora

Baseline surveys for habitats, vegetation and flora were undertaken between 26 and 29 May 2014. The study area for the surveys was the project footprint plus a 500m buffer around it.

http://www.cbd.int/

http://whc.unesco.org/en/interactive-map/

http://www.iucnredlist.org/

http://www.redbookkz.info/en/index.html

http://www.birdlife.org/datazone/home



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The field survey consisted of a standard transect and quadrat method in sites situated between 100m and 2000m from the project area, ensuring that the transect line passed through all common vegetation communities present. Fourteen transect lines were surveyed over an entire length of 17km. Figure 11.1 shows the locations of the flora survey transects.



Figure 11.1: Flora Survey Map at Integrated Petrochemical Complex Project Area

Source: Envirs Consulting



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Quadrat size depended on the vegetation community present; 240 1m2 quadrats were surveyed spaced 3-5m apart, and 15 100m2 quadrats were surveyed, with the larger quadrats being in the most common communities. See Appendix D for a location map of the botanical surveys.

At each location, the habitat was mapped and a brief description of the plot provided, along with the plant species identified in each habitat type and a description of the soil. GPS locations and photos of transects/quadrats, and of protected, threatened, endemic or invasive species were recorded.

Vegetation communities were identified according to Vasylevich (1971). Species cover was estimated visually using the scale in Table 11.1 below.

Table 11.1: Cover scale used for plant communities for the 2014 surveys

Cover scale Percentage

cover

+ ≤1%

1 1-5%

2 5-15%

3 15-25%

4 25-50%

5 ≥50%

Source: Mirkin and Rosenberg (1978)

The following categories of plant species were given priority during the surveys: nationally protected and threatened species in Kazakhstan (Red Data Book of Kazakhstan), rare, endemic (species occurring in Kazakhstan only), or invasive plant species. For these species, more detailed and information is provided regarding their distribution, habitat requirements, abundance and threats in the study area and around it.

Mapping and ground truthing of habitat types was undertaken through recent aerial photography and satellite imagery for the project site and 500m around it.

11.3.3.2 Fauna

General Survey Methodology

Fauna surveys were undertaken between 26 and 30 May 2014 and involved a combination of line transects and point counts, following the methods described in Novikov (1949), Chelintsev (1985), and Fenyuk et al. (1963). The study area for the breeding birds included the project footprint and a buffer zone of 2km around it. Surveys targeting the following species groups were undertaken: mammals, birds, reptiles and amphibians (Appendix D Gryunberg, 2014).

Twelve transect routes were set up in four locations, north, south, east and west of the project area. The location of the transects can be seen in Figure 11.2 (see Appendix D Gryunberg, 2014, for coordinates).



Figure 11.2: Fauna Survey Map at Integrated Petrochemical Project Area

Source: Envirs Consulting



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Three transects spaced 400m apart were set up at each location, each 1300m long. Reptiles were identified within 5m either side of the transect line; birds and mammals within 30m of the transect line. Species were identified by visual inspection and searching for field signs. Emphasis was placed on frequently encountered species, dominant species, endemic species, rare species included those in the Red Book of Kazakhstan, endangered and vulnerable species, migratory species and sedentary species. Nesting bird species and the location of the nest were also noted.

In addition to the transect surveys, eight static quadrats were surveyed in the study area for the presence of the fauna listed above (see Figure 11.2 above). Each quadrat was 1ha in size, the coordinates of the locations can be found in Gryunberg (2014).

A 16km route was surveyed by car at night to record nocturnal mammal and reptile species present within the study area. Identification methodology was as per transect surveys above. The location of this transect route is provided in Figure 11.2 above.

Local people were interviewed regarding the animal species, numbers, migration seasonality, breeding and hunting in the study area during the survey period. Information on road kills near the project site was also recorded where available.

Specific Survey Methodology

Birds

Breeding bird surveys were undertaken in May 2014 during the fauna surveys, as per the methodology outlined above. Local people were also interviewed regarding the bird species, numbers, migration seasonality, breeding, and threats (e.g. hunting) in the study area during the survey period also.

Mammals

Baseline surveys for large and small terrestrial mammals were undertaken during the fauna surveys as per the methodology outlined above. Survey methodology included recording field signs (faecal pellets, tracks, feeding signs, hair) along transects during the day and at night.

Reptiles

Threatened species of reptiles are likely to occur in the project’s ZoI and therefore baseline surveys were carried out in May 2014 to inform the ESIA, as per the transect and quadrat survey methodology outlined above. In addition, artificial refugia were placed at static quadrat location F-13 and were checked twice daily over six days but avoided consecutive days. During each check, the reptile species, number of individuals, sex and approximate size was recorded, along with time of day and temperature.



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11.3.4 Determining Sensitivity and Magnitude

In accordance with IFC PS6, the conservation value (sensitivity) or weighting attributed to each ecological feature which occurs within the ZoI of the Project needs to be undertaken, and these are defined in Table 11.2. The magnitude of the potential impacts upon each feature is then assessed for the construction and operation of the Project.

Table 11.2: Criteria for Determining Conservation Value (Sensitivity of the Receiving Environment)

Conservation value (sensitivity) Species criteria Habitat or Site Criteria

Very High IUCN Critically endangered and endangered species.

Internationally designated sites (or equal status). Critical habitats of significant international ecological importance.

High IUCN Vulnerable species. European species and nationally protected species of significant population size and importance.

Nationally designated sites (or equal status). Areas of critical habitats of national ecological importance, and natural habitats of significant ecological importance and/or high biodiversity with limited potential for substitution.

Medium IUCN Near Threatened species. Nationally protected species or rare species, but not a significant population size and not of national importance.

Regionally important natural habitats. Natural habitats. Modified habitats with high biodiversity or under significant threat of loss within the region.

Low IUCN Least Concern. Species of local national importance.

Undesignated sites and natural habitats of some local biodiversity and cultural heritage interest. Modified habitats with limited ecological value.

Other sites with little or no local biodiversity and cultural interest. Modified habitats with limited biodiversity value.

Negligible IUCN Least Concern species. Species of no national importance.

Highly modified habitats of no or very limited biodiversity value.

Table 11.3: Criteria for Definition of Impact Magnitude

Magnitude (positive or negative)

Definition (considers duration of the impact, spatial extent, reversibility and ability of comply with legislation)

Major Fundamental change to the specific environmental conditions assessed resulting in long term or permanent change, typically widespread in nature (regional national and international), would require significant intervention to return to baseline; exceed national standards and limits.

Moderate Detectable change to the specific environmental conditions assessed resulting in non-fundamental temporary or permanent change.

Minor Detectable but minor change to the specific environmental conditions assessed.

Negligible No perceptible change to the specific environmental conditions assessed.

11.3.5 Determination of Significance

The significance has been determined by the interaction between the magnitude of impacts and the sensitivity of receptors affected, as depicted in the significance matrix presented Section 5.



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For each aspect, the significance of impacts will be discussed before and after mitigation (i.e. residual impact). Impacts identified as have major or moderate significance based on the above approach are classified as significant impacts.

As part of the impact assessment, appropriate mitigation measures are reviewed and included to minimise any potential adverse impacts of the project on biodiversity. The residual impacts are then determined.

11.3.6 Assessment of Cumulative Impacts

Cumulative impacts are those impacts that may result from the combination of past, present or future actions of existing or planned activities in a project’s ZoI. While a single activity may itself result in an insignificant impact, it may, when combined with other impacts (significant or insignificant) in the same geographical area and occurring at the same time, result in a cumulative impact that is significant.

The assessments within this document have included, where relevant, an assessment of the cumulative impact of the Project with other present and planned developments in the ZoI.

11.3.7 Biodiversity Mitigation and Monitoring

Mitigation measures detailed in the ESIA have been developed around international best practice and adherence to the general policies for biodiversity conservation in Kazakhstan. Mitigation measures proposed follow the mitigation hierarchy as defined within IFC PS6: avoid, reduce (minimise), remedy (restore) and offset. The biodiversity approach in this ESIA is the following: ‘No net loss’ of biodiversity; Ecosystems services approach; Seek sustainable use of biodiversity resources; Ensure equitable sharing of biodiversity resources; Apply the precautionary principle; and Take a participatory approach.

11.3.8 Data Limitations

The ecological surveys only focused on the typical habitats and areas of ecological interest. The baseline surveys followed best practice survey techniques and used a series of transects across the ZoI. This provides statically robust coverage for the Project area. This assessment has considered the nature of potential unexpected ecological features and precautionary mitigation measures along with additional monitoring are included in section 11.7.



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11.4.1 Regional Biodiversity Importance

An ecoregion is a large area of land or water that contains a geographically distinct assemblage of natural communities that: share a large majority of their species and ecological dynamics; share similar environmental conditions; and interact ecologically in ways that are critical for their long-term persistence (http://wwf.panda.org/about_our_earth/ecoregions).

The Project is located within a non-Global Ecoregion area. Kazakhstan is located within two other Global Ecoregions: the Central Asian Desert Global Ecoregion towards the south east of the Caspian Sea and the Middle Asian montane Woodland and Steppe towards the southern border of Kazakhstan and outside the ZoI of the Project. The Central Asian Desert Global Ecoregion consists of three terrestrial ecoregions: Central Asian riparian woodlands, Central Asian northern desert and Central Asian southern desert (WWF, 2011). The habitats present are a mosaic of clay, stone, salt and sandy deserts and support the highest level of biological richness of all the Eurasian deserts. There is a high level of endemic flora and fauna in this ecoregion, given the specialised adaptations to extreme temperature changes required by species (WWF, 2011).

11.4.2 Areas Protected for Nature Conservation

11.4.2.1 International Designations

The only international designation in the wider area are the Delta of the Ural River Important Bird Area (IBA), which is located approximately 60 km south-west of the Project site and the Lower Reaches of the Emba River IBA, approximately 90km to the south east of the Project site.

11.4.2.2 National and Local Designations

The Atyrau region and neighboring territories have nature reserves that meet the World Conservation Union's (IUCN) category III and category VI criteria.

Atyrau region

Novinsky Nature Reserve– this area has been designated as a protection area for the Volga river delta wetland complex. It is within a Ramsar site territory, and is over 200 km west of the Project site.

Akzhayik nature reserve – this area is also designated to protect the Ural River delta wetland complex. It forms part of a Ramsar site territory, and is over 100 km west of the Project site.

Severny Caspiy State conservation area – a 700 000 sq. km site in the northern part of the Caspian Sea (between the Volga river estuary and the Ural River estuary). Its use is regulated and the area is protected by the national government temporarily for wildlife and is likely to become a protected area in the future.



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In accordance with the “Strategic plan of governance and use of nature resources in Atyrau region in 2011 -2015”, three new protected area will be designated in the future: Balbulaksky nature reserve,

Tasshagylsky nature reserve and Indersky Natural Park (all being at least 200 km from the Project site).

Zapadno-Kazakhstansky region

Zhaltyrkulsky Zoological Reserve – is designated for its rare species of birds, and is more than 500 km north-west of the Project site.

Urdinsky Geobotanical Reserve – protects plantations of Pinus sylvestris and Populus alba forests, which provide protection against sand dispersion and movement. It is located more than 300 km north of the Project site.

11.4.3 Habitats and Plant Communities

11.4.3.1 Overview

The sections below present a summary of the broad habitats in the ZoI of the Project. The habitats in the ZoI and their IFC PS6 category and conservation value are listed in Table 11.4. Using the criteria in the IFC PS6 (IFC, 2012a) and Guidance Note 6 (IFC, 2012b), none of the habitats within the ZoI are likely to be classified as critical habitat.

Table 11.4: Habitat conservation value and IFC category within the ZoI of the Project

Habitat type IFC habitat category

Conservation value

Desert (Northern desert) Natural Low

Salt flat Natural Low

Saltmarsh Natural Low

Disturbed ground Modified Negligible

Bare ground Modified Negligible

11.4.3.2 Habitats and plant communities in the wider area

The climate in the Project area is harsh and arid, with prolonged drought during the vegetation growing season, and large fluctuations in temperature and salinity. This produces loamy, saline soils on which common vegetation communities typical of the Northern deserts are present, i.e. perennial halophytes such as Anabasis salsa, Anabasis aphylla and Atriplex cana and annual halophyte communities such as Climacoptera branchiara and Salsola foliosa and the complex of Artemisia semiarida and Artemisia vulgaris (Tetrakon Engineering, 2013).

The vegetation in the wider area is dominated by Artemisia terra-albae communities and other Artemisia species including sod steppe grasses and sod desert grasses. This vegetation includes mostly halophytes including Salsola spp. (Tetrakon Engineering, 2013).



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South of the Project in the Caspian lowlands, plant communities typical of sandy soils dominate including Artemisia lerchiana, Poa bulbosa, Agropyron fragile and Stipa sareptana. In this region these communities often form complexes with Artemisia pauciflora and Anabasis salsa which are confined to saline soils (Tetrakon Engineering, 2013).

The water pipeline component of the Project is located through the Middle Desert West Severoturanskoy province which is populated by Anabasis salsa - Artemisia terra plant communities as well as various psammophytic desert communities with Calligonum spp., Haloxyclon persicus, Haloxyclon aphyllum, Krascheninnikovia ceratoides, sand acacia Ammondendron conollyi, Atraphaxis replicate and other species (Tetrakon Engineering, 2013).

11.4.3.3 Habitats and plant communities in the Project Zol

Fifty-four plant communities were identified during the 2014 botanical surveys, of which only three communities were found to be typical of the Project area (Mott MacDonald, 2014): Sparse communities of Artemisia semiarida and Anabasis salsa; Communities of Stipa sareptana, Agropyron fragile, Elytrigia repens found in shallow depressions

where soil moisture content is high; and Rhombomys opimus communities.

At the time of the 2014 habitat and flora surveys, conditions were very hot (±40°C) and dry. The area under the direct footprint of the Project was cleared in 2012, therefore currently only comprises desert habitat, minimally vegetated with individual stands of Halocnemum strobilaceum (Mott MacDonald, 2014).

The area neighbouring the project footprint (within the ZoI) also comprises desert habitat, but with signs of previous vegetation growth including Tulipa biflora, Tulipa gesneriana, Rheum tataricum, Lepidium perfoliatum, Eremopyrum triticeum, Poa bulbosa. Drought-resistant plant species from the Chenopodiaceae family were also identified in this area, as well as Poaceae grass species (e.g. Stipa sareptana, Agropyron fragile, Elytrigia repens). The most common species identified in the area neighboring the project footprint were Artemisia semiarida and Anabasis salsa (Mott MacDonald, 2014).

Saltmarsh habitat typical of the Northern Desert was also confirmed during the 2014 survey, identified by several stands of Halocnemum strobilaceum (Mott MacDonald, 2014). Communities dominated by Climacoptera crassa, Climacoptera obtusifolia, Climacoptera brachiate, Kalidium capsicum and Kalidium foliatum are also typical of this habitat (Tetrakon Engineering, 2013).

Disturbed soils were also identified within the ZoI during the 2014 survey, formed by traffic disturbance of heavy vehicles during the spring and autumn (Mott MacDonald, 2014). This habitat lacks diversity, with only Atriplex tatarica, Anabasis salsa, Halocnemum strobilaceum and Ferula tatarica identified in single or small stands along temporary roads.

A description of the plant communities identified during the 2014 surveys in the three ‘natural’ habitat types

identified is given below (Mott MacDonald, 2014).



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Artemisia semiarida and Anabasis salsa communities

The majority of the area of the ZoI lacks diversity and is dominated by Artemisia semiarida and Anabasis salsa communities, covering 40% of the ZoI. Artemisia semiarida dominates in the east and south-east of the ZoI with an overall cover of 60%, and Anabasis salsa dominates in the west and north–west of the ZoI with an overall cover of 35%.

The dominant plant species identified in the Artemisia semiarida and Anabasis salsa communities during the botanic surveys in 2014 are listed in Table 11.5. Artemisia semiarida is the dominant species in this community, found in 60% of the quadrats, and Anabasis salsa in 35% of the quadrats. Other typical species identified in this community are Anabasis aphylla, Halocnemum strobilaceum, Atriplex cana, Atraphaxis replicate. Eremopyrum triticeum and Rheum tataricum were also present in less abundance.

During the spring season the Artemisia semiarida and Anabasis salsa communities are likely to include: Tulipa gesneriana, Tulipa biflora, Lepidium perfoliatum, Climacoptera brachiate and Poa bulbosa (Mott MacDonald, 2014),

Table 11.5: Dominant plant species identified in Artemisia semiarida and Anabasis salsa communities during the botanic surveys in 2014

Species

Frequency

(% of transects in which species was identified)

Eremopyrum triticeum 75

Rheum tataricum 32

Poa bulbosa 28

Atraphaxis replicata 26

Artemisia lercheana 24

Elytrigia repens 15

Lepidium perfoliatum 14

Anabasis salsa 12

Atriplex cana 12

Halimocnemis molissima 9

Salsola foliosa 8

Ferula tatarica 7

Astragalus physodes 5

Kochia prostrata 5

Source: Mott MacDonald (2014)



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Stipa sareptana, Agropyron fragile and Elytrigia repens communities

These grass communities are mainly present in micro-depressions in the north and east of the ZoI, which are subject to long periods of flooding in spring and are close to groundwater sources, thus making the soil saline. These patches are visible at the satellite image in dark green against light green grey.

Agropyron fragile-Stipa sareptana communities were identified with a vegetative cover between 25-50% in the ZoI. Elytrigia repens and the grass species Tanacetum turlanicum, Tulipa spp., Alyssum desertorum, Ferula tatarica, Astragalus sp. and Atriplex tatarica are also present.

Where the vegetation is dominated by Elytrigia repens communities include Tanacetum turlanicum, Ferula tatarica and Poa bulbosa. This community is distributed widely through the ZoI and vegetation cover in these communities is low, recorded at a maximum of 30% cover.

Where Agropyron fragile dominates, the community is comprised of Lepidium perfoliatum, Ferula tatarica, Poa bulbosa and Pseudosedum lievenii.

Giant gerbil Rhombomys opimus communities

Rhombomys opimus communities have been identified by Mott MacDonald (2014) as having an important edificatory role in the ZoI as they are associated with the presence of saxaul plants (Shar et al., 2008). However, these communities have been degraded by mammal foraging (a major threat to Rhombomys opimus, Shar et al., 2008). The flora in these communities is poor and consists of single, interspaced plant species only including Anabasis salsa, Halocnemum strobilaceum, Ferula tatarica, Astragalus physodes, Astragalus lasiophyllus and Plantago krascheninnikovii; the latter which only has a rare occurrence in other communities. Vegetation cover in areas where Rhombomys opimus communities are present is usually 10-25%.

Soil types identified during the 2014 surveys

No association between soil type and vegetation types was found, but rather vegetation type was correlated with soil moisture content, salinity and pressure from grazing mammals (Mott MacDonald, 2014). Generally it was found that soils identified as being wet were colonised by grass communities and drier, poorer soils by Artemisia semiarida and Anabasis salsa communities (see Mott MacDonald, 2014, for further information). Soils at locations where Rhombomys opimus communities were present were identified as being more nutrient rich.

11.4.4 Flora

Forty-two plant species were identified in the ZoI of the Project during the 2014 flora surveys, two of which are Red Data Book species in Kazakhstan:

Tulipa biflora (‘Rare’ on the Kazakhstan Red List)



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Dead remains of this species were identified in 18 locations within five transects in the ZoI (transects B3, B4, B6, B10, B13, see Figure 11.1. in Section 11.3.3.1 above).

Tulipa gesneriana L. (‘Rare’ on the Kazakhstan Red List) This species was identified only once during the 2014 flora survey, approximately 400m from the area under the project footprint in Transect B4, within a stand of Elytrigia repens (see Figure 11.1. in Section 11.3.3.1 above).

None of the species identified in the botanic surveys undertaken in 2014 (Mott MacDonald, 2014) or mentioned in the national EIA (Tetrakon Engineering, 2013) which are likely to be present in the wider area are species of international conservation concern.

A full list of plant species identified in the ZoI in 2014 is provided in Appendix D.

11.4.5 Birds

The project area is on several major flyways for bird migration; the main routes of which are along the Ural and Emba Rivers, and along the coastline of the Caspian Sea (Gryunberg, 2014). Two hundred and eighty-two species of birds have been recorded in the wider area of the Project and western Kazakhstan in previous literature (Tetrakon Engineering, 2013). No species endemic to Kazakhstan were recorded, either in the wider area or in the Zol.

One hundred and eighty five species of birds are likely to be present in the ZoI (Gryunberg, 2014). This includes more than forty-one bird species listed on the Red Data Book of Kazakhstan. This includes the rare steppe (tawny) eagle Aquila rapax, whose numbers have declined recently, the imperial eagle Aquila heliaca which inhabits steppe, desert and semi-desert habitats and saker falcon Falco cherrug whose numbers have sharply decreased in recent years due to hunting Table 11.6 below shows the birds of international conservation importance and birds listed in the Kazakhstan Red Book that have been recorded in the wider area of the Project (no such birds were recorded in the Zol during the 2014 surveys).

The great bustard has suffered a massive population reduction across most of its range, owing to habitat loss, degradation and fragmentation, as well as hunting. This species only breeds in 16 countries including Kazakhstan, although most populations are partially migratory. The species prefers open, flat and rolling habitat with a mixture of crop and steppe grassland and prefers areas with little or no disturbance and an abundant supply of insects for successful breeding (BirdLife International, 2013). The great bustard is also a Kazakhstan Red Book species, listed as Critically Endangered.

Pallas’s sandgrouse Syrrhaptes paradoxus is also know from western Kazakhstan but its status is undeterminable on the Kazakhstan Red Book. Other species considered rare but not of national or international conservation concern in the wider Project area are: pallid harrier Circus macrourus (listed as Near Threatened on the IUCN Red List) and tawny eagle Aquila rapax (Indeterminate status on the Red Book of Kazakhstan).



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Other resident bird species of no conservation concern found in the wider western Kazakhstan area include Calandra lark Melanocorypha calandra, black lark Melanocorypha yeltoniensis (this species has a large global range but populations in the most suitable habitat in central Kazakhstan have been estimated to be in the hundreds of thousands, and maybe even millions of breeding pairs (BirdLife International, 2012), black kite Milvus migrans, and bea-eater Merops persicus,.

Overwintering species of no conservation concern but known from the wider Project area and western Kazakhstan are: Eurasian skylark Alauda arvensis, Eurasian tree sparrow Passer montanus, rock sparrow Petronia petronia, Eurasian chaffinch Fringílla coélebs, and bunting Emberiza spp.

Other species known from the western Kazakhstan region, specifically the coastal regions of the Caspian Sea are: black-headed gull Larus ridibundus and herring gull Larus argentatus, great crested grebe Podiceps cristatus, great cormorant Phalacrocorax carbo, great egret Ardea alba, little egret Egretta garzetta, Northern pintail Anas acuta, mallard Anas platyrhynchos, common teal Anas crecca, garganey Anas querquedula, Northern shoveler Anas clypeata, red-crested pochard Netta rufina, common pochard Aythya ferina, smew Mergellus albellus, common merganser Mergus merganser, graylag goose Anser anser, bean goose Anser fabalis, common shelduck Tadorna tadorna and gadwall Anas strepera.

None of the bird species recorded during the 2014 biodiversity surveys are species of international conservation concern, or listed on the Red Data Book of Kazakhstan.

Twelve species were confirmed as nesting in the ZoI during the 2014 biodiversity surveys, including one bird of prey, one wader species and ten passerines. This included the Kentish plover Charadrius alexandrinus which was recorded in Quadrat F31 and F32, in depressions on the saline soils (see Figure 11.2. in Section 11.3.3.2).

Six species associated with human activity were recorded in the study area - rock pigeon Columba livia, little owl Athene noctua, Eurasian hoopoe Upupa epops, field sparrow Spizella pusilla, house sparrow Passer domesticus, and barn swallow Hirundo rustica.

The most common species of birds recorded were the small lark Calandrella brachydactyla which account for over 40% of the total number of bird sightings. Other common species include the calandra lark Melanocorypha calandra, Eurasian skylark Alauda arvensis and the grey lark Calandrella rufescens. Such species of larks (Alaudidae) are widespread in the deserts and semi-deserts near the Caspian Sea.

Birds recorded in low abundance were the common long-legged buzzard Buteo rufinus, common kestrel Falco tinnunculus and herring gull Larus argentatus, all observed singly during the 2014 surveys.



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Table 11.6: Birds of international conservation importance identified within the wider area

Species English name IUCN classification

Kazakhstan Red Book status

Mentioned in the wider area of the Project and

western Kazakhstan

Recorded during the 2014

biodiversity surveys in the Zol

of the Project

Otis tarda Great bustard Vulnerable Critically Endangered

Yes No

Tetrax tetrax Little Bustard Near Threatened

Vulnerable Yes No

Oxyura leucocephala White headed duck Endangered Vulnerable Yes No

Chlamydotis undulata/ macqueenii

Houbara’s bustard Vulnerable Vulnerable Yes No

Vanellus gregarus Sociable lapwing Critically endangered

Critically endangered

Yes No

Aquila heliaca Eastern imperial eagle

Vulnerable Vulnerable Yes No

Pelecanus crispus Dalmatian pelican Vulnerable Vulnerable Yes No

Branta ruficollis Red-breasted Goose

Endangered Vulnerable Yes No

Numenius tenuirostris

Slender-billed curlew

Critically Endangered

Critically Endangered

Yes No

Aquila chrysaetos Golden eagle Least Concern Rare Yes No

Bubo bubo Eurasian eagle-owl Least Concern Vulnerable Yes No

Phoenicopterus roseus

Greater flamingo Least Concern Vulnerable Yes No

Cygnus cygnus Whooper swan Least Concern Vulnerable Yes No

Plegadis falcinellus Glossy ibis Least Concern Vulnerable Yes No

Grus grus Common crane Least Concern Rare Yes No

Pterocles orientalis Black-bellied sandgrouse

Least Concern Vulnerable Yes No

Ardeola ralloides Squacco heron Least Concern Vulnerable Yes No

Circaetus gallicus Short-toed snake eagle

Least Concern Critically Endangered

Yes No

Pelecanus onocrotalus

Great white pelican Least Concern Critically Endangered

Yes* No

Egretta garzetta Little egret Least Concern Rare Yes* No

Ciconia nigra Black stork Least Concern Rare Yes* No

Platalea leucorodia Eurasian spoonbill Least Concern Vulnerable Yes* No

Phoenicopterus roseus

Greater flamingo Least Concern Vulnerable Yes* No

Larus ichthyaetus Pallas’s gull Least Concern Vulnerable Yes* No

Falco peregrinus Peregrine falcon Least Concern Critically Endangered

Yes* No



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Kazakhstan Red Book status

Mentioned in the wider area of the Project and

western Kazakhstan

Recorded during the 2014

biodiversity surveys in the Zol

of the Project

Hieraaetus pennatus Booted eagle Least Concern Rare Yes* No

Pandion haliaetus Osprey Least Concern Critically Endangered

Yes* No

Chettusia gregaria Sociable lapwing Vulnerable Endangered Yes No

Porphyrio porphyria Purple gallinule Least Concern Vulnerable Yes No

Crex crex Ocorncrake Vulnerable - Yes No

Grus grus Crane Least Concern Rare Yes No

Grus leucogeranus Asiatic white crane Critically Endangered

Endangered Yes No

Falco naumanni Lesser kestrel Vulnerable - Yes No

Falco cherrug Saker falcon Endangered Endangered Yes* No

Haliaeetus albicilla White-tailed eagle Near Threatened

Vulnerable Yes No

Aquila clanga Spotted eagle Vulnerable - Yes No

Aythya nyroca Ferruginous duck Near Threatened

Rare No

Anas angustirostris Marbled duck Vulnerable Endangered Yes No

Cygnus arrul Whooper swan Not assessed Vulnerable Yes No

Anser erythropus Lesser white-fronted goose

Vulnerable - Yes No

Rufibrenta ruficollis Red-breasted goose Vulnerable Vulnerable Yes No

Source: Gryunberg (2014), *denotes species recorded during the spring and autumn migration period.

11.4.6 Mammals

Forty mammal species are known from the wider Project area and western Kazakhstan. The mammal fauna is diverse and represented by rodent species (e.g. Spermophilus, Allactaga, Meriones), mainly from desert habitat (Tetrakon Engineering, 2013). The most abundant family is the Gerbillinae. Table 11.7 below shows the mammal species of conservation importance identified within or near to the Zol of the Project.

Saiga Saiga tatarica ssp. tatarica is a migratory species of global conservation concern listed as Critically Endangered on the IUCN Red List. The Project site is between but outside the Ustyurt population of the Saiga (summer range) and the Ural population (winter range) of this species. Occasional sightings of Saiga are mentioned in Bekenov et al. (1998) near the project area, between the Ural and Ustyurt populations. However, the Regional Forestry and Hunting Inspection (personal communication) have confirmed that Saiga has not been observed in the Project area since 2000 and no evidence of Saiga were recorded during the 2014 surveys.



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Mammal species listed on the Red Data Book of Kazakhstan and likely to be present in western Kazakhstan are: Caracal Caracal caracal (Critically Endangered); Bobrinski’s serotine bat Eptesicus bobrinskoi (Rare) - found in the north eastern coast of the Caspian Sea; sand cat Felis margarita (Rare and listed as Near-threatened on the IUCN Red List); and, Pallas’s cat Felis (Otocolobus) manul (listed as Rare on the Red Data Book of Kazakhstan and Near-Threatened on the IUCN Red List).

The most common species of bats found in the wider Project area and western Kazakhstan are the steppe whiskered bat Myotis mystacinus, serotine bat Eptesicus serotinus and the particoloured bat Vespertilio murinus. None of these bat species listed are of international or national conservation concern.

Other species present in the wider Project area and western Kazakhstan, but not of conservation concern are the long-eared hedgehog Hemiechinus auritus, the racoon dog Nyctereutes procyonoides, gray wolf Canis lupus, red fox Vulpes vulpes, corsac fox Vulpes corsac, least weasel Mustela nivalis, ermine Mustela erminea, the steppe polecat Mustela eversmanii, yellow ground squirrel Spermophilus fulvus, small five-toed jerboa Allactaga elater, Siberian jerboa Allactaga sibirica and Eurasian badger Meles meles – which inhabits the north-east coast of the Caspian Sea, and the African wildcat Felis silvestris lybica. The wild boar Sus scrofa also inhabits the delta of the Emba River. All of these terrestrial mammal species are listed as Least Concern on the IUCN Red List.

Over 30 mammal species from 11 families are likely to be present in the ZoI but only 20 mammal species from ten families were recorded during the biodiversity surveys in 2014 (Gryunberg, 2014). One internationally threatened species was recorded – European marbled polecat Vormela peregusna, listed as Vulnerable on the IUCN Red List and Rare on the Red Data Book of Kazakhstan (see Table 11.7. below). This species is distributed from south-east Europe to northern China and Mongolia but is rare in much of its range, threatened mainly through the loss of natural steppe and desert habitats (Tikhonov et al., 2008). It inhabits desert, semi-desert and steppe habitats. This species was confirmed in the ZoI in 2014 through photographic evidence confirmation (Gryunberg, 2014).

The Aral fat-tailed jerboa Pygeretmus platyurus was recorded in areas with sparse vegetation. This species is sub-endemic, found only in Kazakhstan and Turkmenistan, where it is widespread with no major threats (Tsytsulina, 2008). This species inhabits clay semi-deserts and deserts where it burrows simple tunnels with several cells. Three individuals were observed during the 2014 surveys, during the nocturnal survey in transect F15-F16. It feeds mostly on green parts of saltworts, rarely on seeds and underground parts of plants (Tsytsulina, 2008).

The majority of mammals recorded were either from the sand eel family (Gerbelina), or rodents, including the great gerbil Rhombomys opimus, which is listed as the most common species. Colonies of this species were found in all transects and static quadrat sites. The red tail gerbil Meriones libycus was also found, but in lesser abundances than the great gerbil.

Two species of the squirrel family (Sciuridae) were recorded: Aral yellow souslik (yellow ground squirrel) Spermophilus fulvus and little souslik (little ground squirrel) Spermophilus pygmaeus, the latter confined to wet areas along road edges.



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Three species of the false jerboas family (Allactagidae) were also recorded: the common species little jerboa Allactaga elater and the great Jerboa Allactaga major, observed on a single occasion during the nocturnal surveys in transect F31-F32.

Other species recorded included the gray hamster Cricetulus migratorius, social vole Microtus socialis, and the European hare Lepus europaeus, the latter which was identified during the nocturnal and diurnal transect surveys in transect F7-F8, F11-F12.

Table 11.7: Mammals of conservation importance identified within or near the ZoI of the Project


Kazakhstan Red Data Book status

Endemic to Kazakhstan

Recorded in the 2014 biodiversity surveys

Vormela peregusna

European marbled polecat

Vulnerable - No Yes

Caracal caracal Caracal Least Concern Critically Endangered

No No

Eptesicus bobrinskoi

Bobrinski’s serotine bat

Least Concern Rare No No

Felis margarita Sand cat Near Threatened Rare No No

Felis (Otocolobus) manul

Pallas’s cat Near Threatened Rare No No

Pygeretmus platyurus

Aral fat-tailed jerboa

Least Concern - Sub-endemic (Kazakhstan and Turkmenistan)

Yes

11.4.7 Reptiles and Amphibians

The amphibian fauna of the wider Project area and western Kazakhstan is represented by two species: green toad Bufo viridis or Pseudepidalea viridis subgroup and the Eurasian marsh frog Pelophylax ridibundus. Both species are common and widespread in western, central and eastern Europe and inhabit a wide range of habitats including forests, forest steppe, scrubland, grassland and alpine habitats (Agasyan, 2009). The green toad is known to reach a population size of 40-50 individuals/hectare in the floodplain areas of the Emba River, but only 1-6 individuals/hectare in the arid regions and temporary ponds in the ZoI (Tetrakon Engineering, 2013).

Twenty-one species of reptiles are known from the wider Project area and western Kazakhstan, concentrated in the riverine habitats and from the Emba estuary, of which ten species are listed in the desert habitat within the ZoI (Tetrakon Engineering, 2013). One species is of international conservation concern, listed as Vulnerable on the IUCN Red List of Threatened Species: the Central Asian tortoise Testudo horsfieldii. The assessment information provided by the IUCN is given the status ‘needs updating’

The four-lined snake Elaphe quatuorlineata is a rare species in western Kazakhstan, with an Indeterminate Red Data Book status. This species is also listed as Near-Threatened on the IUCN Red List of Threatened



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Species. The Caucasian gecko Cyrtopodion (Mediodactylus) russowi is also listed in the OVOS as present in the desert habitat within wider Project area. This species is native to Kazakhstan and found only east of the Caspian Sea as far as northeastern Iraq. This species was declared extinct in the Red Book of the Russian Federation in 2001 due to lack of records after 1935 (Ananjeva, 2010).

Other reptile species previously recorded in the wider Project area include the even-fingered gecko Alsophylax pipiens, sunwatcher Phrynocephalus helioscopus, secret toad-headed agama Phrynocephalus mystaceus , spotted toad-headed agama Phrynocephalus guttatus, steppe agama Trapelus sanguinolentus, the wall lizards Eremias lineolata, Eremias arguta, Eremias velox, dwarf sand boa Eryx miliaris and the steppe ribbon racer Psammophis lineolatus.

Sunwatcher is a sub-endemic species, found only in Central Asia. The secret toad-headed agama Phrynocephalus mystaceus is considered rare in most parts of its territory west of the Emba River but is not a Red Data Book species in Kazakhstan (Tetrakon Engineering, 2013).

Other reptile species are known to be present in western Kazakhstan, but with a wider distribution outside the ZoI are: tessellated water snake Natrix tessellata and the dwarf sand boa Eryx miliaris in riverine habitat on the banks of the Emba River and the coastline of the Caspian Sea; meadow viper Vipera ursinii (listed as Vulnerable on the IUCN Red List) in floodplains and wet areas of the Caspian steppe; and four lined snake Elaphe quatuorlineata (listed as Near-threatened on the IUCN Red List), steppe rattlesnake Elaphe dione, Siberian pit viper Gloydius halys, and the sand lizard Lacerta agilis distributed throughout Kazahkstan.

Seven reptile species from four families were identified during the biodiversity surveys in 2014. None of the species found are of conservation concern globally, or species listed on the Red Book of Kazakhstan, and no rare reptile species are likely to be present in the ZoI (Gryunberg, 2014). The most highly distributed species found was the wall lizard steppe runner Eremias arguta which was identified over a wider distribution in the study area, in seven of the eleven transects surveyed (F7-F8, F11-F12, F17-F18, F19-F20, F21-F22, F25-F26, F27-F28; see Figure 11.2 in Section 11.3.3.2.). This species has not yet been assessed against the IUCN Red List of Threatened Species.

The sand lizard Lacerta agilis was recorded in one transect in the study area (transect F22-F21), where steppe vegetation is present. Three individuals of this species were observed (1 male and 2 female). Snake species identified were pallas coluber (steppe rattlesnake) Elaphe dione, steppe ribbon snake Psammophis lineolatum and orsini viper Vipera ursini. All snake species are scarce in the study area, but none of the species found are Red Data Book species in Kazakhstan.

Of the amphibians, only the green toad Bufo viridis was identified in the study area during the biodiversity surveys in May 2014 (Gryunberg, 2014). The marsh frog (Rana/Pelophylax ridibunda) is also known to be present in waterbodies immediately outside the ZoI, including the Sokolok River. Neither of these amphibian species are of conservation concern.



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Table 11.8: Herpetofauna of conservation importance identified near to ZoI of the Project

Species English name IUCN classification Kazakhstan Red Data Book

Endemic to Kazakhstan

Recorded in 2014 survey

Testudo horsfieldii

Central Asian Tortoise

Vulnerable No No No

Elaphe quatuorlineata

Four-lined Snake Near Threatened Indeterminate No No

Cyrtopodion (Mediodactylus) russowi

Caucasian gecko Least concern No Sub-endemic (Caucasian)

No

11.4.8 Invertebrates

There are more than 300 species of invertebrates known from the habitat present in the wider Project area and western Kazakhstan around the Caspian Sea (Tetrakon Engineering, 2013). These species are distributed through the saline desert, scrub ad semi-desert habitat typical in the north and east of the Caspian Sea. The majority are families of anthophilous invertebrates including: Halictidae, Andrenidae, Sphecidae, Eumenidae, Chrysididae, Pompilidae, Ichneumonidae, Braconidae, Pteromalidae, Encyrtidae, Eurytomidae, Tachinudae, Sarcophagidae, Syrphidae, Culicidae, Tephritidae, Chrysomelidae, Bruchidae, Dermestidae, Mordellidae, Coccinellidae, Pieridae, Diptera, Hymenoptera, Lepidoptera and Coleoptera. None of the families listed are known to be of international conservation concern.

One species present is listed on the Kazakhstan Red Book: Cicindela nox (status unknown), and twenty other species present are considered rare in Kazakhstan including: Scarabaeus tiphon, Pyrgodera armata, Cleonus sp., Iris polysetica, Julodis variolaris, Aeschna sp., Podalonia ebenina, Cryptocheilus sp., Galeodes caspius and Lycaena sp.

Also present in the wider Project area are several families from the Class Arachnida: Aranea, Lycosidae, Tirigidae, Arachnidae, Solifules and Ageleniidae; as well as scorpions Scorpiones, molluscs Mollusca and desert woodlice Isopoda (Tetrakon Engineering, 2013).


11.5.1 Overview

This section describes the likely ecological impacts of the main activities associated with the Project prior to mitigation.

The impacts are presented for each project phase i.e. construction, operation and decommissioning. Impacts on ecological features of negligible conservation importance are not assessed or discussed in this chapter.



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11.5.2 Construction Impacts

During the construction of the Project, the potential impacts could include: Noise and light disturbance from construction activities affecting birds and mammals; Dust deposition around working areas affecting adjacent habitats; Increased risk of localised pollution events due to use of construction vehicles affecting adjacent

habitats; Localised changes in air quality resulting from construction activities and increased vehicle movements

through the area; Accidental introduction and dispersal of invasive species from construction activities; and Temporary habitat loss during construction of a new water pipeline and upgrading of the existing

pumping stations.

11.5.2.1 Protected Areas

The protected areas (international or national designations) identified in Section 11.4.2 are further than 5 km from the Project area (the closest is 60km away) and are extremely unlikely to be affected by the works. The sensitivities of the protected sites are considered to be medium and high. Given that impact magnitude is negligible, any impacts are considered to be not significant.

11.5.2.2 Sensitive Habitats

The Project site consists of bare and disturbed ground as the area has already been cleared. The habitats within the Zol of the Project are of low conservation value. Some additional vegetation clearance is likely to be required for the construction of the new water pipeline and for the upgrading of existing pumping stations. However, these habitats are considered to be of low conservation value and the impacts of the works will be minor in magnitude and therefore not a significant effect.

Increased dust levels and deposition are likely during construction, but sensitive habitats and flora are unlikely to be affected given the location of the Project site within an existing cleared area.

11.5.2.3 Notable Flora

The desk study indicates mainly common species of flora are present in the Zol (see Section 11.4.4 above). These are generally considered to be of low conservation value and of low sensitivity. Impacts on these locally important species are considered to be minor adverse in magnitude and effects likely to be assessed as not significant.

Two Kazakhstan Red Data Book species were recorded within the Zol of the Project: Tulipa biflora and Tulipa gesneriana L. These were recorded at transects all around the works area. Indirect impacts on these species may include increased dust and disturbance through off-road driving. These species are considered to be of medium conservation value. Impacts of the works are considered to be minor adverse in magnitude and therefore the effect is minor adverse and is not significant.



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11.5.2.4 Notable Fauna

There are records for threatened fauna in the Zol that are listed on the IUCN Red List and the Red Data Book of Kazahkstan, including two mammal species (European marbled polecat Vormela peregusna and Aral fat-tailed jerboa Pygeretmus platyurus) . No bird, reptile, amphibian or invertebrate species of international conservation concern or listed on the Red Data Book of Kazakhstan were recorded in the 2014 biodiversity surveys.

Adverse impacts on European marbled polecat Vormela peregusna and Aral fat-tailed jerboa Pygeretmus platyurus may involve temporary loss of habitat (resulting from the construction of the new water pipeline), and indirect impacts such as disturbance caused by noise and artificial lighting. . Marbled polecat Vormela peregusna and Aral fat-tailed jerboa Pygeretmus platyurus have been recorded in the Zol in the 2014 biodiversity surveys and are considered to be of high conservation value and of medium conservation value, respectively. Given the temporary nature of the habitat loss and the distance they were recorded from the Project site (approximately 1km), they are considered to have low sensitivity to the impacts described above. Impacts are considered to be of minor magnitude, and therefore not significant.

Impacts on other globally or nationally threatened mammal species are considered to be negligible, given that none were recorded in the Zol of the Project (see Section 11.4.6 above). Saiga Saiga tatarica ssp. tatarica are not known to be present in the Project Zol (personal communication from the Regional Forestry and Hunting Inspection, Bekenov et al., 1998) and no evidence was recorded in the 2014 surveys. Therefore, they are considered unlikely to be affected by the works. They are of very high conservation value and with negligible sensitivity to the impacts of construction described above. Impacts are considered to be of negligible magnitude and therefore not significant.

Caracal Caracal caracal sand cat Felis margarita and Pallas’s cat Felis (Otocolobus) manul are considered to range from medium to high conservation value and of low sensitivity to the impacts described above. Impacts on them are considered to be of minor magnitude, given the limited and temporary nature of habitat loss; the effect is assessed as minor and therefore not significant.

Impacts on globally or nationally threatened bird species are considered to be negligible (unlikely), given that none were recorded in the Zol of the Project (see Section 11.4.5 above). These species are considered to be of very high conservation value but given the likely distance from the works, are considered to have negligible sensitivity to the Project. Impacts on Critically Endangered and Endangered species can be considered to be of negligible magnitude and therefore not significant.

Impacts on globally or nationally threatened reptiles and amphibians are considered to be negligible, given that none were recorded in the Zol of the Project (see Section 11.4.7 above). Those present in the wider area are considered to range between medium to high conservation value and of low sensitivity to the impacts described above, given their likely distance to the Project area. Impacts are considered to be of negligible magnitude and therefore not significant.



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11.5.3 Operation Impacts

During operational activities of the Project, the potential adverse impacts on habitats, flora and fauna may include: During the early phases of the Project, liquid propane will be transported to the Project site using;

existing rail and loading facilities (that have been constructed for the IPC). There is a risk of pollution as products are taken to site, including spillages and leaks;

There is low pollution risk from the storage and transport of catalysts used in the polypropylene process;

There is a low risk of pollution from inappropriate storage of liquid propylene and hydrogen; There is a low risk of pollution from the transportation of polypropylene pellets, which will loaded onto

trucks or rail; There is low risk of pollution from new gas pipelines that will provide natural gas to the plant; There is a negligible risk of increased pollution into rivers within the Atyrau Region as the Project will

not abstract or discharge water into these rivers (water will be sourced from Kigach River located across the Kazakhstan/Russian border near to Astrakhan);

Flares from Project sites may have a negative impact on migrating birds but flaring will be minimal during normal operation and also used in emergency situations;

Increased abstraction from the Kigach River, one of the tributaries of the Volga at Astrakhan; and Increased disturbance and noise from workers on fauna. Further information is provided in the following sections where relevant.


The risk to protected areas being affected during operation is considered to be negligible given the distance to the works area. Project impacts on protected areas during operation are therefore not predicted to result in a significant effect (medium to high conservation value and negligible magnitude).

11.5.3.2 Habitats

There are no sensitive habitats on the Project site and Zol that will be affected during operation. The habitats that may be affected by accidental pollution (in the absence of mitigation) are of low and negligible conservation value, and impact magnitude is minor. Project effects on habitats are therefore not significant.

11.5.3.3 Flora

Two nationally threatened plant species are known to occur in the Zol: Tulipa biflora and Tulipa gesneriana. Adverse impacts on these species could include pollution resulting from the spillage of chemicals, as described above. These impacts are likely to be minor, as chemicals will be stored and transferred within the Project area, and should not spread out into the Zol. The magnitude of the impact is likely to be negligible adverse as these species are not present within the Project site itself, but recorded 500m away or more. The sensitivity of these species to pollution and spillage is considered to be high.



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However, given that impacts are considered to be of negligible magnitude, the effect on nationally threatened species is not considered to be significant.

The other flora species in the ZoI are of low conservation value and impact magnitude is likely to be minor or negligible. Project effects on other flora species during operation are not considered to be significant.

11.5.3.4 Fauna

The impacts on threatened mammal and reptile species are considered to be negligible during operation since loading will occur within the existing industrial area and air quality will not change markedly compared to the baseline conditions.

Flaring and noise disturbance during operation may have adverse impacts on birds and bats, but these impacts are likely to be minor (in the absence of mitigation) as flaring will be minimal during normal operation and occur in emergencies only. The magnitude of the impacts on birds and bats is likely to be minor adverse because the habitats suitable for these species are not in the immediate vicinity of the Project sites. The Project impacts on threatened and notable fauna during operation are considered to be of minor significance for the species that have medium or high conservation value. For all other animal species of low conservation value, Project effects are predicted not to be significant.

11.5.4 Decommissioning Impacts


No adverse impacts are likely on any protected areas during decommissioning, as all protected areas are in excess of 5 km from the project site. Project effects on protected areas during decommissioning have been assessed as not being significant.

11.5.4.2 Habitats

The Project site consists of bare and disturbed ground as the area has already been cleared. The habitats within the Zol of the Project are of low conservation value. Some additional vegetation clearance may be required for the decommissioning of the water pipeline and pumping stations. Impacts of decommissioning are expected to be minor in magnitude and therefore not likely to result in a significant effect.

11.5.4.3 Flora

Effects on threatened species of plants are unlikely to be significant during decommissioning. The magnitude of the impacts during construction is likely to be negligible during decommissioning as no habitat will be lost during this phase and changes in the hydrology are unlikely.



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11.5.4.4 Fauna

Impacts during decommissioning are likely to be similar to construction. The birds and bats may be affected by noise and artificial lighting during decommissioning; these effects are likely to be minor in the absence of mitigation, and therefore not significant.


There are no other projects outside the IPC that could result in cumulative impacts on habitats, flora and fauna.


11.7.1 Mitigation

11.7.1.1 Overview

Mitigation measures have been developed for key biodiversity features to ensure the systematic implementation of the mitigation hierarchy i.e. avoid, reduce (minimise), remedy (restore) and offset. This will allow for the careful management of risk, the best possible outcomes for the Project without compromising the health, function and integrity of the ecological systems. All effects are assessed as not significant because the biodiversity receptors are of low conservation value or the impact magnitude is negligible or minor. In line with EBRD PR6 (2014), the mitigation hierarchy should be implemented to achieve no net loss of biodiversity, even if the habitats are classified as modified IFC PS6 requires that impacts on biodiversity are minimised in modified habitat and in natural habitat the mitigation hierarchy is implemented to achieve no net loss of biodiversity where feasible (IFC, 2012a). The best practice measures presented below will help reduce further the scale of the impacts identified.

11.7.1.2 Avoidance Measures Incorporated in Project Design

The design of the Project has taken into consideration the environmental and ecological sensitivities, with the aim to avoid significant impacts on the areas of high nature conservation value, in particular: The Project location has been chosen in an area where existing infrastructure can be maximised for

the delivery of raw materials and the transport of the final polypropylene pellets. Flares will be used instead of venting of excess/waste gases, and there will be two flares (associated

with the plant. All of the major process systems will be connected to the appropriate corresponding flare to minimise fugitive emissions (see Section 2 for further details).

The Project will comply with safety standards to avoid spillages and leakages from chemicals and liquids stored onsite. Set procedures will be followed where spillages and leakages do occur.

11.7.1.3 Generic Mitigation Measures

The following generic mitigation measures will be applied on the Project:



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All construction and operational working areas will be kept to the minimum to reduce habitat loss and degradation;

Access routes for construction and operational activities outside the existing cleared area (if required) will be kept to a minimum. Plans will be implemented to minimise all construction traffic activities outside the existing industrial area. These actions will significantly reduce potential impacts on habitats and disturbance to species;

Artificial lighting used on construction sites and camps will be minimised, shaded and directed downwards to avoid light spillage and disturbance to birds, bats and other wildlife.

Noise disturbance and vibration will be kept to a minimum through measures such as ensuring proper maintenance of construction machinery and equipment and complying with national standards;

Measures, such as wind breaks and chemical binding agents will be implemented for reduction of dust during the working period;

All workers engaged in the Project will be made aware of the environmental and ecological sensitivities on the project site and surrounding areas.

11.7.1.4 Habitats and Flora

There are no sensitive habitats likely to be affected by the works, but there are two nationally threatened species of plants in the proximity of the project site. There is unlikely to be a significant impact on habitats and flora as the Project area has already been cleared ready for construction. Any potential impacts on habitats and flora as a result of spillages and pollution will be mitigated as described below in Section 11.7.1.5.

The design of the Project has considered and incorporated the use of existing infrastructure corridors in order to avoid or minimise habitat loss and degradation.

Any additional habitat clearance required will be restored on-site (if the impact is temporary) or recreated off-site through new planting using native species that do not require special irrigation measures.

11.7.1.5 Pollution prevention and control

Pollution prevention and treatment measures will be implemented with regard to waste water, as recommended in the following IFC Environmental, Health and Safety (EHS) Guidelines: Petroleum-based Polymers Manufacturing (IFC, 2007); Large Volume Petroleum-based Organic Chemicals Manufacturing (IFC, 2007); A Spill Prevention and Control Plan will be prepared for the construction site, including the following

measures; Conduct a spill risk assessment; Install secondary containment around vessels and tanks to contain accidental release; Develop corrosion maintenance and monitoring programme to ensure the integrity of all equipment; Ensure spill response and containment equipment is deployed or available for a response.



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A Spill Response Plan will also be prepared and implemented to address potential chemical and fuel spills from facilities, vehicles, loading/unloading operations and pipeline ruptures. More details on spill prevention and control are found in the IFC EHS Guidelines mentioned above).

11.7.1.6 Birds

To minimise the potential impact to all breeding bird species, any further vegetation clearance will be undertaken outside of the bird nesting period (main breeding season is between April to July). Where clearance is not possible outside the breeding season, a check for breeding birds and active nests by a qualified ecologist will be undertaken 48 hours prior to vegetation clearance. If breeding birds are discovered then works will be postponed in that area until the breeding cycle is complete (this may take up to three weeks). A species specific buffer zone (minimum 25 m) will be set up around the nest site.

The study area is on several major global flyways for migratory land and waterbirds (CMS, 2011a). The following best practice noise reduction measures will be implemented to reduce impacts on breeding or migrating birds during construction: Avoidance of unnecessary revving of engines and switch off equipment when not required; Vehicles and equipment will be properly maintained to meet the manufacturers’ noise rating levels. Any

silencers or bearings which become defective would be replaced as soon as possible; Using reverse warning systems incorporating broadband noise where practicable; Using enclosures for noisy plant such as pumps or generators; Minimising drop height of materials; Limiting the use of particularly noisy plant or vehicles where practicable; and Plant and vehicles will be operated with noise control hoods closed.

Measures to minimise flare volumes will be implemented where and when possible, in particular during the spring and autumn bird migration. Venting of the gas is not considered best practice and will not be used. Pollution prevention and control measures for gas flaring will be implemented, in line with the IFC EHS Guidelines (IFC, 2007).

11.7.1.7 Mammals

Habitat loss should be avoided, and where possible a phased vegetation clearance should be undertaken, to ensure animals are able to escape the works area during construction. Noise and disturbance should be minimized through best practice measures during construction and operation (see Section 11.7.1.3 above).

11.7.1.8 Non-native Invasive Species

Non-native (alien) invasive species are the second threat to the global biodiversity after habitat destruction. The likelihood of invasions by non-native species is higher in habitats that are altered and disturbed, for example during construction. Invasive species have the following traits: Fast growth Rapid reproduction High dispersal ability



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Ability to alter growth form to suit current conditions Tolerance of a wide range of environmental conditions Ability to live off of a wide range of food types Association with humans

No non-native and invasive species are highlighted in the national EIA (Tetrakon Engineering, 2013). However, any development project poses a risk of spreading invasive species, including plants, fish and invertebrates in particular. IFC PS6 (IFC, 2012) includes the following best practice measures with regard to Alien Invasive Species (AIS): Must not intentionally introduce alien species unless this is in accordance with existing national

regulatory framework; Must not deliberately introduce AIS irrespective of national regulatory framework; Introduction of alien species (e.g. in planting) must be subject to a risk assessment; Implement measures to avoid accidental introduction or spreading of alien species (see below); and Consider the implementation of measures to eradicate AIS from natural habitats over which KPI has

management control.

All construction and operational activities will comply with the International Petroleum Industry Environmental Conservation Association (IPIECA) guidelines on the prevention and management of alien plant and animal species (IPIECA, 2010). Preventative, control and monitoring measures will be implemented with regard to the following aspects of the Project:

Packaging and movement of materials Minimise traffic and the distance it has travelled Source goods/materials locally where possible Contain any AIS and report their presence

Vehicles and plant ‘As-new’ wash-down is essential before entering non-infested areas and after working in infested areas Train and raise awareness regarding AIS Pressure wash vehicle tyres in a contained area Contain and destroy residue Record and report the presence of any AIS

Soil and vegetation Minimize disturbance to, or movement of, soil and vegetation Prevent soil damage and erosion Ensure imported soil/other materials are safe and free of AIS (source from a reputable supplier,

request information on the soil’s origin and certification of AIS-free status if possible) Prevent AIS establishment on exposed stored soil (do not store bare soil near known sources of AIS,

consider using matting to cover exposed soil) Ensure infested material is disposed of safely Retain as much natural vegetation as possible



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Habitat reclamation Use native plants for reinstatement and landscaping Assess any non-native species (to be used in landscaping) for AIS potential Consider that some AIS may be soil-based Avoid altering soil and water body properties

11.7.2 Monitoring

Monitoring of ecological mitigation will be conducted for the duration of the construction phase. These requirements, along with associated responsibilities and reporting requirements will be detailed in the Construction Environment Management Plan (CEMP). The Environmental Manager of the EPC contractor or EPCM contractor will ensure the measures included in this report and the CEMP are implemented during the construction of the Project. Specialist advice from a qualified ecologist will be obtained when required. The environmental (including ecological) reporting responsibilities during construction will be described in the CEMP.


The ZoI of the Project supports habitats and species typical of the region, and which are of very high to low biodiversity conservation importance. However, the habitats and species of high/medium conservation value are either unlikely to be affected by the Project, or the magnitude of the impacts is likely to be minor.

Without mitigation the Project would have a number of minor adverse impacts on the biodiversity. These impacts will be significantly reduced through the responsible implementation of the mitigation and measures, which are described in Sections 111.7.1.

In the long-term the overall impact on biodiversity is likely to be negligible.

Table 11.9 summarises the residual impacts of the Project on the key ecological features which occur within the ZoI.

Table 11.9: Summary of Residual Impacts during Construction and Decommissioning of the Project

Key Ecological Features

Potential Impacts (construction)

Sensitivity (Conservation Importance)

Magnitude of Impact

Impact Significance

Mitigation Residual Impacts

Protected areas

International designations (IBA)

Impacts very unlikely as the IBA is 60 km away from Project site

Very high Negligible Insignificant None required Insignificant

National and Local Designations

Impacts very unlikely as all are in excess of 100 km from Project site

Medium and High

Negligible Insignificant None required Insignificant

Habitats



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Magnitude of Impact

Impact Significance


Natural and modified habitats

Temporary habitat loss for pipeline route. Increased dust.

Low and Negligible

Minor Insignificant Best practice measures to minimise habitat loss and degradation

Insignificant

Flora

Nationally important plant species (Kazakhstan RDB)

Impacts on Tulipa biflora and Tulipa gesneriana L. are unlikely

High Negligible Insignificant Pollution prevention and best practice measures to minimise habitat loss and degradation

Insignificant

Non-notable plant species

Pollution resulting from the spillage of chemicals.

Low Minor Insignificant Pollution prevention and best practice measures

Insignificant

Fauna

Threatened bird species (IUCN Red List)

Loss of small areas of suitable habitat, noise and disturbance.

Very high Minor Minor adverse

Avoidance or minimisation of habitat loss and degradation.

Best practice measures during construction to reduce noise.

Pre-construction checks for breeding birds

Insignificant

Threatened mammal species (IUCN Red List) recorded in the Project Zol

Impacts on European marbled polecat Vormela peregusna and Aral fat-tailed jerboa Pygeretmus platyurus possible.

Loss of small areas of suitable habitat, noise, disturbance.

High and Medium

Minor Minor adverse

Phase habitat clearance.

Best practice measures for noise and disturbance.

Insignificant

Threatened mammal species recorded in the wider area only

Impacts on Saiga Very High Negligible Insignificant None Insignificant

Threatened mammal species in the Project Zol

Impacts on Caracal Caracal caracal sand cat Felis margarita and Pallas’s cat Felis (Otocolobus) manul

Medium to High

Minor Minor adverse

Phase habitat clearance.

Best practice measures for noise and disturbance.

Insignificant

Non-notable mammal species

Noise and disturbance.

Low Minor Insignificant Best practice measures for noise

Insignificant



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Magnitude of Impact

Impact Significance


and disturbance.

Threatened herpetofauna

Impacts on Central Asian Tortoise (Testudo horfieldii)

Medium to High

Negligible Insignificant None Insignificant

Table 11.11: Summary of Residual Impacts during Operation of the Project


Potential Impacts

(operation)

Sensitivity (Conservation

Importance)

Magnitude Impact Significance


Protected areas

International designations (IBA)

Impacts very unlikely as the IBA is 60 km away from Project site

Very high Negligible Insignificant None required Insignificant

National and Local Designations

Impacts very unlikely as all are in excess of 100 km from Project site

Medium and High

Negligible Insignificant None required Insignificant

Habitats

Natural and modified habitats

Increased dust. Risk of spillages and pollution.

Low and Negligible

Minor Insignificant Best practice measures

Insignificant

Flora

Nationally important plant species (Kazakhstan RDB)

Impacts on Tulipa biflora and Tulipa gesneriana L. are unlikely but could include pollution resulting from the spillage of chemicals.

High Negligible Insignificant Pollution prevention and best practice measures

Insignificant

Non-notable plant species

Pollution resulting from the spillage of chemicals.

Low Minor Insignificant Pollution prevention and best practice measures

Insignificant

Fauna

Threatened bird species (IUCN Red List)

Flaring. Very high Minor Minor adverse Best practice measures with use of flaring minimal during normal operation and

Minor adverse



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Potential Impacts

(operation)

Sensitivity (Conservation

Importance)

Magnitude Impact Significance


occurring in emergencies only.

Threatened mammal species (IUCN Red List) recorded in the Project Zol

Noise and disturbance

Medium and High

Minor Minor adverse Best practice measures for noise and disturbance.

Insignificant

Threatened mammal species recorded in the wider area only

Impacts on Saiga

Very High Negligible Insignificant None Insignificant

Threatened mammal species in the Project Zol

Impacts on Caracal Caracal caracal sand cat Felis margarita and Pallas’s cat Felis (Otocolobus) manul unlikely

Medium to High

Negligible Insignificant Best practice measures for noise and disturbance.

Insignificant

Non-notable mammal species

Noise and disturbance.

Low Minor Insignificant Best practice measures for noise and disturbance.

Insignificant

11.9 References

Agasyan, A., Avci, A., Tuniyev, B., Crnobrnja Isailovic, J., Lymberakis, P., Andrén, C., Cogalniceanu, D., Wilkinson, J., Ananjeva, N., Üzüm, N., Orlov, N., Podloucky, R., Tuniyev, S., Kaya, U., Stöck, M., Sharif Khan, M. Kuzmin, S., Tarkhnishvili, D., Ishchenko, V., Papenfuss, T., Degani, G., H. Ugurtas, Rastegar-Pouyani, AMohammed Disi, Anderson, Beebee & Andreone (2009). Pseudepidalea viridis. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.2. [Online]. Available from www.iucnredlist.org. (Accessed: 28 May 2014).

Ananjeva, N., Orlov, N., Papenfuss, T. & Shafiei Bafti, S. (2010). Mediodactylus russowii. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.2. [Online]. Available at www.iucnredlist.org. (Accessed 28 May 2014).

Bekenov, A., Grachevande, A. and Milner-Gulland, J. (1998). The ecology and management of the Saiga antelope in Kazakhstan. Mammal Rev, Volume 28, No 1, p. 1-52.

BirdLife International (2012). Melanocorypha yeltoniensis. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.2. [Online]. Available at www.iucnredlist.org. (Accessed: 29 May 2014).






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BirdLife International (2013). Otis tarda. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.2. [Online]. Available at www.iucnredlist.org. (Accessed: 29 May 2014).

Chelintsev, N.G. (1985). Methods of inspecting fauna in routes // Ecology and fauna conservation. Pages 74-81.Chemonics International Inc. (2001). Biodiversity Assessment for Kazakhstan. Task order under the biodiversity & sustainable forestry IQC (BIOFOR). Submitted to USAID Central Asian Republics Mission, Kazakhstan. June, 2011.

CMS (Convention on Migratory Species) (2011a). A review of current knowledge of bird flyways. Principal knowledge gaps and conservation priorities. UNEP/CMS/ScC17/Inf.4.2b.

CMS (Convention on Migratory Species) (2011b). Guidelines for mitigating conflict between migratory birds and electricity power grids. Convention on Migratory Species, UNEP. Available at http://www.cms.int/bodies/COP/cop10/docs_and_inf_docs/doc_30_electrocution_guidlines_e.pdf.

CBD (Convention on Biological Diversity) (2014). Kazakhstan – Country Profile. [online] Available at http://www.cbd.int/countries/profile/default.shtml?country=kz [Accessed: 22 May 2014]

EBRD (2008). Environmental and Social Policy. European Bank for Reconstruction and Development.

Fenyuk B.K., Pastukhov B.N., Semenov N.M. (1963). Organization and methodical principles of inspecting the number of rodents by anti-plague institutions // Organization and methods of inspecting birds and rodents. Published by AN USSR, Pages 152 -158.

Gryunberg, V.V. (2014). Field report on surveying fauna in the territory of Special Economic Zone "National Industrial Petrochemical Technology Park” and near the site at which Integrated Petrochemical Complex Kazakhstan Petrochemical Industries Project is constructed.

Huff, J. (2007). Benzene-induced cancers: abridged history and occupational health impact. International Journal of Occupational Environmental Health 13 (2): 213-21.

IEEM (2006). Guidelines for Ecological Impact Assessment. Institute of Ecology and Environmental Management. www.ieem.net.

IFC (2012a). Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. International Finance Corporation, World Bank Group.

IFC (2012b). Guidance Note 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. International Finance Corporation, World Bank Group.

IFC (International Finance Corporation) (2007). Environmental, Health and Safety Guidelines. Available http://www1.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/IFC%20Sustainability/SiteMap (Accessed 26 May 2014). Relevant Guidelines: Environmental, Health and Safety General Guidelines


http://www.cms.int/bodies/COP/cop10/docs_and_inf_docs/doc_30_electrocution_guidlines_e.pdf

http://www.ieem.net/



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Environmental, Health and Safety Guidelines: Construction and Decommissioning Environmental, Health and Safety Guidelines for Natural Gas Processing Environmental, Health and Safety Guidelines for Petroleum-based Polymers Manufacturing Environmental, Health and Safety Guidelines for Large Volume Petroleum-based Organic Chemicals

Manufacturing

IFC (IFC 2008). Environmental, Health, and Safety Guidelines for Thermal Power Plants. International Finance Corporation, World Bank Group.

IPIECA & OGP (2010). Alien invasive species and the oil and gas industry. Guidance for prevention and management. OGP Report Number 436. Available at <http://www.ipieca.org/sites/default/files/publications/alien_invasive_species.pdf>[Accessed 7/05/2014].

IPIECA (2011). Ecosystem Services Guidance: Biodiversity and Ecosystem Services Guide and Checklist. IPIECA & OGP, London.

IUCN (2013). IUCN Red List of threatened species. Version 2013.2. <http://www.iucnredlist.org> Accessed 8/05/2014. International Union for Conservation of Nature and Natural Resources.

Mirkin, B.M., Rosenberg, G.S. (1978). Phytoecology. Principles and Methods. Nauka.

Mott MacDonald (2014). Kazakhstan Petrochemical Industries. Flora and Vegetation.

Novikov G.A. (1949). Field studies of ecology of terrestrial vertebrates. Soviet Science.

Shar, S., Lkhagvasuren, D. and Molur, S. (2008). Rhombomys opimus. In In: IUCN 2014. IUCN Red List of Threatened Species. Version 2014.1. <www.iucnredlist.org>. Downloaded on 23 June 2014.

Tetrakon Engineering (2013). Integrated petrochemical complex in Atyrau region. EIA Report. Report prepared for Kazakhstan Petrochemical Industries Inc.

Tikhonov, A., Cavallini, P., Maran, T., Krantz, A., Herrero, J., Giannatos, G., Stubbe, M., Conroy, J., Kryštufek, B., Abramov, A. & Wozencraft, C. (2008). Vormela peregusna. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.2. <www.iucnredlist.org>. Downloaded on 29 May 2014.

Tsytsulina, K. (2008). Pygeretmus platyurus. In: IUCN 2014. IUCN Red List of Threatened Species. Version 2014.1. <www.iucnredlist.org>. Downloaded on 13 June 2014.

Vasylevich, V.I. (1971). Methods of identification of vegetation associations.






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12.1 Introduction

This section outlines the proposed approach for the management of the key solid waste streams predicted to arise during the construction, operation and decommissioning phases of the Project.

Waste management is a key aspect to be assessed by the Project in order to achieve minimisation of raw material consumption, maximise opportunities for waste reuse and recycling and ensure that any final treatment or disposal of wastes generated by the Project is conducted in an environmentally sound manner, particularly for hazardous wastes.

The scope of this chapter is limited to the assessment of all solid wastes and to those liquid wastes that are not treated via the wastewater treatment plant (refer to Section 10 for discussion in relation to the wastewater treatment plant).


12.2.1 Waste Management Legislation and Policy in Republic of Kazakhstan

The main waste management principles of the Republic of Kazakhstan are described in Environmental Code Chapter 42 “Environmental requirements on industrial and domestic waste management”. However,

there are also a number of additional key legal requirement, which have been identified below: “Methodology on the determination of the standard emissions to the environment” approved by Order

No. 379-O of the RK Minister of Environment dated December 11, 2013. It determines standard rules for calculation of emissions to atmosphere, water and limits for waste disposal

“List of pollution substances and waste types for which emission standards are applied” approved by

RK Government Decree No 557 dated June 30, 2007 RND 03.1.0.3.01-96 “Guidelines on the standardisation of industrial waste generation and disposal” RND 03.3.0.4.01-96 “Methodology on the definition of the components of pollution by toxic substances

and waste consumption” “Waste classification code” approved by the Order No. 169-P of the RK Minister of Environmental

dated May 31, 2007 SanPiN “Sanitary requirements for industrial and domestic waste collection, use, application,

processing, transportation, storage and disposal” approved by the RK Government Decree No.291 dated March 6, 2012

GOST 30774-2001 Standard on "Resource saving. Waste management. Hazardous waste certificate. General requirements"

Order 164-P of the RK Minister of Environment “On the establishment of the standard report form for the hazardous waste and guideline for its completion” rule for natural and legal persons of draft

standards for the treatment of waste” dated May 21, 2012

Under the above mentioned Environmental Code (Chapter 6, Article 287) and Waste classification code, according to the Basel convention and for the purpose of transportation, storage or disposal of hazardous waste can be classified as follows:

12 Waste and Materials Handling



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Green – index G Amber – index A Red – index R

Under the above mentioned SanPiN all industrial wastes are classified the basis of their negative impact on the environment in a following way: Class I – extremely hazardous waste Class II – highly hazardous waste Class III – moderately hazardous waste Class IV – low-hazardous waste.


12.2.2.1 IFC Performance Standards

As discussed in Chapter 4, PS3 on Pollution Prevention and Abatement requires reference to be made to relevant EHS Guidelines; these are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP). The following IFC EHS Guidelines contain relevant information related to waste management for the Project: General EHS guidelines (2007) Petroleum-based Polymers Manufacturing (April 2007) Large Volume Petroleum-based Organic Chemicals Manufacturing (April 2007)

The IFC EHS Guidelines for Petroleum-based Polymers Manufacturing state that the storage and handling of hazardous and non-hazardous wastes should be conducted in a way consistent with good EHS practice for waste management, as described in the General EHS Guideline. Industry-specific hazardous wastes include waste solvents and waste oil, spent catalysts, saturated filtering beds, and solid polymer wastes from polymerization plants.

These guidelines have been used to frame the waste management approach for the Project and assess the Project’s ability to meet Good International Industry Practice (GIIP).

12.2.2.2 EBRD Performance Requirements

EBRD PR3 on Pollution Prevention and Abatement requires the avoidance or minimisation of hazardous and non-hazardous waste materials and to reduce its harmfulness as far as practicable (clause 12 and 13).

The EBRD are committed to promoting European Union environmental requirements. The main European measure in relation to waste is Directive 2008/98/EC. Under the Directive; EU Member States must work towards encouraging the prevention or reduction of waste and its harmfulness, through the development of clean technologies, product improvements and disposal techniques. The recovery of waste is also encouraged, as is the prohibition of uncontrolled dumping.



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The Waste Directive sets out measures to minimise the negative effects of the generation and management of waste on human health and the environment and aims to reduce the use of resources through the development of a waste policy.

Directive 91/689/EEC on hazardous waste, lists wastes which can be classified as hazardous and requires EU Member States to publish a hazardous waste management plan, in accordance with the guidelines set out in Directive 2008/98/EC.

All waste delivery sites (hazardous and non-hazardous) must also be identified and registered and relevant labeling standards adhered to when such waste is collected, transported and stored.

12.2.2.3 European Waste Catalogue

The European Waste Catalogue (EWC) classifies waste materials and categorises them according to what they are and how they were produced and it is referred to in a number of European Union Directives and Commission decisions regarding waste management. Reference is made to this when describing the appropriate handling and storage methods.


12.3.1 Overview

The assessment of impacts from waste generation has been conducted on the basis of a desk-based review of Project information provided by the Project parties. Where appropriate the assessment also builds on the information provided in the National OVOS.

12.3.2 Site Visit

The ESIA Project Team conducted a scoping site visit to the IPC in April 2014. During this time the proposed waste management practices that will be adopted for the Project were discussed.

12.3.3 Spatial Scope

In terms of considering the consumption of raw materials (including receipt, handling and storage) and subsequent management and disposal of waste, the spatial scope of the Project encompasses the proposed Project site. Any other waste transferred and disposed offsite will be done so by licensed contractors.

12.3.4 Temporal Scope

The temporal scope covers the potential impacts related to the consumption of raw materials (including receipt, handling and storage) and subsequent management and disposal of waste arising from the construction, operation and decommissioning phases of the Project.



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12.3.5 Assessment of Impact Significance

An assessment of the significance of impacts with regards to the waste generated by the Project has been made for the construction, operational and decommissioning phases. The significance of potential impacts is a function of the presence and sensitivity of receptors and the magnitude of the impact in terms of duration, spatial extent, reversibility and likelihood of occurrence.

The assessment follows the standard assessment structure outlined in Chapter 5.


12.4.1 National Overview

Kazakhstan generates huge volumes of waste each year. In 2008, 457 million tonnes (29 tonnes per capita) of waste was generated; the EU generated 2,612 millions of tonnes waste in 2008 (5.2 tonnes of waste per capita).46 There has been a significant increase in wastes being produced, the majority of which is from the mining industry, quarry development and process industry.

Recycling and reuse rates in Kazakhstan are also extremely low. It is estimated that the percentage of waste that goes through the recycling process does not exceed 5% of total waste.47 Additionally, according to the Ministry of Environmental and Water Resources, the majority of the waste going to landfill goes without separation or disinfection; therefore, many landfills in Kazakhstan do not meet necessary sanitary requirements and often require land remediation.

The Government of the Republic of Kazakhstan has therefore developed a “Programme on modernisation

of domestic waste management system until 2050”. This system is based on the six goals which are to: Increase the population percentage that has access to domestic waste services, removing up to 90%

of waste by 2020, and up to 100% by 2035. Increase the percentage of biological waste collection from 10% to 80% by 2050 Increase separate collection of packaging waste from 10% in 2020 to 80% in 2050. Implement a system of collection and disposal of hazardous domestic waste and increase its

separation rate from 35% in 2020 to 80% in 2050. Increase the percentage of sanitary landfills up to 100% by 2050, with a milestone of 50% of sanitary

landfills in 2020. Increase the green power generated from waste for heat and electricity uses.

12.4.2 Regional Overview

In recent years, there has been a steady increase in the volume of waste produced in the Region. Historically the Region has accumulated huge amounts of industrial wastes, a considerable part of which is 46 UNECE statistics 47 Statistics Agency of the Republic of Kazakhstan, http://www.stat.gov.kz/



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toxic and radioactive; however, there have been growing volumes of municipal solid wastes as a result of a growing number of industries focused towards upstream oil and gas, and due to an inward migration of people from the urban areas in to the city in search of work. This has put pressure on the region in terms of processing and storing municipal and commercial and industrial (C&I) waste.

There has been an absence of sufficient and suitable infrastructure for the collection and removal waste, which is one of the primary causes of dumps in populated city areas. Moreover, some of the current landfill sites and dumps for solid wastes do not meet the required regulatory criteria resulting in soil contamination and fires.


12.5.1 Overview

Wastes will be generated during both the construction and operation phases and at the eventual decommissioning of the Project for which an appropriate waste management, mitigation and disposal plan will need to be established. The likely waste types from both the construction and operational phases of the Project include solid, liquid, hazardous, non-hazardous and inert wastes.

The principle potential impacts which can arise from the generation of waste from the Project are as follows: Contamination of the environment, groundwater and the ground due to leakage and spillage of wastes

and during the wetter months surface water bodies. In all cases these would all be associated with poor waste handling and storage arrangements;

Fugitive emissions, such as dust, associated with the handling and storage of some waste streams The over use of landfill facilities, which are typically a finite resource; Occupational health and safety; Fire and explosion due to reactive, flammable and explosive materials; Visual impacts normally associated with poor storage of waste; and Increased waste miles from transporting waste materials from the Project to its final disposal location.

Potential hazardous waste types generated during construction and operational phases across the Project may include: oils and solvents waste, polluted polypropylene packages, wiping material, lubricants, contaminated ground (potentially from leakage and spillage), waste catalysts and polymers. Management of these hazardous wastes will require particular consideration, particularly any final treatment or disposal options.

The following sections will discuss the potential environmental impact, and proposed handling / storage and disposal methods for each of the waste streams that may arise during the three stages of the Project.



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12.5.2 Construction

This section aims to characterise the raw materials to be consumed and the waste streams which can arise from construction activities associated with the development of the Project.

12.5.2.1 Material Use

Materials used during construction will principally comprise the items of equipment for the Project, as well as materials used for site preparation such as rods for piling and buildings, concrete for foundations and auxiliary structures, steel for buildings, materials for fitting out the interiors of buildings etc.

Smaller quantities of other materials will be used throughout construction. Mitigation proposed to minimise the use of materials is discussed in Section 12.7.

12.5.2.2 Waste Generation

The environmental impacts of generated wastes associated with the construction phase of the Project will be short term and mostly reversible for aspects such as fugitive emissions to air, noise, ground contamination and visual disturbance. These potential impacts will be effectively managed through the establishment of detailed waste management plans in line with the framework waste management plan outlined in the ESMP (Volume IV). The specific details of such waste management plans will be prepared by the construction contractor, the key elements of which are summarised in Section 12.7.2.

Table 12.1 summarises waste streams that are expected to be generated as part of the construction phase of the Project as well as their potential impacts, how they will be handled/stored and the method of disposal for each waste stream.

At this stage there are still discussions taking place about the possibility of constructing a landfill either within the IPC or very close to it. This would be solely for waste generated from activities within the IPC and would be constructed in accordance with national regulations. However in the event that this does not take place KPI have had discussions with two existing waste contractors who have their own landfills which are not related to the waste landfills within Atyrau and meet appropriate national design and operational specifications. Both of these contractors work within the oil and gas industry and are familiar with handling the types of waste streams that this Project will generate. On this basis it is considered that the proposed options for disposing of Project waste are acceptable.

Table 12.1: Construction Wastes: Potential impact, proposed handling / storage and offsite disposal methods

Waste Type Potential Impact Handling / Storage Method Disposal Method

Non-hazardous Construction Wastes

Excavation spoil

Contamination of environments.

Fugitive dust emissions.

Disposal of spoil and excavation material which results in land take.

Temporary storage on the site for further use on site or removal.

Excess waste will be disposed of in spoil disposal sites or, where appropriate, used to level off the site.

Spoil disposal site. Collection by carrier.



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Concrete waste

Fugitive dust emissions.

Disposal to landfill, where waste re-use or recovery is not feasible.

Increased waste miles from transporting waste materials from the Project site.

Segregated according to the Republic of Kazakhstan’s SanPiN Waste Classification or further reference will be made to European Waste Catalogue (EWC) and suitably stored on a temporary basis in a waste management area.

Using it in other work locations or returning unused cement to the vendor can minimise the volume of waste.

Waste concrete can be crushed and used as road material or fill, or where possible, buried in a local landfill site. Soils contaminated by cement can also be used as landfill cover.

If surplus quantities for the above are present collection and disposal by licensed carrier for recovery and re-use.

Concrete wastewater

Contamination of receiving environments.

Wash water which cannot be immediately reused is to be stored in an open lined pit or open tanks so as to aid sedimentation or other on-site treatment as appropriate.

Concrete wash water to be reused on site wherever possible.

On site concrete batching should include wash water recirculation.

Remaining wash water to be stored and allowed to evaporate.

Any remaining wash water to be fully treated (fine solids removed by filtration or settlement and pH corrected to 6-9) before being discharged to any surface water only if properly permitted (i.e. not to bare ground).

Cement Contamination of receiving environments.

Segregated according to the Republic of Kazakhstan’s SanPiN Waste Classification and suitably stored on a temporary basis in a waste management area.

Cement slurry will be left to dry out.

Collected by competent carrier for recovery and re-use.

Iron and steel scrap

The use of landfill, where waste re-use or recovery is not feasible.

Visual amenity impacts associated with poor storage of waste.



Collected by competent carrier for recycling.

Scrap metal will be sold for recycling, as appropriate.

Non-ferrous scrap



Increased waste miles from


Collected by competent carrier for recycling.



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Waste Type Potential Impact Handling / Storage Method Disposal Method transporting waste materials from the Project site.

Bricks and tiles



Re-use. Surplus material should be retained on site.

Packaging The use of landfill, where waste re-use or recovery is not feasible.




Collected by a carrier for recycling.

Pallets that have been used during transport or for storage




Collected by a carrier for recovery and re-use.

Glass The use of landfill, where waste re-use or recovery is not feasible.




Paper and cardboard






Timber The use of landfill, where waste re-use or recovery is not feasible


Collected by a carrier for recycling if reasonable achievable.

All waste timber generated on site will be sold if possible, if not recycled.

Other Non-Hazardous Wastes

Domestic waste


Segregated according to the Republic of Kazakhstan’s SanPiN Waste Classification or further

Collected in covered containers and sent to licensed local disposal site.



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reference will be made to European Waste Catalogue (EWC) and suitably stored on a temporary basis in a waste management area.

Plastics The use of landfill, where waste re-use or recovery is not feasible.





Drums, barrels and containers from non-hazardous materials





Drums, barrels are collected by a carrier for recycling.

Hazardous Wastes

Oils and lubricants

Hazardous.



Collected on a temporary basis in bunded, segregated marked drums within a waste management area.

Recovery and re-use options to be fully explored. Collected by a carrier. Where recovery and re-use is not feasible handling to a carrier.

Oil contaminated wiping cloths

Hazardous.



Segregated according to the Republic of Kazakhstan’s Environmental Code (Chapter 6, Article 287) on hazardous waste, the SanPiN Waste Classification or where appropriate further reference will be made to European Waste Catalogue (EWC) and suitably stored on a temporary basis in a waste management area.

Collected by competent carrier to be disposed of in a licensed facility.

Batteries Hazardous.




Recycling options to be fully explored. Collected and disposed or recycled by a carrier. Where recycling is not feasible then handling to a licensed carrier.

Fluorescent Hazardous. Segregated according to the Collected and disposed by a



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Waste Type Potential Impact Handling / Storage Method Disposal Method tubes Contamination of environments

The use of landfill, where waste re-use or recovery is not feasible

Republic of Kazakhstan’s Environmental Code (Chapter 6, Article 287) on hazardous waste, the SanPiN Waste Classification or where appropriate further reference will be made to European Waste Catalogue (EWC) and suitably stored on a temporary basis in a waste management area.

licenced carrier.

Mercury lamps Hazardous.


Collected in bunded, segregated container and suitably stored on a temporary basis within a waste management area.

Sent to licensed mercury disposal facility.

Waste enamel and reagents

Hazardous.



Collected in bunded, segregated drums and suitably stored on a temporary basis within a waste management area.

Recovery and re-use options to be fully explored. Collected by a licenced carrier. Where recovery and re-use is not feasible then disposal in a licensed facility.

Used solvents Hazardous.


Collected in bunded, segregated drums and suitably stored on a temporary basis within a waste management area.

Reuse solvents as far as possible or returning them to the supplier. All remaining solvents will be incinerated.

Tyres The use of landfill, where waste re-use or recovery is not feasible.




Collected by a carrier for recycling or disposal.

12.5.3 Operation

12.5.3.1 Overview

One of the key environmental issues within the petrochemical sector is the generation of a relatively large quantity of spent solvents and non-recyclable waste. Within the Project these unavoidable waste streams will be treated in recovery and / or abatement systems, recycled where possible, sold to external users or in the last resort will be disposed of as waste.

Hazardous wastes generated through the operations are expected to include spent chemicals, catalysts, adsorbents and waste oils / diesel. Packaging from the delivery of products will also be generated.

Guidance on managing wastes streams in the polymer sector is provided in the IFC EHS Guidelines for Petroleum-based Polymers Manufacturing (April 2007). Another source of industry best practice is



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provided in the EU Reference Document on Best Available Techniques (BAT) in the Production of Polymers (August 2007).

12.5.3.2 Material Use

Materials considered to be of a hazardous nature will require bespoke consideration, particularly for any final treatment and disposal options. Some materials will have a known consumption and storage volume whereas the consumption and volume of other materials will be dependent on routine maintenance and outage activities therefore it is difficult to give exact volumes for all materials.

The following set of tables present the key materials and feedstocks required for the Project, as well as the main materials consumed during the operation of associated infrastructure.

Table 12.2: Key Materials and Feedstocks used for the Operation of the Project

Material Activity Hazardous / Non-hazardous Storage

General Materials

Propane Primary fuel Hazardous Direct supply from regional network

Production Chemicals Production process Hazardous These will be stored in warehouses within the Project extent

Paints, oils and fuels, lubricants, cleaners, solvents

Maintenance and outage activities

Hazardous Minimal but will be stored in a secure, bunded and covered designated storage area

Fluorescent tubes


Hazardous Minimal

Batteries


Hazardous Minimal

Propane Dehydrogenation (PDH) Plant

Propane Feedstock Hazardous Propane to be stored in four propane bullets.

The storage area will be located away from the process units.

Recycled Polypropylene Feedstock Hazardous Recycled Polypropylene will be stored in intermediate storage tanks. Storage tanks will be fully bunded and connected to the low pressure flare system to catch all fugitive emissions.

CATOFIN Reactor Catalyst

Process Hazardous CATOFIN Reactor Catalysts to be stored in 1 ton bags in the chemical storage warehouse

CATOFIN Reactor Inert Material

Process Non Hazardous CATOFIN Reactor Inert Material to be stored in 2 ton bags in the chemical storage warehouse

Molecular Sieve/ Adsorbents & Supports

Process Hazardous Molecular Sieve/Adsorbents & supports to be stored in 150kg drums in the chemical storage warehouse

Other Catalyst Process Hazardous Stored in the chemical storage warehouse

Chemicals ) Process Hazardous Stored in the chemical storage warehouse or in storage area.

Methanol Process Hazardous Stored in the chemical storage warehouse



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Material Activity Hazardous / Non-hazardous Storage

Polypropylene (PP) Plant

Propylene Feedstock Hazardous Propylene will be pumped directly from the PDH plant and the propylene storage area.

Hydrogen Feedstock Hazardous Hydrogen will be transferred from the intermediate storage tanks or directly from the PDH plant

Catalyst: PTK Process Hazardous The catalyst will be stored in 70 kg drums in the chemical storage warehouse.

Propylene Dryer Molecular Sieve

Process Hazardous Stored in 150 kg Drums in the chemical storage warehouse

Propylene Dryer Molecular Sieve Support Balls

Process Hazardous Stored in 150 kg Drums in the chemical storage warehouse

Triethylaluminium (TEA) co-catalyst

Process Hazardous TEA will be stored in containers in an outdoor covered shed

Silane Process Hazardous Silane will be stored in in 180 kg drums in the chemical storage warehouse

Isopropanol (IPA) Process Hazardous IPA will be stored in 150 kg drums in the chemical storage warehouse

Peroxides Process Hazardous Stored 20L plastic drums in the chemical storage warehouse

White Oil Process Hazardous Stored in 200L drums in the chemical storage warehouse

Each of the materials and chemicals used during operation of the Project has specific materials handling and storage specifications outlined within their safety data sheets. This includes minimum and maximum storage temperatures and humidity specifications.

All catalyst will be stored in a dry weather protected area and the flooring will be bunded to contain any spillages and equipped with a drain to the local catalyst bund to enable any final trace spillages to be washed out after initial dry cleaning method. Specific handling methods for catalysts will also be put in place to minimise the risk of spillage.

Triethylaluminium (TEA) is a metalo-organic compound that is used as co-catalyst in the polymerization process of propene. It is extremely flammable; when it comes in to contact with air it ignites spontaneously and when it comes into contact with water it releases extremely flammable gases. TEA will therefore be stored securely in transport containers in an outdoor covered shed.

Table 12.3: Key Materials for the Operation of the Associated Infrastructure

Material Activity Hazardous /

Non-hazardous Storage

Product Handling Unit (PHU)

FFS (Form Fill Seal) Rolls Process Non-hazardous Rolls Stored in the PHU Warehouse

Pallets Process Non-hazardous Stored in the PHU Warehouse



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Material Activity Hazardous /

Non-hazardous Storage

Shrink Hood (For covering Stack of bagged pellets - shrink wrap)

Process Non-hazardous Rolls Stored in the PHU Warehouse

Slip Sheets (fits on Pallet under first row of bags or between pallets)

Process Non-hazardous Stored in cardboard boxes in the PHU Warehouse

Water Systems and Water Treatment

Oxidant/Germicide Process Hazardous Stored in the chemical storage warehouse

Sulphuric Acid Process Hazardous Stored in the chemical storage warehouse

Resins Process Hazardous Stored in 25kg barrels in the chemical storage warehouse

Scale and Corrosion Inhibitors

Process Hazardous Stored in 50kg drums in the chemical storage warehouse

Sulphuric Acid Hazardous Stored in the Waste Water Treatment Unit

Caustic (NaOH) Hazardous Weekly quantities should be stored locally in Waste Water Treatment Unit. The rest will be stored in the chemical storage warehouse

Power Plant

Ammonia Process Hazardous Stored in the chemical storage warehouse

Dimethyl Ketoxime Process Hazardous Stored in the chemical storage warehouse

Sodium Phosphate Process Hazardous Stored in the chemical storage warehouse

Lube Oil Process Hazardous Stored in the chemical storage warehouse

12.5.3.3 Storage of Generated Products

The PP Plants will generate large quantities of polypropylene pellets. The polypropylene handling unit (PHU) will pack polypropylene product pellets into bags and bulk as follows: PP Bags

– 25 kg per bag; – 55 bags per pallet; – 75 T/h (3000 bags, 55 pallets).

PP “Big bag” – 1000 kg per bag; – 30 T/h (30 Big bags).

PP Iso-container – 12 m size, 24.75 T PP; – 100 T/h (4 Iso-containers).

After palletizing and film covering, the pallets with PP product are transported by an electric forklift truck to enclosed warehouse for storage. The warehouse is split by forklift truck accesses into several stockpiling zones, each zone will stock pile two levels of product, each level has 16x20 pallets, and the total capacity is 880 tonnes. The maximal stockpiling capacity inside enclosed warehouse is 24,640 tonnes, equivalent to normal production capacity of 16 days for PP unit. In addition, there is an open container stockyard,



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located at the south of warehouse. The majority of packed product shall be kept in containers stockpiled outdoors.

12.5.3.4 Waste Generation

Waste streams that will arise from the operation of the Project will require adequate use, handling, storage and disposal procedures to ensure adverse environmental impacts are kept to a minimum and to comply with national regulations and international standards. Hazardous wastes generated through the operations are expected to include spent chemicals, catalysts, adsorbents and waste oils/diesel. Table 12.4 below presents the expected sources of each waste stream, the potential environmental impact which could occur and its significance, along with the expected disposal / final removal method.



Table 12.4: Overview of the operational phase waste handling strategy for the Project

Waste Source Potential environmental Impact Mitigation and Disposal method

Generic Waste associated with Plant Operations

General waste All activities Potential contamination of environment.

Visual amenity impacts.

Use of finite landfill resource.

Placed in a segregated central waste storage area within the Project boundary before being dispatched for re-use, recycling or disposal.

Paper and Cardboard From packaging and deliveries etc

Potential contamination of receiving environment.



Plastic From packaging and deliveries etc




Glass Maintenance, deliveries, workers facilities


Recycling potential.


Scrap metal Associated with outages and maintenance



Recycling potential.


Pallets Associated with deliveries




Solvent wastes Process units Hazardous.


Stored in appropriate containers and sent to central storage area before being collected and disposed of by licensed carrier.

Waste Electronics and Electrical Equipment (WEEE) – Non- hazardous

Maintenance and replacement of electrical equipment

Non Hazardous

Recycling opportunities

Waste is to be segregated into ferrous and non-ferrous metals and will be dispatched to facilities for reuse. Non-ferrous metals can be recycled by companies that produce electrical transformers and electrical batteries.

Maintenance oils Associated with routine and on-going maintenance in the facility and outages

Hazardous

Potential contamination of receiving environment

Opportunities to reuse where possible will be explored. Waste will be incinerated when not possible.




Contaminated packaging Primarily associated with any chemical deliveries

Hazardous

Unknown contaminants and potential contamination of receiving environments

Use of finite landfill resource

Initially to be placed in the hazardous waste storage and disposed of by licensed contractors.

Oily contaminated materials, such as oily rags

Associated with routine and on-going maintenance in the facility and outages

Hazardous


Initially to be placed in the hazardous waste storage and disposed of by licensed contractors.

Lubricating and auxiliary oils

Associated with routine and on-going maintenance in the facility

Hazardous


Recovery and re-use options to be fully explored. Collected by a licensed carrier. Where recovery and re-use is not feasible then disposal in a licensed facility.

Where this is not possible waste will be incinerated

Waste collected as a result of spills, leakages and/or accidental damage

Associated with routine and on-going maintenance in the facility and outages

Hazardous


Stored in appropriate containers at the waste storage area before being collected and disposed of by a licenced contractor.

Waste Associated the PDH / PP Plant

Catalyst

(Spent CATOFIN catalyst)

Process Units Hazardous


All catalysts will be neutralised and transferred to the hazardous waste area at the waste storage area prior to being collected by specialist licensed companies and either recycled or disposed of at a licensed facility.

The spent catalyst which cannot be recovered will be sent to offsite landfill as industrial waste.

Reactor Inert Material

PDH reactors Non Hazardous

Recovery and re-use options to be fully explored. Where this is not possible waste will be se t to landfill in accordance with local regulations

Alumina Balls Process Units Hazardous Recovery and re-use options to be fully explored. Where this is not possible waste will be se t to landfill in accordance with local regulations

Molecular sieve & Adsorbents Process Unit Hazardous Recovery and re-use options to be fully explored. Where this is not possible waste will be se t to landfill in accordance with local regulations

Adsorbent Hazardous Recovery and re-use options to be fully explored. Where this is not possible waste will be se t to landfill in accordance with local regulations

Heavy Hydrocarbons Sour Water Stripper Collection

Drum

Hazardous


Stored in appropriate drums and collected and disposed of by a licenced contractor. Offsite incineration likely

Hydraulic oil Hazardous


Stored in appropriate drums and collected and disposed of by a licenced contractor. Offsite incineration likely.




White Oil Hazardous


Stored in appropriate drums and collected and disposed of by a licenced contractor. Offsite incineration or reuse for fuel where possible.

Empty Drums Various Hazardous


Collected and reused by supplier.

Polymer powder/stabilizers, polymer wastes

Various Hazardous


Stored in appropriate containers. Recovered polymer materials may be sold as off-specification product. Where recovery and re-use is not feasible then disposal in a licensed facility

Oligomers Carrier Gas Cooler Hazardous


Stored in appropriate drums and collected and disposed of by a licenced contractor. Offsite incineration or reuse for fuel where possible.

Waste from the Associated Facilities

Sludge from raw water treatment

plant

Water Treatment Unit Hazardous


Collected and disposed of by a licenced contractor

Surplus activated sludge from

wastewater treatment plant

Waste Water Treatment Plant

Collected and disposed of by a licenced contractor

Empty drums Various Hazardous


Collected and reused by supplier.

Spent Resin Power Plant Hazardous Collected and disposed of by a licenced contractor

Sludge from boiler feed water unit

Power Plant Hazardous Collected and disposed of by a licenced contractor



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12.5.3.5 Decommissioning Waste Streams

The Best Available Technique (BAT) Reference Document (BREF) on for the Production of Polymers (August 2007) provides the following design considerations for waste management during decommissioning: Integrating consideration of the environmental impact from the eventual decommissioning of the unit at

the design stage, thereby allowing for an easier, cleaner and cheaper decommissioning process; Adopting preventive techniques for the generation of large quantities of solid waste, including:

– avoiding underground structures; – incorporating features that facilitate dismantling; – choosing surface finishes that are easily decontaminated; – using an equipment configuration that minimises trapped chemicals and facilitates drain-down or

washing; – designing flexible, self-contained units that enable phased closure; and – using biodegradable and recyclable materials where possible.

KPI will employ all these approaches where possible and will continuously review waste disposal to identify more environmentally acceptable routes in accordance with BAT and the IFC General EHS Guidelines. Prior to the eventual decommissioning of the project, a Decommissioning Environmental Management Plan (DEMP) will be prepared detailing the best practice approach that will be adopted. The DEMP will include a section on waste management.

12.5.4 Impact Significance

The proposed Project will be operated under best practice methods for storing and disposing of materials and waste. Table 12.5 provides a summary of the impact significance associated with material handling and waste management.

Table 12.5: Summary Impact Significance

Activity Potential Impact Sensitivity Magnitude Impact Significance

Construction

Waste generation, handling and storage

Contamination of environments (particularly surface watercourses, groundwater and the ground) due to leakage and spillage of wastes associated with poor waste handling and storage arrangements

Low Moderate Minor

Fugitive emissions, such as dust, associated with the handling and storage of some waste streams

Low Moderate Minor

Visual amenity impacts associated with poor storage of waste

Low Minor Insignificant



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Activity Potential Impact Sensitivity Magnitude Impact Significance

Choice of final waste disposal option

The use of landfill, which is a finite resource

Low Moderate Minor


Low Moderate Minor

Operation

Waste generation, handling and storage

Contamination of receiving environments due to leakage and spillage of waste streams from the operation of the project

Low Moderate Minor

Fugitive emissions associated with the handling and storage of operational waste streams

Low Moderate Minor


The use of landfill, which is a finite resource

Low Minor Minor


Low Moderate Minor


Additional waste will also be generated from the other projects located within the IPC. To meet national requirements these will have to store, handle and dispose of waste in the same way as proposed for the Project.

The operation of the whole IPC will increase the amount of waste that is being recycled and disposed of but it is expected that the same methods of disposal as described within this chapter would also be used for the rest of the IPC. As a result it is not expected that any additional cumulative effects would be experienced as a result of the operation of the IPC.


12.7.1 General Requirements

KPI will investigate the suitability of a regional landfill sites in order to determine sites that are designed and operated in accordance with national requirements so that waste from the Project is disposed of in an acceptable manner.

The IFC General EHS Guidelines require all waste material arisings (regardless of the stage of the Project) to be segregated into non-hazardous and hazardous wastes for consideration for re-use, recycling, or disposal. Moreover, the Project should also give due consideration to the IFC EHS General Guidelines, for which the requirements related to waste management are as follows; General waste management:



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– Waste management planning: identify and characterise the source of all waste streams from the Project with the proposed final disposal option;

– Waste Prevention: identify opportunities to prevent waste production in the first instance; – Recycling and reuse: waste reuse and recycling opportunities to be identified. Investigations into

suitable facilities that can process such waste streams to be explored; and – Treatment and disposal: where re-use of recycling is not feasible or possible, appropriate treatment

and/or final disposal options are to be identified for all waste streams. Hazardous waste management:

– Waste storage: temporary waste storage to be fully identified and designed according to industry best practice;

– Transportation: all waste containers designated for off-site shipment to be secured and appropriately labelled with loading overseen by competent and trained KPI employees;

– Treatment and disposal: where re-use of recycling is not feasible or possible, appropriate treatment and/or final disposal options to be identified for all waste streams, including those considered to be hazardous; and

– Monitoring: procedures for waste tracking to be developed. In addition, there should be routine audits of internal waste management practices to ensure on-going compliance throughout the life of the Project. Any recommendations for improvements in the waste management practices of the Project will form part of on-going operational reporting.

12.7.2 Construction and Operational Waste Management Plans

For all construction activities associated with the Project, a waste management plan will be produced as part of the CEMP prepared by the construction contractor. A framework for the waste management plan has been provided in the ESMP (volume IV) of this ESIA. The final waste management plan will identify likely waste arisings, appropriate handling, reuse and recycle opportunities and, as a last resort, disposal methods. The waste management plan will be prepared in accordance with national regulations.

For the operational phase of the Project, the production of a detailed waste management procedure, within the framework provided, will be fundamental to ensure waste management best practice is undertaken and becomes embedded into the operational procedures of KPI. The waste management procedure will provide the following; Highlight relevant international, national and regional policy and legislation; A Site Waste Management Plan (SWMP) which will contain:

– A map showing each temporary waste storage location for the Project and within the Project area; – A description of each waste generated by the operation of the Project, its classification, the

appropriate handling methodology, the correct approach for temporary storage and the correct route for removal/disposal off site;

– Waste generation data collection for each waste stream by volume. This should include the proportion of each waste stream going for reuse, recycling or disposal. In case of unusual waste volumes, this should be investigated;

– Any waste monitoring as deemed to be necessary;



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– An audit schedule which details the frequency of waste management audits and those responsible for undertaking them;

– A section related to continuous improvement and corrective actions where audit findings can be recorded and incorporated into the waste management procedure. This will also highlight any new and feasible reuse or recycling opportunities which may arise over time;

– A mechanism by which to routinely track waste consignments from the originating location to the final waste treatment and disposal location;

– The correct procedure for reporting any environmental incidents related to waste; and – The specific regulatory reporting requirements as they relate to waste.

12.7.3 Materials Storage, Handling and Use

Material and waste handling and storage areas will be established within the Project site during the construction phase and, where appropriate, these will be retained for the operational phase. These will be specifically designed giving due consideration to the following requirements and will be used before waste materials are transferred to the central waste storage area: Separate storage areas for hazardous and non-hazardous wastes; Separate skips for each waste stream to allow segregation in order to maximise re-use and recycling

opportunities; All skips to be suitably covered (to avoid dispersion of dust and other light materials by wind or filling of

the skip with rain); Liquid wastes /oil /chemicals to be stored in tanks or drums located in bunded areas which can hold

110% of the total storage volume and in accordance with national safety requirements; Spill kits to be available at all times; Located away from existing sensitive receptors such as existing communities or industries; Not at risk from theft or vandalism and unlikely to be damaged; Easily accessible in a safe manner; Well ventilated; Located next to any required Personal Protective Equipment (PPE) (as necessary for irritants and

hazardous materials); and The contractor will be required to develop a spill control, prevention and counter measure plan and an

Emergency Preparedness and Response Plan (EPRP).

The ESMP includes reference to the control measures in order to minimise the likelihood of incidents associated with materials storage, handling and use. These include the following: Identification of the necessary PPE requirements; Identification of the necessary bunding and spill kit requirements; Training requirements (as necessary) with respect to materials handling procedures; The correct procedure for reporting any environmental incidents related to spills / leakages and how to

deal with any spills / leakages; The specific regulatory reporting requirements as they relate to materials storage; Inventory of hazardous materials and specific procedures/ controls; and



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All hazardous substances used during the Project will be covered by a Material Safety Data Sheet (MSDS).

In addition, a valid copy of all waste carriers’ licences will be kept on site. The transfer notes will be completed in full and contain an accurate description of the waste and be signed by the producer and carrier before waste leaves the site.

12.7.4 Proposed Monitoring

Waste management monitoring for the Project will be undertaken by KPI as part of the construction and operational waste management plans detailed in Section 12.7.2 above. Monitoring data will be analysed and reviewed at regular intervals and compared with the operating standards so that any necessary corrective actions can be taken.


The mitigation measures identified above will ensure that the vast majority of waste generated as a result of the Project will be managed according to environmental best practice and the risk to the environment is significantly reduced. Following application of the mitigation measures the resultant residual impacts are presented in Table 12.6.




Activity Potential Impacts Sensitivity Magnitude Impact Significance Mitigation

Residual Impacts

Construction

Waste generation, and storage

Contamination of environments due to leakage and spillage of wastes associated with poor waste handling and storage arrangements

Low Moderate Minor Develop a waste management handling procedure as part of the ESMP

Identify a suitable temporary storage location for each waste stream

Both the onsite and offsite waste storage facilities will be include the following:

Separate storage areas for hazardous and non-hazardous wastes

Separate skips for each waste stream to allow segregation in order to maximise re-use and recycling opportunities

All skips to have a suitable cover

Liquid wastes/oil/chemicals to be stored in tanks or drums located in bunded areas which can hold 110% of the total storage volume.

Spill kits to be available at all times.

Insignificant


Low Moderate Minor Cover any skips used for the temporary storage of waste

Insignificant


Low Minor Insignificant Develop a waste management handling procedure

All waste storage vessels to be covered at all times

Insignificant


The use of landfill, which is a finite resource should be final recourse

Low Moderate Minor Characterise each waste type as either hazardous or non-hazardous and determine the hazardous class and applicable requirements

Seek to minimise waste production in the first instance

Where waste streams are unavoidable, highlight potential re-use and recycling opportunities according to current best practice and local opportunities

Insignificant



Activity Potential Impacts Sensitivity Magnitude Impact Significance Mitigation

Residual Impacts


Low Moderate Minor Identify waste handling facilities in close proximity to the Project

Review on an on-going basis the locally available re-use/recycling facilities to ensure they can accept the waste streams.

Insignificant

Operation

Waste generation and storage

Contamination of receiving environments due to leakage and spillage of waste streams from the operation of the PHD/PP Plants.

Low Moderate Minor As above Insignificant

Fugitive emissions associated with the handling and storage of operational waste streams




Low Minor Minor As above Insignificant



Decommissioning A future DEMP will be prepared

Waste generation and storage

Contamination of receiving environments (particularly surface watercourses, groundwater and the ground) due to leakage and spillage of wastes associated with poor waste handling and storage arrangements





Low Minor Insignificant As above Insignificant








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13.1 Introduction

This section considers the potential traffic and transportation impacts associated with the construction, operation and decommissioning of the Project. It considers the receptors external to the project site which may potentially be sensitive to the traffic and transport associated with the construction and operational phase and the significance of these impacts.

The assessment presented in this Section focuses on a number of aspects, including: Road and rail networks external to the development site which could require upgrade or experience

wear and tear Delays to other road users as a result of abnormal loads transportation or from exceedance of road

network capacity Scheduling impacts (i.e. as a result of increased freight on major routes) Road safety implications (i.e. as a result of increased traffic flow) Impacts on other environmental receptors, including ecology and the water environment, as a result of,

for example, run-off of contaminants

During both the construction and operational phase of the Project there will be a number of transportation activities. Depending on the phase the number and type of these movements will alter. The generic types of movements for each phase are described in Table 13.1 below. The impacts of traffic movements associated with decommissioning of the Project are assumed to be no greater than those associated with construction.

Table 13.1: Predicted Traffic and Transportation Activities

Project Lifecycle Stage Project Activity or Element

Construction Import of abnormal loads

Delivery of resources to site (concrete / water)

Mobilisation of construction workforce

Disposal of solid waste arisings

Earthmoving, foundations, excavations

Delivery of mechanical and electrical equipment for OHL works (towers, conductors etc.)

Delivery of materials and equipment)

Movement of construction workforce between workers accommodation and construction site

Operation Export of products from the industrial area;

Import of chemicals and catalysts;

Maintenance activities; and

Daily ingress and egress of workers.

13 Traffic and Transport



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13.2.1 Traffic and Transport Legislation and Policy in Republic of Kazakhstan

The main legal requirements for traffic and transport management in Kazakhstan are as follows: Law No. 156-XIII “On transport in the Republic of Kazakhstan” dated September 21, 1994 (as

amended 11.04.2014); and “Rules on access and service regulations of the railway infrastructure in the Common Economic

Space” approved by RK Government Decree No.841 dated August 26, 2013.


13.2.2.1 IFC Performance Standards and EBRD Performance Requirements

In respect of traffic and transport, the principles of the assessment have been developed in line with IFC Performance Standard 1 (Assessment and Management of Environmental and Social Risks and Impacts) and Performance Standard 4 (Community Health, Safety and Security), and with EBRD Performance Requirement 1 (Environmental and Social Appraisal and Management) and Performance Requirement 4 (Community Health, Safety and Security). The main policy and legislative objectives of each document which are relevant to this assessment chapter are summarized in Table 13.2 below.

Table 13.2: IFC Performance Standards

Performance Standard Key Policy and Legislative Objectives

Performance Standard 1 (Assessment and Management of Environmental and Social Risks and Impacts)

Performance Requirement 1 (Environmental and Social Appraisal and Management)

To identify and assess social and environment impacts, both adverse and beneficial, in the project’s area of influence

To avoid, or where avoidance is not possible, minimize, mitigate, or compensate for adverse impacts on workers, affected communities, and the environment

To ensure that affected communities are appropriately engaged on issues that could potentially affect them

To promote improved social and environment performance of companies through the effective use of management systems

Performance Standard 4 (Community Health, Safety and Security)

Performance Requirement 4 (Community Health, Safety and Security)

To avoid or minimize risks to and impacts on the health and safety of the local community during the project life cycle from both routine and non-routine circumstances

To ensure that the safeguarding of personnel and property is carried out in a legitimate manner that avoids or minimizes risks to the community’s safety and security



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13.2.2.2 JBIC and NEXI Environmental and Social Guidelines

There are no specific environmental and social requirements for traffic and transport in the JBIC or NEXI environmental and social guidelines.48 However, in both cases, reference should be made to Checklist 6: Petrochemicals49,50, in relation to the potential impact of vehicle transportation on living and livelihood.


13.3.1 Overview

The assessment has been undertaken using primary data collected during a site visit in April 2014 (detailed in Section 2) and by secondary data identified through a desk-top study. The methodology for the assessment can be summarised as follows: Establishment of baseline – an examination of existing traffic and transport routes which lead to the

proposed Project area, using knowledge gained from the Mott MacDonald site visit in April 2014; Trip generation – The estimated number of traffic movements associated with the Project for the peak

construction periods and for the typical operational period have been used; Assessment of impacts based on predicted volumes of vehicle movements generated by both the

construction and the operational phases. Possible effects arising as a result of the additional traffic have been identified and their significance assessed. Significance criteria have been adopted for the prediction of impacts within this ESIA.

Development of mitigation to reduce any significant impacts to an acceptable level and to identify good practice measures to minimise the overall environmental impact from traffic and transportation associated with the project.

13.3.2 Available Data and Data Limitations

The data made available for this section comes principally from the following sources: Information provided by KPI and CB&I; and Observations made during the site visits undertaken by the Project team in April 2014.

This assessment has been undertaken in the absence of the following data; Detailed traffic counts on the main roads which have been compiled over a number of days, weeks or

months Road safety information is unavailable and therefore a review of road accident trends cannot be

undertaken Precise origins of materials and spare parts during construction and operation and exact transportation

methods and routes.

48 JBIC makes reference to the IFC Performance Standards, where appropriate. 49 JBIC Environmental Checklists: https://www.jbic.go.jp/en/efforts/environment/confirm 50 NEXI Environmental Checklists: http://nexi.go.jp/en/environment/social/checklist/



275

In undertaking the required assessments for this section, it has been necessary to generate assumptions to overcome the absence of data based on experience of similar projects and knowledge of the likely transportation routes that materials may take. Professional judgement has been used to reduce the level of subjectivity within these assumptions as far as possible and where professional judgement has been used an explanation for assumptions reached has been provided.

13.3.3 Determining Significance of Impacts and Effects

The significance of potential impacts is a function of the presence and sensitivity of receptors and the magnitude of the impact in terms of duration, spatial extent, reversibility and likelihood of occurrence. The generic criteria for defining magnitude, sensitivity and overall significance are presented in Section 5 have been applied to this traffic and transport assessment.

The magnitude of transport impacts is, to an extent, subjective. The determination of the magnitude will therefore be based upon professional judgement taking into account the perceived sensitivity of the receiving environment.

13.3.4 Environmental Mitigation

Appropriate mitigation measures for the minimisation of traffic and transport related effects will be identified. Where there is the potential for aspects of the Project to cause cumulative traffic and transport related effects, or where other existing or proposed developments may lead to cumulative effects, the assessment will consider the combined effects and identify applicable and relevant mitigation measures.

Occupational health and safety requirements in relation to moving vehicles within the working area are addressed in detail in the ESMP. Potential nuisance (e.g. noise, air quality) and other environmental impacts caused by increased traffic are considered within the relevant environmental specialist chapters in this ESIA.


13.4.1 Overview

The Republic of Kazakhstan has well-connected road networks, railway network systems and inland waterways. Details on the traffic and transport networks in the Atyrau region have been detailed below. Where appropriate, details of transport routes outside of Kazakhstan have been identified.

13.4.2 Road

Kazakhstan has a vast road network, totalling approximately 97,418 km.51

51 CIA. 2014. World Factbook. Online: https://www.cia.gov/library/publications/the-world-factbook/geos/kz.html

https://www.cia.gov/library/publications/the-world-factbook/geos/kz.html



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During the Mott MacDonald site visit in April 2014 a number of basis traffic counts were undertaken, the objective of which was to collect heavy and light vehicle numbers to determine indicative traffic flows along the A27. The A27 is the main trunk road leading from Atyrau to Makat and finishes at the Russian border in the south-east. It is located only 6 km from the IPC site and also forms part of the international Astrakhan-Atyrau-Aktau-Turkmenistan route, which carries more than 1,300 vehicles per day.

During the site visit traffic counts were carried out for 30 minute intervals at the three locations identified in Figure 13.1 below: Location A (Latitude 47°17'38.77"N, Longitude 52°18'6.26"E) Location B (Latitude 47°8'39.63"N, Longitude 51°57'46.76"E) Location C (Latitude 47°8'32.99"N, Longitude 51°56'44.38"E)

These locations were chosen as they captured traffic passing the new approach road to the IPC as well as traffic leaving and entering Atyrau itself. The two counts in Atyrau were located before and after a major junction so existing baseline traffic flows along the A27 could be determined.

Figure 13.1 also presents a summary of the existing traffic levels along the road in each direction. These are based on an average one minute period from the total traffic counts.



Figure 13.1: Traffic Count Locations and Total Vehicle Flows per Minute

Source: Mott MacDonald notes, numbers represent total vehicles per minute



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The following tables present the traffic data collected at Location A. This is a key location close to the IPC access road and at the junction / exit road to the Karabatan refinery. Data was collected on a weekday (Friday 25 April 2014) and at the weekend (Saturday 26 April 2014).

Table 13.3: Location A: 25/04 Friday 15:02 – 15:32

Direction Number of vans, trucks

and large vehicles Number of cars Total vehicles Total vehicles per minute

From Atyrau 23 45 68 2.3

To Atyrau 22 43 65 2.1

Table 13.4: Location A: 25/04 Friday 16:21 – 16:51




To Atyrau 26 55 81 2.7

Table 13.5: Location A: 26/04 Saturday 11:25 – 12:25




To Atyrau 14 49 63 2.1

The tables below present data collected at Locations B and C on Saturday 26 April 2014. These sites were selected to determine indicative traffic flows in and out of Atyrau.

Table 13.6: Location B: 26/04 Saturday 12:45 – 13:15



From Atyrau 42 313 355 11.8

To Atyrau 64 311 375 12.5

Table 13.7: Location C: 26/04 Saturday 13:20 – 13:50



From Atyrau 78 516 594 19.8

To Atyrau 57 408 465 15.5

Although not exhaustive, the traffic count results demonstrate that there are relatively low vehicle numbers on the A27 close to the IPC. Although the A27 is a single lane at this section, the traffic was free flowing. In addition, the traffic count data illustrates that there is a lot more traffic on the outskirts of Atyrau (i.e. at locations B and C) than there is at location A. However, it should be noted that these sections of the A27 are dual lane and traffic was free flowing and not congested.



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13.4.3 Railway

The railway system is Kazakhstan is well connected to the Commonwealth of Independent States (CIS), Europe and the Far East. In the Atyrau region, the main railway network system is the Atyrau – Makat city line. The nearest railway station is Karabatan station, which is located approximately 35 km from Atyrau city and 9 km from the Project site. This will serve as the main rail yard for the Project, with a local rail spur up to the Project site.

The existing railway passes to the south of the IPC and is adjacent to the settlement Karabatan Station and the closest houses to the railway are approximately 30 m from the edge of the rail track. During consultation with residents of the settlement it was determined that on a normal day 23 trains would pass by the settlement.

13.4.4 Inland River System

There are a number of inland waterways which connect Atyrau to the wider region and to Europe and the CIS.

The nearest port to the Project is the Atyrau Ural river berth and the Agip jetty. However, there are a number of other sea ports located in the Caspian Sea, which have been detailed below: Aktau port – Aktau Commercial Port is located on the east coast of the Caspian Sea and is the only

international seaport of the Republic of Kazakhstan. Bautino port – the port serves as a base to support offshore oil operations for the development of oil

fields in the Caspian Sea. A number of multinational oil and gas companies are located on the port territory, such as "Agip" and “Tengiz Service”, as well as JSC "Aktau International Sea Commercial Port ".

Kuryk port – currently the Kuryk port provides services for the “Ersai” Steel Works.52

It should be noted that entry to the Russian river / canal network to the Caspian Sea is only open from the end of April to the end of October; however, actual dates might vary depending on weather conditions.

13.5 Assessment of Project Impacts

13.5.1 Construction Phase Impacts

13.5.1.1 Overview

A variety of construction materials, as summarized below, will be delivered to the site during the construction period, including: Materials for construction of infrastructure including site roads, vehicle parking and walkways Steel

52 The future development of the Kuryk port, however, will depend on the future operation of the Kashagan oil field.



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Concrete Building materials Piping Large operational plant items Specialist equipment.

The current estimate for construction materials and equipment is approximately 249,000 freight tons, which will be sourced from both national and international locations. Construction materials and equipment for the Project will be transported by road, rail and by river to the construction site; air freight has not been considered as a main transport option for the Project.

During the construction phase there are a number of key factors that will be taken into account when finalising the logistics plan. These include, for example, the size of containers that can be transported on the national railway system or the maximum size of abnormal loads that can access the site via key access roads.

The exact locations from which large items (i.e. out of gauge,long-lead) will be sourced are yet to be determined; however, it is considered that the only way for a significant part of the out of gauge / long-lead items to be transported is by barge. The inland Russia-Ukraine-Kazakhstan river system is considered as the main transport option for these items.53

It is estimated that 60% of the construction materials and equipment to be delivered to site by train. Where the use of rail transport is not available, remaining items will be transported to the Project sites via road using standard sized road trailers. Road deliveries will gain access to the site via the A27 and the project site will be set up to receive up to 50 trucks a day when required.

The project has one piece of equipment that will be 1000 metric tons and the plan is to fabricate it locally and transport it to site by a self-propelled modular transporter (SPMT). The fabrication site is located approximately 30 km from the Project site.

As discussed in Section 2 the Project will generate on average 1000-1500 construction jobs for the proposed schedule and it is expected that during the peak construction period during the summer of 2016 construction workers will peak between 2000-2500. At present it is anticipated that most of these will be housed locally on a nearby workers accommodation camp. Buses will be provided to transport construction workers from the workers accommodation to the construction site.

13.5.1.2 Capacity

The additional rail movements per month and additional daily road traffic movements are considered to be relatively small in comparison to the number of existing movements on the railway line and the existing capacity on the surrounding road network. Moreover, given the length and the size of the inland Russia-

53 Mariupol in Ukraine to be considered the main port for the Project; however, St Petersburg and Novorossiysk, both located in

Russia may also be utilised.



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Ukraine-Kazakhstan river system, the additional barges using the river will not have any impact on other river traffic. However, as exact numbers are not available at this stage, the magnitude of additional movements is conservatively considered as minor.

The sensitivity of the rail, river and road is conservatively considered to be medium based on the existing road conditions. During the Mott MacDonald site visit it appeared that there was additional capacity on the local road network but although as identified in Section 13.4 there are relatively low vehicle numbers the traffic count data is not exhaustive and only gives an indication of traffic flows along the A27. In addition it is likely that construction will pass through Atyrau where the number of vehicle movements is much higher than close to the IPC.

It has therefore been concluded that the impact of construction movements on the capacity of the local road network, the local rail network and the inland Russia-Ukraine-Kazakhstan river system is of minor adverse significance.

13.5.1.3 Transboundary Effects

During construction, the Project intends to use the inland Russia-Ukraine-Kazakhstan river system. It is therefore possible that the Project could have transboundary effects, such as the pollution of international waterways if there was a significant spillage from cargo tankers transporting project materials. Although unlikely, the significance of a potential impact is considered to be minor adverse.

13.5.1.4 Wear and Tear

With respect to the physical effects of construction traffic, it is considered that trucks (including those carrying abnormal loads) will have an effect of minor magnitude on the local road infrastructure due to the number of trucks and other vehicles during the construction phase. The sensitivity of truck movements to the local road network is considered to be low at present as a result of the good existing road conditions. There will be a number of heavy goods vehicles using the road network so there is the potential for the road surfaces to deteriorate, but overall the impact of construction traffic on highway ‘wear and tear’ is

therefore judged to be of insignificant.

13.5.1.5 Abnormal Loads

It is assumed that abnormal loads will be delivered via a combination of the inland Russia-Ukraine-Kazakhstan river system and road. Deliveries transferred from the river berth to road would use only roads suitable for such deliveries. A detailed Construction Traffic Management Plan (CTMP) will be developed in consultation with the local transport authority to identify appropriate solutions to the transportation of abnormal loads.

Although the exact number of abnormal loads is not known at present and will not be known until later in the detailed design phase and during the final construction plan, abnormal loads will be kept to a minimum as far as is reasonably practicable. The magnitude has been assumed as minor. The sensitivity of the abnormal movements is described as medium as there are a number of road users which may be affected,



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particularly in the areas surrounding Atyrau. The impact of abnormal loads is therefore judged to be of minor adverse significance.

13.5.1.6 Road Safety

As described above in the assessment of the road capacity, the exact number of additional vehicles during the construction phase is not known. However, as the majority of these vehicles will be Heavy Goods Vehicles (HGV), the increase in numbers related to road safety is described as moderate. The routes proposed for Project road traffic will avoid passing through the smaller settlements, with the potential impact being limited to housing along the main A27 highway. The sensitivity of people in residential areas along the proposed construction transport is considered to be medium as there will be vulnerable road users such as pedestrians. The impact of construction traffic on road safety is therefore judged to be of moderate adverse significance.

13.5.1.7 Nuisance to Nearby Settlements

The additional rail movements as a result of construction activities have the potential to have an adverse effect on sensitive receptors, particularly at Karabatan Station. The current number of trains per day is low and although the exact number of additional trains during construction is not known it is not anticipated that these will significantly increase the existing numbers. On this basis the significance effect on nuisance is considered to be insignificant.

13.5.2 Operation Phase Impacts

13.5.2.1 Overview

As described in the Project description the propylene generated from the PDH plant will be used within the PP plant and therefore there will be no transport associated with it. The PP plant will manufacture large quantities of polypropylene pellets which will either be transported from the IPC using the rail station and spur or they will be transported by road using articulated HGVs. As described in Section 2 there are a number of potential transport options dependant on who the end user of the polypropylene pellets is however it is estimated that at there will be approximately 15 vehicle movements per day and three rail movements per day associated with the transport of products.

The operation of the Project will generate solid waste, which will be collected by a licenced waste carrier for disposal or recycling. Currently no contract for a licenced carrier for disposing of or recycling waste is in place and therefore the following vehicle numbers are based on estimates from the expected volumes of waste. It has conservatively been estimated that approximately 10 vehicles per month will be responsible for transporting operational waste from the Project, with 5 vehicle movements per month to transport domestic waste from the Project.

Operation of the Project will involve the daily commute of operational personnel to and from the IPC. At present it is expected that the majority of these workers will live in Atyrau either in their existing accommodation or in purpose built accommodation for the Project. The operational workforce for both the



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Project will operate in shifts and it is planned that shuttle buses will transport the majority of workers to and from the site. There will be some provision for car parking within the IPC and it is expected that some additional car journeys to and from the IPC will also be made.

13.5.2.2 Capacity - Operational Workforce

The operation of the Project is not expected to significantly affect the existing number of movements on the road network. Although a significant number of new jobs will be created, the majority of the workforce will be transported by bus and will be spread across the day.

In accordance with the significance criteria, the sensitivity of the receiving road network is considered to be low and the magnitude of effect negligible and consequently the significance is assessed to be insignificant.

13.5.2.3 Capacity – Movement of Products

The operation of the plant will generate 500,000 tonnes of polypropylene pellets per annum, which will be exported from the IPC by rail and by HGVs. Based on the volumes of products that will be generated the magnitude of the additional rail movements and HGV movements is described as moderate. There is additional capacity on the rail line and local road network so the sensitivity is described as low. In accordance with the significance criteria, the effect of transporting the products is assessed to be of minor adverse significance.

13.5.2.4 Transboundary Effects

There are not considered to be any transboundary effects as a result of Project operations, consequently the impact significance is judged to be insignificant.

13.5.2.5 Wear and Tear

During the operational phase of the Project, there will be additional traffic on the existing road network. Given the current good condition of the roads surrounding the IPC the sensitivity on the receiving road network is considered to be low, the magnitude of effect moderate due to the expected number of large goods vehicles required to transport polyethylene and polypropylene from the site on an annual basis and consequently impact significance assessed to be of minor adverse significance.



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13.5.2.6 Abnormal Loads

It is not anticipated that abnormal loads will be required as part of routine operations consequently the impact significance is judged to be insignificant.

13.5.2.7 Road Safety

Within the IPC

There will be a number of vehicle movements associated with operational workforce and deliveries and transportation of goods to and from the Project. Although the workforce will be provided with clear walkways and be fully briefed on health and safety and be equipped with high visibility jackets the potential impacts are predicted to be of a moderate magnitude. The sensitivity of the workers on site is considered to be low due to the requirement for site operations to conform to international safety standards. The significance of the impact on road safety and accidents within the existing industrial area is considered to be of minor adverse significance.

Outside the IPC

During the operational phase there will be additional HGVs using the local road network. Although exact numbers of additional vehicles is not known the transportation of pellets will result in approximately 15 additional vehicles per day, therefore the magnitude of the increase in numbers related to road safety is described as minor. The sensitivity of road users such as pedestrians, particularly in areas where the main traffic routes pass residential areas in Atyrau, is considered to be medium. Although the operational traffic is not likely to pass through the nearby settlements, the potential impact of operational traffic on road safety is conservatively assessed to be of minor adverse significance.

13.5.2.8 Nuisance

The additional rail movements as a result of operation activities have the potential to have an adverse effect on sensitive receptors, particularly at Karabatan Station. The current number of trains per day is low and although the exact number of additional trains during operation is not known (it is anticipated to be approximately five per day - two for the delivery of propane and up to three for the export of polypropylene pellets) the existing numbers will not significantly increase. On this basis the significance effect on nuisance is considered to be insignificant.

13.5.3 Decommissioning

The impacts of traffic movements associated with decommissioning of the Project are assumed to be no greater than those associated with construction.



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The ethylene, polyethylene plant, butadiene production plant and polymer production plant also form part of the IPC site. These plants will also generate additional traffic during their construction and operational phases, although the construction periods will overlap it are not expected that they will coincide at exactly the same time. Exact numbers of additional traffic movements associated with these plants is not known at this stage and therefore cannot be assessed in detail. However it is not considered that the additional traffic caused by these plants on top of the Projects traffic would cause significant impacts as the expected levels of traffic and rail movements generated would be of a similar magnitude to those expected for the Project and therefore in comparison to available capacity are small.

Nevertheless mitigation measures provided in section 13.7 have been provided based on the potential cumulative impacts from the IPC.


At this time it is assumed that mitigation proposed for construction will be duplicated for the decommissioning phase. However, it is expected that mitigation based on future knowledge and best practice will be recommended as part of any future detailed decommissioning plan.

There is only one potentially significant impact identified during this assessment – road safety outside the industrial area, and mitigation measures are proposed to address this potential risk. All other potential impacts were assessed as non-significant, however, good practice measures and recommended measures to reduce non-significant impacts are also outlined in Table 13.8.

Mitigation is presented in this section by theme of impact due to the applicability of mitigation measures to impacts resulting from all scheme components.

Table 13.8: Mitigation and Enhancement Measures

Impact Theme Mitigation and Enhancement Measures

Reduced safety of vulnerable road users on the local roads and of residents at any residential areas affected by construction or operational traffic

Measures to reduce the risk to vulnerable road users and occupants of residential properties in the vicinity of roads which will be affected by construction and operational traffic will be identified as part of the detailed Construction Traffic Management Plan (CTMP).

The CTMP will draw on international best practice in developing and ensuring the implementation of suitable strategies, Consultation the appropriate highways authority to ensure identified measures take into account local circumstance.

Delays to road users as a result of abnormal loads

A detailed CTMP will be developed in consultation with the local transport authority to identify key issues and appropriate solutions. The CTMP will be produced in accordance with applicable international standards.

Wear and tear on local roads as a result of traffic volumes and abnormal roads

Measures to reduce wear and tear will be considered as part of the CTMP. In addition, KPI will enter into a voluntary agreement with the relevant highways authority to reimburse the cost of any repairs required to the public highway network as a result of the project.

Improved safety for other motorists Erect signs in each direction along the A27 where the road is single carriageway about the dangers of overtaking.



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13.7.1 Proposed Monitoring

Procedures for monitoring the effectiveness of the mitigation measures proposed in this section are provided in the ESMP and will be expanded upon in the Project specific CTMP and an operational traffic management plan (TMP). Monitoring measures should in particular be designed to identify failure or ineffectiveness of measures in terms of road and rail safety.


Residual effects are those effects that remain after mitigation has been implemented. A tabulated summary of impacts associated with the development and the residual impacts following mitigation is presented in Table 13.9.





Construction

Capacity Additional volume of traffic on the road network resulting in disruption to existing users

Medium Minor Minor adverse Where possible deliveries of materials and movements of construction workers will be planned to avoid the busiest roads in Atyrau and times of day when traffic is at its greatest.

Insignificant

Wear and tear Wear and tear as a result of type of traffic and volumes

Low Minor Insignificant Measures to reduce wear and tear will be considered as part of the CTMP. KPI will enter into a voluntary agreement with the relevant highways authority to reimburse the cost of any repairs required to the public highway network as a result of the project.

Insignificant

Abnormal loads Delays to road users as a result of abnormal loads

Medium Minor Minor adverse Abnormal loads will be scheduled for night time periods to minimise disruption. Local residents will be informed of the schedule for abnormal roads in advance

Insignificant

Road safety Reduced safety of residents of Atyrau and surrounding villages, particularly vulnerable groups such as pedestrians.

Medium Moderate Moderate The CTMP will draw on international best practice in developing and ensuring the implementation of suitable strategies to guard against reduced safety for pedestrians.

Minor adverse

Operation

Capacity – Operational workforce

Exceedance of road network capacity resulting in disruption to existing users

Low Negligible Insignificant Provide adequate shuttle busses to transport workers to the IPC and reduce the need to drive.

Insignificant




Capacity – Movement of products

Increase number of HGV movements on the road network resulting in disruption to existing users

Low Moderate Minor adverse Where possible products should be transported from the IPC using rail.

Insignificant

Wear and tear Wear and tear as a result of type of traffic and volumes

Medium Minor Minor adverse KPI will enter into a voluntary agreement with the relevant highways authority to reimburse the cost of any repairs required to the public highway network as a result of the project.

Insignificant

Road safety within industrial area

Reduced safety of workforce in the industrial area

Low Moderate Minor adverse Workers should be informed and reminded of road safety in the IPC via tool box talks and staff notice boards.

Insignificant

Road safety outside the IPC

Reduced safety of residents of Atyrau, particularly vulnerable groups such as pedestrians.

Medium Minor Minor adverse Measures to reduce the risk to vulnerable road users and occupants of residential properties in the vicinity of access routes should be identified as part of the detailed CTMP. The CTMP should draw on international best practice in developing and ensuring the implementation of suitable strategies.

Warning signs for overtaking should be erected along the A27

Minor adverse

Decommissioning

As per construction - - - - - -



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14.1 Introduction

Potential noise and vibration impacts due to the Project are expected to arise during all phases. Temporary impacts are likely to occur due to construction activities particularly piling, drilling, excavation works and the movement of heavy vehicles. Temporary impacts may also arise during the decommissioning phase as the equipment and buildings are dismantled and the site reinstated. Permanent impacts are expected due to the operation of fixed plant and equipment, and due to the use of associated infrastructure such as the road and railway links to the Project site. Cumulative impacts may arise due to the concurrent construction and/or operation of other projects to be implemented within the IPC.

This Chapter presents an assessment of key noise and vibration impacts in order to identify potential significant effects so that the scope to mitigate any significant adverse effects can be considered.

With reference to Figure 2.9 within Section 2, the nearest existing residential receptors to the Project site are at Karabatan Station at 7 km to the south-east. The burial site at 4.5 km to the south-east of the Project site is also considered to be a sensitive receptor. Residential receptors at Karabatan Station are at a minimum of 30 metres from the new rail spur which will be used during the construction and operation of the Project.

Options for workers accommodation are expected to be at a minimum of 15 km from the Project site and are sufficiently remote such that no significant adverse effect are expected to arise at these locations.

During a noise survey conducted by Mott MacDonald in April 2014, it was observed that the noise climate in the area of the closest sensitive receptors is dominated by wind generated sources due to exposed nature of the local terrain.

Ground-borne vibration from construction activities or operational sources has the potential to affect the occupiers of buildings or the structure itself. The largest vibration impacts arising due to the Project are expected to be associated with construction activities such as percussive piling or vibratory equipment. This is can be a matter of concern where this type of work is undertaken in close proximity to buildings. Given the location of the Project site in relation to sensitive receptors, effects due to vibration during construction works, and due to operational activities at the Project site, are not expected and are not assessed further.


14.2.1 National

Kazakhstan’s main noise and vibration standards and regulations are as follows: RK Law Nom 10-I On ratification of the Convention of the International Labour Organization (ILO) N

148 "On the professional risk protection of workers from air pollution, noise and vibration at the workplace" (1977)

14 Noise and Vibration



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SanPiN "Sanitary requirements on air quality in urban and rural areas, soils and their security, conditions of urban and rural settlements areas, working conditions with sources of physical impact factors" established by Government Decree No.168 dated January 25, 2012

National Law of the Republic of Kazakhstan № 7-1 dated June 13, 1996 "On ratification of the International Labour Organization (ILO) Occupational Safety and Health Convention, 1981 (No. 155)"

Government Decree of the Republic of Kazakhstan № 878 dated June 9, 2000 "On approval of the National Action Plan on Healthy Environment (NAPHE) of the Republic of Kazakhstan" (as amended by the RK Government Decree № 922 on 12.09.03)

Sanitary Norms of RoK 1.02.007-94 "Sanitary norms on noise levels in the workplace"

These are mainly concerned with noise levels within buildings given to occupational and recreational activities.

14.2.2 International

14.2.2.1 World Health Organization

The World Health Organization (WHO) provides broad guidance on noise levels required to protect individuals from harmful levels of noise within a range of environments, which is described in ‘Guidelines for Community Noise’ (1999). The guidelines are intended to guide the long-term management of community noise to help meet the WHO’s core objective of “the attainment by all peoples of the highest possible levels of health”.

This is an important reference which includes guideline noise values that are founded on the results of scientific research into the effects of noise on the population. This forms the basis of standards for noise used worldwide. The specific values that are considered appropriate to the Project are given in Table 14.1.

Table 14.1: WHO Guideline values relevant to the Project

Specific environment Critical health effect(s) Guideline noise value

Outdoor living areas Serious annoyance – daytime and evening 55 Leq,16 hours dB(A)

Dwellings – outside bedrooms (window open) Sleep disturbance – night-time 45 Leq,8 hours dB(A)

Industrial, commercial, shopping and traffic areas, indoors and outdoors

Hearing impairment 70 Leq,24 hours dB(A)

The Guidelines do not specify the hours of the day over which the time bases apply because what is considered to be daytimes, evenings and night-times are expected to be dependent on the social and cultural trends of a country and therefore vary around the world.

14.2.2.2 International Finance Corporation – Environmental Noise

The World Bank Group (WB) has developed a thorough programme of pollution prevention and management techniques in order to ensure that projects funded by the organisation are environmentally and socially responsible. The International Finance Corporation (IFC), a member of the WB, has produced



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Environmental, Health and Safety (EHS) General Guidelines that apply to investment projects in various industry sectors. The respective limit values for environmental noise are detailed in Table 14.2.

Table 14.2: WB/IFC Noise Limit Values

Specific Environment Noise Level Leq,1 hour dB(A) free field

Daytime

(07:00-22:00)

Night-time

(22:00-07:00)

Residential, educational or institutional 55 45

Industrial or commercial 70 70

The EHS Guidelines require the noise impacts should not exceed the limit values presented in Table 14.2 or result in a maximum increase in background levels of 3 dB(A) at the nearest sensitive receptor location outside the Project site.

14.2.2.3 International Finance Corporation – Construction and Decommissioning

The IFC General EHS Guidelines for Construction and Decommissioning include recommendations for noise reduction and control strategies as follows: Planning activities in consultation with local communities so that activities with the greatest potential to

generate noise are planned during periods of the day that will result in least disturbance Using noise control devices, such as temporary noise barriers and deflectors for impact and blasting

activities, and exhaust muffling devices for combustion engines Avoiding or minimizing project transportation through community areas

14.2.2.4 British Standard 5228 – Code of Practice for Noise and Vibration Control on Construction and Open Sites

Construction is considered within the WHO guidance as a source of community noise. However, no specific allowance is made for the consideration of the short-term exposure to higher levels of noise that typically arise during construction. Consequently, the noise limit levels presented above are considered to be unduly stringent if applied as criteria for the assessment of temporary noise impacts arising during the construction of the Project.

Consequently, the WHO and IFC Guidelines are generally applied only to the permanent, operational noise impacts of a development. It is widely accepted that noise impacts generated during the construction of an industrial site are inherently higher than the impacts arising under operation. Consequently, higher noise levels during construction are usually tolerated in the knowledge that the impacts are temporary.

The British Standard 5228 ‘Code of Practice for Noise and Vibration Control on Construction and Open

Sites’ (2009 amended 2014) provides comprehensive guidance on construction noise and vibration including details of typical noise levels associated with various items of construction equipment or activities, prediction methods, and measures and procedures that have been found to be most effective in



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reducing impacts. The guidance forms the basis of the majority of construction noise assessments in the United Kingdom and is widely recognised internationally. It has been adopted for this assessment.


14.3.1 Significance of Effects

The purpose of the assessment is to identify and assess the significance of effects due to noise and vibration impacts expected to be associated with the Project. The significance of effects is a function of the magnitude of impact and the sensitivity of the receptor. The significance criteria to be used in this assessment are presented in Section 5.

The methodologies and scales used to assess the magnitude of impact for the key noise impacts expected during construction and operation are set out below.

14.3.2 Magnitude of Impact

14.3.2.1 Construction and Decommissioning Phases – Temporary Noise Impacts from General Construction Activities

Annex E of BS 5228 presents example methods for assessing the significance of noise from construction activities and ‘Example method 2 – 5 dB(A) change’ has been adopted. Noise levels due to site activities are deemed to be potentially significant if the ambient noise levels during construction (pre-construction ambient plus construction noise) exceed the pre-construction ambient noise levels by 5 dB or more subject to lower cut-off values of 65 dB(A) for the daytime, 55 dB(A) for the evening and 45 dB(A) for the night-time for the level of construction noise alone. Furthermore, to be regarded as significant, noise levels of this magnitude would need to be sustained over one month or more unless works of shorter duration are likely to result in a significant effect.

Based on these criteria, the magnitude of impact of noise due to general construction noise will be assessed using the scales presented in Table 14.3 assuming the majority of works will be conducted during normal daytime working hours.



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Table 14.3: Assessment of magnitude of construction noise impacts

Construction Noise Level Leq dB(A)

Definition Daytimes Duration Magnitude of impact

Potentially perceptible but non-significant change in conditions

<55 Months Negligible

<60 Weeks

<65 Days

Perceptible but restricted change in conditions

55 – 60 Months Minor

60 – 65 Weeks

65 – 70 Days

Material but non-significant change in conditions

60 – 65 Months Moderate

65 – 70 Weeks

70 – 75 Days

Significant change in conditions

>65 Months Major

>70 Weeks

>75 Days

14.3.2.2 Operational Phase – Permanent Noise Impacts from Fixed Plant

The Project has the potential to generate noise during normal operation due to the items of equipment that are to be installed within the Project site. Additional temporary noise impacts may be generated during start-up operations and emergency situations (audible alarms, emergency flaring) but as this is anticipated to be very infrequent this is not considered further. The assessment considers steady-state operational noise only.

The magnitude criteria for operational noise impacts presented have been developed based on the IFC/World Bank Group guidelines and WHO Guidelines.

Table 14.4: Assessment of magnitude for operational noise impact from fixed plant

Criteria Definition Magnitude of impact

Residential

- Daytime 55 Leq dB(A)

- Night-time 45 Leq dB(A)

Operational noise level below criterion Negligible

Operational noise level less than 3 Leq dB(A) over criterion

Minor

Operational noise level less than 5 Leq dB(A) over criterion

Moderate

Operational noise level 5 Leq dB(A) or more above the criterion

Major

14.3.2.3 All Phases – Road and Rail Traffic Noise

Road and rail traffic accessing the site during the construction and decommissioning phases may generate temporary increases in road traffic noise in the area. The delivery of materials, export of products, attendance of site operatives for daily activities and for periodic servicing and maintenance is expected to generate long-term road and rail traffic movements in the area over the operational lifetime of the Project.



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The UK methodology for predicting noise impacts due to free-flowing road traffic is the Calculation of Road Traffic Noise (CRTN). This demonstrates that a 25% increase in the volume of traffic (all other factors unchanged) is required to result in a corresponding 1 dB increase in traffic noise. This is the smallest change in steady-state road traffic noise that may be perceptible in the short-term. The Design Manual for Roads and Bridges (DMRB) is a UK standard relevant to road projects and Volume 11 Section 3 Part 7 HD 213/11 includes specific guidance for assessing noise associated with road projects.

The scale presented in Table 14.5 is used for the classification of the magnitudes of impact of short-term changes in road traffic noise. It is based on the DMRB guidance within HD 213/11 and is adopted here. It should be noted that within CRTN, road traffic noise is described using the L10 dB(A) statistical descriptor for the 18-hour daytime period 06:00 to 24:00. This is the noise level exceeded for 10% of the measurement interval and describes the highest part of the sound measured.

Table 14.5: Assessment of the magnitude of impact due to changes in road traffic during construction

Change in the level of road traffic noise LA10,18h dB (A)

Definition Magnitude of impact

Less than 1 dB(A) A potentially perceptible but non-significant change in conditions

Negligible

1 dB(A) to < 3 dB(A) A perceptible but restricted change in conditions

Minor

3 dB(A) to <5 dB(A) A material but non-significant change in conditions

Moderate

5 dB(A) or more A significant change in conditions Major

The 18-hour descriptor may not be appropriate given the rural nature of the area and relatively low traffic flows, which are more intermittent rather than ‘free-flowing’. However, it is assumed that the scales can be

applied to describe the magnitude of noise change where the level of noise from traffic is described using the LAeq descriptor.

In the case of rail traffic, no similar methodology exists to assess the magnitude of impact corresponding with changes in noise from rail movements. Therefore, for consistency, the above scales are also applied to determine the magnitude of impact due to changes in rail noise from existing routes due to the additional rail movements associated with the Project.



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14.3.3 Sensitivity of Receptors

Sensitivity criteria for the assessment of noise impacts affecting sensitive receptors are assigned in Table 14.6.

Table 14.6: Receptor sensitivity criteria

Sensitivity Type of receptor

High Residential area, hospitals, schools, colleges or universities, places of worship, designated environmental areas, nature areas, high value amenity areas, cemeteries.

Medium Offices, recreational areas, agricultural land.

Low Public open spaces, industrial areas, car parks.

Negligible Derelict land.

The key sensitive receptors considered within this assessment are identified as residential receptors at Karabatan Station and the burial site. All receptors within these areas are considered to have High sensitivity for the purposes of this assessment. The increased sensitivity of residential receptors during the night time is accounted for by applying more stringent criteria in assessing the magnitude of impacts during the night. Therefore, there is no need to adjust the assigned sensitivity.


14.4.1 Overview

The area of the Project site is rural with very few sources of man-made noise. It is flat and is exposed to the wind as a consequence. Noise generated by wind in the low lying vegetation was observed to be a dominant feature of the noise climate, with the A27 road and railway as the main sources of man-made noise in the surrounding area.

14.4.2 Survey

The baseline noise survey was undertaken by Mott MacDonald on Saturday 26 April 2014 comprising short-term, attended noise measurements made at four positions: Within the Project site Access road on the southern perimeter of the Project site Burial site between the Project site and Karabatan Station settlement Karabatan Station settlement

A plan indicating the measurement positions is presented in Figure 14.1.



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Figure 14.1: Positions used during the attended noise survey by Mott MacDonald on Saturday 26 April 2014


All measurements were undertaken in accordance with the principles of ISO 1996 ‘Acoustics – Description, measurement and assessment of environmental noise – Part 2: Determination of environmental noise levels’ (2007) which describes methods to be used for measuring and describing environmental noise relevant for general land use.

All acoustic measurement equipment used during the noise survey was designed to be in conformance with the Class 1 requirements for accuracy as set out in the international standard IEC 61672 for sound level meters and IEC 60942 for calibrators. The sound level meter and field calibrator used held current calibration certificates obtained under laboratory conditions traceable to UK and International Standards.



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Before and after the measurement session, the reference calibration level of the sound level meter was checked using the field calibrator. No significant drift in sensitivity was identified over the measurement session (less than 0.5 dB).

The microphone of the sound level meter was supported using a tripod at a height of 1.5m above local ground level and fitted with a windshield suitable for outdoor use.

The sound level meter was configured to measure a range of acoustic parameters (A-weighted) averaged over the measurement interval of 15 minutes. The following parameters were recorded: Leq dB(A) Equivalent continuous noise level in decibels L(max)F dB(A) Maximum sound pressure level in decibels using the fast time weighting L90 dB(A) Sound pressure level in decibels exceeded for 90% of the measurement interval

The results of the noise survey are summarised in Table 14.7. The dominant source of noise during the measurements was noted to be wind, which was observed to be reasonably constant and typical of the exposed location. This was noticeable at the Project site measurement position which was in an area that had been already cleared prior to the construction of the IPC and was particularly exposed.

Table 14.7: Summary of baseline noise survey results

Position Interval start

time (hh:mm) Leq dB(A) L(max)F dB(A) L90 dB(A)

Project site

10:24 59.9 70.0 53.5

10:34 60.0 70.8 53.2

10:44 60.9 69.7 53.2

10:54 61.1 70.5 53.8

Access road

11:16 47.2 59.6 34.5

11:26 45.5 60.5 35.9

11:36 44.0 56.5 34.7

Burial site

11:57 50.0 63.8 41.8

12:07 49.8 63.0 40.8

12:17 50.9 66.6 42.3

Karabatan Station

12:53 53.3 72.2 47.9

13:04 54.6 68.2 50.4

13:14 53.3 69.5 47.1



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14.5.1.1 Temporary Noise Impacts from General Construction Activities

It is assumed that the construction of the Project will comprise three main activities: Site clearance, excavation, piling and groundworks Movement of materials Construction of infrastructure

Details of the phasing of these activities and the type and quantity of plant items required is not currently available. However, an assumed inventory, based on that required for similar developments, is presented in Table 14.8 and has been used to provide an indication of potential noise impacts. The utilisation of plant is given over a three-year construction period. Reference noise levels taken from BS 5228 – 1:2014 for equivalent items are also presented.

Table 14.8: Assumed inventory of construction

Title of Construction Machinery and Vehicles Rating/size

Quantity by year BS 5228 Reference

Reference noise level

Leq,10m dB(A)

Year 1 Year 2 Year 3

Self-propelled module transporter

6 lines 0 6 3 C.5/37 76

Low bed trailer 60t capacity 0 1 1 D.7/121 70

Flat-bed trailer 30t capacity 1 3 3 D.7/121 70

Flat-bed trailer 10t capacity 2 4 4 D.7/121 70

Excavators 1 2 1 C.6/4 80

Front end loaders

3 2 1 C.2/26 79

Diesel generators

350 kW 2 20 10 C.6/39 65

Diesel compressors 375 CFM

2 6 6 C.5/5 65

Portable welding machine (diesel)

1 5 4 C.4/85 66

Portable welding machine (electric)

5 15 10 C.3/33 57

Portable lighting plant

8 kW 0 4 4 C.4/87 65

200t Mobile telescopic crane

0 1 1 C.4/46 67



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Title of Construction Machinery and Vehicles Rating/size

Quantity by year BS 5228 Reference

Reference noise level

Leq,10m dB(A)


1 4 4 C.4/46 67


1 4 4 C.4/46 67

75t Hydraulic crane

275 hp/205 kW 1 3 3 D.7/112 74

50t Hydraulic crane

50 – 60t 1 5 5 D.7/112 74

30t Hydraulic crane

25t 1 3 3 D.7/112 74

160t Crawler crane

0 1 1 C.4/52 75

280t Crawler crane

0 1 1 C.4/52 75

400t Crawler crane

0 1 1 C.4/50 75

500t Crawler crane

0 1 1 C.4/50 75

1250t Crawler crane

0 1 1 C.4/50 75

Batching plant (electric)

100m3/h 2 2 1 D.6/10 78

Concrete mixer truck + pump

6 – 8 m3 5 5 2 C.4/24 67

Tower crane (electric)

2 2 1 C.4/48 76

Forklift 3t – 7t 1 2 1 C.4/54 79

Truck 20t 2 4 4 D.7/121 70

Elevated Work Platform

80’/120’ 6 5 4 C.4/59 78

‘Method for Activity LAeq’ presented in Annex F of BS 5228 – 1:2014 includes a methodology for predicting noise impacts from construction activities. It has been used with the reference noise levels from Table 14.8 to estimate noise levels (Leq dB(A)) from construction at receptor locations.

A precautionary approach has been taken in order to consider worst-case noise impacts. The following assumptions have been made in order to simplify the predictions: No attenuation due to the screening of noise sources by buildings or topographical features between

the construction noise sources and the sensitive receptor positions No attenuation due to ground absorption (hard ground conditions) No attenuation due to atmospheric absorption as the calculation procedures of BS 5228 – 1:2014

make no provision for this



300

All plant indicated within each year of the construction period will operate continuously and simultaneously

The distance of propagation for all sources is the shortest distance from the Project site perimeter and the receptor

In practice, these factors would provide additional reductions in the level of noise received at the sensitive receptor positions that are not accounted for here, therefore the results of the calculations would produce a very conservative assessment.

Table 14.9: Predicted temporary noise impacts due to general construction activities

Receptor

Noise level from the PP/PDH

plant Leq dB(A) (free

field )

Magnitude of impact daytime

Magnitude of impact night

time

Year 1 Year 2 Year 3

Karabatan Station 33 34 33 Negligible Negligible

Burial site 37 37 37 Negligible Negligible

The results of the calculations show that at all sensitive receptors, and under worst-case conditions, noise levels from general construction activities are expected to be below the most stringent lower cut-off value of 55 dB(A) for construction noise alone (no background noise). It would also fall below a lower threshold of 45 dB(A) which would apply in the night period. This is assessed as set out in Table 14.3 as having a negligible magnitude of impact at all receptors. It indicates that no significant adverse effects due to general construction activities are expected, even in works were carried out during the night time.

14.5.1.2 Temporary Noise Impacts from Road Traffic during Construction

Road traffic during construction is expected to comprise: Buses to transport the workforce between workers accommodation and the Project site with an

expected peak of 2,000 to 2,500 workers Delivery of materials and equipment and it is expected that the site will have capacity for up to 50

deliveries per day (100 movements)

It is understood that the A27 road currently carries a minimum of 1,300 vehicles per day. Construction-related traffic would need to increase daily flows by 335 vehicles for noise levels at positions adjacent to the road to increase by 1 dB. Significant adverse effects on high sensitivity receptors are indicated by moderate or major magnitude of impacts which, in terms of road traffic noise, corresponds with a change 3 dB or more. This is a doubling of traffic flow as a minimum. Based on the number of deliveries and workers, it is considered unlikely that the construction-related traffic will double flows on the A27. It is concluded that no significant adverse effects are expected due to road traffic during construction.



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14.5.1.3 Temporary Noise Impacts from Road and Rail Traffic during Construction

It is estimated that 60% of the materials required for the construction of the Project will be delivered to the site by rail using the newly constructed spur form the existing railway. The exact numbers of additional rail movements is not yet known. The additional movements will pass through Karabatan Station on the new rail spur which will be at a minimum distance of 30 metres from residential receptors.

It is understood that approximately 23 rail movements currently pass through Karabatan Station each day.

The same scales to indicate magnitude of impact and the significance of effects have been applied in the case of road and rail traffic within the present assessment. Therefore, a significant adverse effect would be indicated where noise levels increase by 3 dB or more which also corresponds with a doubling of rail movements. This is not expected to occur.


14.5.2.1 Permanent Noise Impacts from Fixed Plant

Based on the information provided by CB&I, the following assumptions are made: The plant shall be of a modern (state of the art) design The plant shall include ALARP (As Low As Reasonably Practicable) noise abatement measures such

as low noise equipment designs, acoustic enclosures, acoustic insulation, silencers etc The plant, in general, will not include noise abatement measures beyond ALARP, such as closed

buildings for gas turbines, fired heaters and compressors or replacement of all air cooling by water cooling.

Detailed modelling of individual items of fixed plant has not been carried out at this stage. However, site noise emissions have been estimated using a method used within the chemical process industry, which agrees well with CB&I project experience. The equation to estimate sound power level of the site per unit area is given in Equation 1.

(1)

The area of the Project site is 1,109,250m2, and the estimated overall sound power level for the site is given as 125.5 dB(A).

For the prediction of operational noise impacts, a three-dimensional acoustic model has been developed to describe the acoustic environment in the area of the IPC to the sensitive receptors. The model has been developed using DataKustik GmbH CadnaA (v4.1.146) software which implements the procedures of ISO 9613 ‘Acoustics – Attenuation of sound during propagation outdoors – Part 2: General method of calculation’ (1996). The model assumes a moderate degree of ground absorption (G = 0.5).

It should be noted that the accuracy of ISO 9613 for the prediction of sound attenuation at distances of up to 1,000m is given as ±3 dB. For longer propagation distances the accuracy of the methodology is not



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stated and is expected to be progressively less reliable. This is due to the influence of meteorological conditions and the ability of elements of the calculations to represent terrain that is not flat.

Table 14.10 presents the results of the calculations carried out by the acoustic model.

Table 14.10: Predicted permanent noise impacts due the operation of fixed plant of the PP/PDH development

Receptor

Noise level from the PP/PDH plant Leq dB(A) (free field )

Magnitude of impact daytime

Magnitude of impact night time

Karabatan Station 19 Negligible Negligible

Burial site 27 Negligible Negligible

The results show that operational noise levels are expected to be below 45 dB(A) at all sensitive receptors and therefore the magnitude of impact is assessed as set out in Table 14.4 as negligible in all cases. The assessment indicates that no significant adverse effects are expected at any sensitive receptor due to the operation of fixed plant to be installed at the IPC under the PD/PDH Project.

The operational noise impacts are also assessed in terms of the IFC guidelines (see Table 14.2), which take into account changes in ambient noise levels. The results are presented in Table 14.12 and show that: Operational noise impacts at the Karabatan Station and the burial site due to the Project are below the

55 dB(A) and 45 dB(A) guideline levels for daytime and night-time respectively The Project is not expected to result in a change in ambient noise levels at any of the existing sensitive

receptors.

Table 14.11: Assessment of operational impacts of the Project against IFC guidelines

Receptor

Noise level from the PP/PDH plant Leq dB(A) (free field )

Baseline Leq dB(A) (free field )

Ambient during construction

Change in ambient due to the operation of the PP/PDH plant

Karabatan Station 19 54 54 0

Burial site 27 50 50 0

14.5.2.2 Permanent Noise Impacts from Road Traffic during Operation

Road traffic during operation is expected to comprise: Export of products (polypropylene pellets) is expected to result in 100 movements per day Shuttle buses and a small number of private cars to transport the workforce between workers

accommodation and the Project site Collection of operational solid waste is expected to involve 10 vehicle movements per month Collection of domestic solid waste is expected to involve 5 vehicle movements per month

It explained in Section 14.5.1.2 above that a significant adverse effect due to increase in road traffic noise at receptors adjacent to the A27 road corresponds with a doubling traffic flow (3 dB increase in noise).



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Based on the expected vehicle movements given above, flows on the A27 are not expected to increase by 1,300 vehicles per day and therefore no significant adverse effects are anticipated.

14.5.2.3 Permanent Noise Impacts from Rail Traffic during Operation

The operation of the Project is expected to generate at least four additional rail movements per day: two for the delivery of propane and two for the export of polypropylene pellets additional rail movements. These will pass through Karabatan Station on a new rail spur which will be at a minimum distance of 30 metres from residential receptors.

Given that 23 rail movements currently pass through Karabatan Station each day, the addition of four movements per day would not generate a large increase in rail noise. It is concluded that permanent noise impacts from rail traffic during operation are not expected to result in significant adverse effects. It is assumed the rail movements associated with the Project are not noisier than the existing types of rail traffic.


Specific details on decommissioning are not available at this stage. However, impacts during decommissioning are expected to be of a similar magnitude to those during construction but of shorter duration. Therefore, temporary impacts due to general site activities and road traffic in decommissioning the Project site are also expected to be negligible.


Permanent noise impacts due to the Project are expected to occur in combination with other developments within the IPC.

The area of the entire IPC (including the Project) is 6,981,000 m2 and, using Equation 1, the estimated overall sound power level for the site is given as 133.4 dB(A). Table 14.12 summarises the results of the noise calculations using the acoustic model.

Table 14.12: Predicted cumulative noise impacts due the operation of fixed plant within the IPC

Receptor

Noise level from the IPC Leq dB(A) (free

field ) Magnitude of impact

daytime Magnitude of impact night

time

Karabatan Station 27 Negligible Negligible

Burial site 34 Negligible Negligible

The results show that operational noise levels are expected not to exceed 45 dB(A) at all sensitive receptors and therefore the magnitude of cumulative impacts due to the IPC is assessed as negligible in all cases.



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The cumulative operational noise impacts of the IPC are assessed in terms of the IFC guidelines (see Table 14.2). The results are presented in Table 14.13 and show that: Operational noise impacts at the Karabatan Station and burial site due to the IPC are below the 55

dB(A) and 45 dB(A) guideline levels for daytime and night-time respectively Noise from the IPC is not expected to result in a change in ambient noise levels at any of the existing

sensitive receptors.

Table 14.13: Assessment of operational impacts of the IPC against IFC guidelines

Receptor

Noise level from the IPC Leq dB(A) (free

field) Baseline Leq dB(A)

(free field )

Ambient during construction

Change in ambient due to the operation of the PP/PDH plant

Karabatan Station 27 54 54 0

Burial site 34 50 50 0


14.7.1 Construction and Decommissioning Phases

The assessment has indicated that the noise impacts during the construction and decommissioning phases are not expected to be significant at all offsite sensitive receptors. Therefore no specific additional requirements for mitigation have been identified by this assessment, which assumes that basic measures to minimise noise impacts from construction will be applied as a matter of course. The application of best practicable means of noise and vibration control is expected for the purposes of minimising the exposure of the workforce with regard to risks of potential hearing damage in the workplace.

General methods for the control of noise include the following: The selection of low noise plant and equipment; Plant and equipment to be examined on a daily basis for defects prior to the start of works and under

no circumstances should defective plant be used; Avoid unnecessary revving of engines; Plant and equipment to be switched off when not in use; Noisy activities to be limited to daytime working hours where possible; Plant and equipment to be positioned as far as possible from sensitive areas; Location of static plant to take advantage of any screening to break the line of sight from receptors; and Site operatives to be briefed in keeping noise to a minimum.

Noise from construction traffic can be mitigated as follows: Limit vehicle speeds on site; Traffic on site should be managed to avoid the need to queue up or wait with engines running; Sensitive routing of vehicles and selection of site access points to avoid disturbance of the community;

and



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Maintain site tracks to minimise discontinuities in the road surfaces ad avoid body slap noise from heavy vehicles.

More detailed guidance is provided within BS 5228 – 1:2014.

14.7.2 Operational Noise

The assessment has indicated that the noise impacts during the operational phase are not expected to be significant at all offsite sensitive receptors. Therefore no specific additional requirements for mitigation have been identified by this assessment beyond ALARP which is required to minimise risks of exposure to occupational noise.


The assessment is summarised in Table 14.14 and indicates that all residual impacts are expected to have no significant adverse effects.





Construction Temporary noise impacts from general construction activities at all sensitive receptors

High Negligible Insignificant Best practicable means of noise and vibration control

Insignificant

Temporary noise impacts from road traffic at all residential receptors adjacent to the A27 road

High Negligible Insignificant Avoiding or minimizing project transportation through community areas recommended within IFC Guidelines

Insignificant

Temporary noise impacts from rail traffic at all residential receptors adjacent to the new rail spur at Karabatan Station

High Negligible to Minor

Insignificant assuming the existing frequency of rail movements will not double

No specific requirement beyond best practice maintenance of rail infrastructure

Insignificant

Operation Permanent noise impacts from fixed plant at all sensitive receptors

High Negligible Insignificant ALARP required for occupational noise

Insignificant

Permanent noise impacts from road traffic at all residential receptors adjacent to the A27 road

High Negligible Insignificant Avoiding or minimising project transportation through community areas recommended within IFC Guidelines

Insignificant

Permanent noise impacts from rail traffic at all residential receptors adjacent to the new rail spur at Karabatan Station

High Negligible to Minor

Insignificant assuming the existing frequency of rail movements will not double

No specific requirement beyond best practice maintenance of rail infrastructure

Insignificant

Decommissioning Temporary noise impacts from general decommissioning activities at all

High Negligible Insignificant Best practicable means of noise and vibration control

Insignificant



Activity Potential Impacts Sensitivity Magnitude Impact Significance Mitigation Residual Impacts sensitive receptors



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15.1 Introduction

1.1.1 Overview

This section identifies potential emissions of greenhouse gases (GHG) associated with the operation of the Project.

1.1.2 Rationale

Since pre-industrial times, atmospheric concentrations of carbon dioxide (CO2) have increased by 40 percent to 391 parts per million (ppm) in 2011. Over a period from 1880 to 2012, global average surface temperatures increased by 0.85°C. In 2013, the Intergovernmental Panel on Climate Change Working Group 1 released its 5th Assessment Report. The summary report for policymakers stated that “warming of

the climate system is unequivocal” and that “it is extremely likely that human influence [in the form of greenhouse gas emissions] has been the dominant cause of the observed warming since the mid-20th century”.

CO2 is the most prevalent greenhouse gas in the atmosphere and consequently the greatest driver of the greenhouse effect and climate change. However it is not the most effective gas at trapping outgoing long-wave radiation on a unit-mass basis. Other anthropogenic greenhouse gases include methane (CH4) and nitrous oxide (N2O). In typical greenhouse gas accounting procedures, the amount of each greenhouse gas is normalised according to its “Global Warming Potential” - an equivalent mass of CO2 which would have the same warming effect. The sum total of greenhouse gases is commonly expressed in units of CO2-equivalent (CO2e).

The United Nations Framework Convention on Climate Change (UNFCCC) in 1992 was the first international treaty on the subject. Its objective was to “stabilise greenhouse gas concentrations at a level

that would prevent dangerous anthropogenic interference with the climate system”. Although legally non-binding, it did establish a framework for the later, legally-binding, Kyoto Protocol.

1.1.3 General approach

The greenhouse gas emissions of this Project have been assessed with reference to a number of international lenders’ standards and guidelines. Section 15.2.1 outlines the relevant standards and guidelines and the requirements they place on the Project with regard to greenhouse gases.

1.1.4 Scope

This assessment considers direct (scope 1) emissions of greenhouse gases as well as indirect emissions which arise through the purchase of electricity from the associated facilities of the IPC (scope 2). Other indirect sources of emissions (scope 3) have not been considered in this assessment as they were not necessary to fulfil the lenders’ standards and guidelines outlined in section 15.2.1.

15 Greenhouse Gas



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Direct emissions (scope 1) are emissions from sources owned or controlled by the reporting entity. Indirect emissions are emissions that are a consequence of activities which occur at sources owned or controlled by another entity. Indirect emissions from the consumption of purchased heat, electricity, or steam, are referred to as scope 2 emissions. Other indirect emissions are referred to as scope 3 emissions and include emissions associated with the manufacture of materials and waste disposal, among other sources.

Table 15.1 identifies the potential Project emission sources and whether they have been quantified in this assessment. Two fuel sources are combusted for energy in the Project: natural gas and recovered process off-gas. Direct emissions occur when carbon in both fuels is converted to CO2 in the combustion process. The Project has been designed to maximise its energy efficiency and minimise CO2 emissions from combustion activities. Section 3.5 presents analysis review of the key design features being implemented on the Project and makes a comparison to other potential options in terms of greenhouse gas emissions. The review indicates that the design and fuel choice have, where possible, minimised greenhouse gas emissions in accordance with international requirements.

Fugitive emissions refer to the unintentional loss of gas to the atmosphere during the process, for example, through leakage. Refrigerant emissions refer to the leakage of refrigerant gases in the cold storage of propylene, many of which are also greenhouse gases. The use of electricity leads to the indirect emissions of GHG from the combustion of fossil fuels at the power plants where it is produced.

Table 15.1: Sources of Emissions Identified and Quantified in the Assessment

Emissions source Type of emission Quantified in assessment?

PDH reactor heater / boiler Direct (scope 1) – combustion Yes

PDH gas turbines Direct (scope 1) – combustion Yes

Regeneration air heater Direct (scope 1) – combustion Yes

Auxiliary components Direct (scope 1) - combustion Yes

Fugitive emissions to flare Direct (scope 1) – fugitive No*

Refrigerant gas leakage Direct (scope 1) – refrigerant No*

Purchase of electricity Indirect (scope 2) Yes

* Total emissions from the flare and refrigerant gas leakage are expected to be insignificant when compared to the other sources. As a result, they have not been quantified in this assessment.

Emissions which result from the construction and decommissioning of this Project have not been considered in this assessment. They are not expected to be significant when compared to operational emissions over the lifetime of the Project and consideration of these emissions is not required by the lenders’ guidelines (Section 15.2.1).



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15.2.1 International Standards and Guidelines

1.1.4.1 Equator Principles54

Principle 10: Reporting and Transparency states: “The client will publicly report GHG emission levels (combined scope 1 and scope 2 emissions) during

the operational phase for Projects emitting over 100,000 tonnes of CO2 equivalent annually”.

Annex A: Quantification and Reporting provides more detail and states: “Quantification of GHG emissions will be conducted by the client in accordance with internationally

recognised methodologies and good practice, for example, the GHG Protocol.” “The client [is required] to report publicly on an annual basis…Public reporting requirements can be

satisfied via regulatory requirements for reporting or environmental impact assessments, or voluntary reporting mechanisms such as the Carbon Disclosure Project, where such reporting includes emissions at the Project level.”

1.1.4.2 IFC Performance Standards55

The need to consider greenhouse gas emissions is outlined in IFC Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts (paragraph 7): “The risks and impacts identification process will consider the emissions of greenhouse gases, the

relevant risks associated with a changing climate, and the adaptation opportunities…”

IFC Performance Standard 3: Resource Efficiency and Pollution Prevention (paragraph 8) details the assessment requirements. “For projects that are expected to or currently produce more than 25,000 tonnes of CO2-equivalent

annually, the client will quantify direct emissions from the facilities owned or controlled within the physical project boundary, as well as indirect emissions associated with the off-site production of energy used by the project. Quantification of GHG emissions will be conducted by the client annually in accordance with internationally recognised methodologies and good-practice.”

Notes to paragraph 8 of Performance Standard 3 state that: “The quantification of emissions should consider all significant sources of greenhouse gas emissions”. “Estimation methodologies are provided by the Intergovernmental Panel on Climate Change, various

international organisations, and relevant host country agencies.”

54 The Equator Principles. June 2013. http://www.equator-principles.com/resources/equator_principles_III.pdf. (Accessed

30/05/2014). 55 International Finance Corporation (IFC). 2012. IFC Performance Standards on Environmental and Social Sustainability.

http://www.ifc.org/wps/wcm/connect/c8f524004a73daeca09afdf998895a12/IFC_Performance_Standards.pdf?MOD=AJPERES (Accessed 30/05/2014).



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1.1.4.3 World Bank EHS Guidelines56

The World Bank publishes a series of Environment, Health and Safety Guidelines and these have been considered in this assessment. As noted previously, of relevance to this Project are the General EHS Guidelines (2007), EHS Guidelines for Large Volume Petroleum-Based Organic Chemical Manufacturing (2007), and EHS Guidelines for Petroleum-Based Polymers Manufacturing (2007). These guidelines do not set out any specific requirements for the assessment and reporting of greenhouse gas emissions.

1.1.4.4 EBRD Environment and Social Policy57

The EBRD Environmental and Social Policy (2014) sets out in Performance Requirement 3: Resource Efficiency and Pollution Prevention and Control that: “For projects that currently produce, or are expected to produce post-investment, more than 25,000

tonnes of CO2-equivalent annually, the client will quantify these emissions in accordance with EBRD Methodology for Assessment of Greenhouse Gas Emissions. The scope of GHG assessment shall include all direct emissions from the facilities, activities and operations that are part of the project or system, as well as indirect emissions associated with the production of energy used by the project. Quantification of GHG emissions will be conducted by the client annually and reported to EBRD”.

The EBRD Methodology for Assessment of Greenhouse Gas Emissions (2010) establishes a number of emissions categories as part of its assessment screening process. Petrochemicals manufacturing is estimated to fall within the medium-high category (100kt to 1Mt CO2e per year) and therefore requires an assessment of greenhouse gas emissions.

1.1.4.5 JBIC58

JBIC Guidelines for Confirmation of Environmental and Social Considerations were reviewed; however the guidelines do not have requirements for the assessment and reporting of greenhouse gas emissions.

1.1.4.6 OECD Common Approaches59

One rationale behind the OECD Common Approaches is: “…the responsibility of members to implement the commitments undertaken by the Parties to the

United Nations Framework Convention on Climate Change.”

56 International Finance Corporation (IFC). Environmental, Health, and Safety Guidelines.

http://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/IFC+Sustainability/Sustainability+Framework/Environmental,+Health,+and+Safety+Guidelines/ (Accessed 30 May 2014).

57 European Bank for Reconstruction and Development (EBRD). 2014. Environmental and social policy. http://www.ebrd.com/downloads/research/policies/esp-final.pdf (Accessed 30 May 2014).

58 Japan Bank for International Cooperation (JBIC). 2012. Guidelines for confirmation of environmental and social considerations. http://www.jbic.go.jp/wp-content/uploads/page/efforts/environment/confirm_en/pdf_01.pdf (Accessed 30 May 2014).

59 Organisation for Economic Cooperation and Development (OECD). 2012. The Common Approaches. http://search.oecd.org/officialdocuments/displaydocumentpdf/?cote=tad/ecg(2012)5&doclanguage=en (Accessed 30 May 2014).



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Section IV: Classification (paragraph 10) states: “Members should identify the potential positive and negative environmental and social

impacts…including greenhouse gas emissions”.

Section VIII: Reporting and Monitoring of the Recommendation (paragraph 42) states: “Report projected annual emissions during the operations phase of projects in CO2-equivalent…where

such emissions are projected to be in excess of 25,000 tonnes CO2-equivalent annually”.

15.2.1.1 United Nations Framework Convention on Climate Change (UNFCCC)

Kazakhstan signed the UNFCCC60 on 8 June 1992, ratified the UNFCCC on the 17 May 1995, and the UNFCCC entered into force on 15 August 1995.

Kazakhstan was originally a non-Annex I party to the UNFCCC. However, at the 2001 Conference of the Parties the country was allowed to enter Annex I for the purposes of the Kyoto Protocol following its request. Annex I countries are industrialised countries that are required to develop national policies for the mitigation of climate change by reducing greenhouse gas emissions (see below).

15.2.1.2 Kyoto Protocol

Kazakhstan signed the Kyoto Protocol61 to the UNFCCC on 12 March 1999, ratified the Kyoto Protocol on 19 June 2009, and the Kyoto Protocol entered into force on 17 September 2009. Under the original text of the Kyoto Protocol, Kazakhstan did not have any emissions reductions targets to achieve. This was because of its original status as a non-Annex I country to the UNFCCC62.

The Doha Amendment to the Kyoto Protocol, agreed by the Parties involved, set a commitment for Kazakhstan to achieve a 5% reduction in emissions over the period 2013-2020 against emissions in the baseline year 199063.

1.1.4.7 Summary

To satisfy the requirements of the lenders’ guidelines, the assessment should: Quantify and publicly report emissions on an annual basis for projects which emit more than

25,000 tCO2e per year;

60 United Nations Framework Convention on Climate Change. Parties and observer states: Kazakhstan.

http://maindb.unfccc.int/public/country.pl?country=KZ (Accessed 30/05/2014). 61 Kyoto Protocol to the United Nations Framework Convention on Climate Change. 1998.

http://unfccc.int/resource/docs/convkp/kpeng.pdf (Accessed 30/05/2014). 62 National Communication III-VI of the Republic of Kazakhstan to the United Nations Framework Convention on Climate Change.

http://unfccc.int/files/national_reports/annex_i_natcom_/application/pdf/kaz_nc3,4,5,6_eng.pdf (Accessed 30/05/2014). 63 Doha Amendment to the Kyoto Protocol. http://unfccc.int/files/kyoto_protocol/application/pdf/kp_doha_amendment_english.pdf

(Accessed 30/05/2014).



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Quantify significant direct emissions occurring within the project boundary and indirect emissions from the off-site production of electricity; and

Be in accordance with internationally recognised methodologies and good practice.

15.2.2 National legislation

The Ministry of Environment and Water Resources of Kazakhstan is responsible for developing and implementing government policies on environmental protection and management. This includes climate change issues. This Ministry was established in October 2013 and replaced the Ministry of Environment Protection.

The Ecological Code of the Republic of Kazakhstan64 is legislation for the protection of the environment and natural resources within Kazakhstan, and is the main legislation for regulating greenhouse gas emissions. Government responsibility for greenhouse gases is delegated onto the authorised body for environmental protection, the Ministry of Environment and Water Resources of Kazakhstan, who produce the UNFCCC National Communications.

The Code outlines the responsibility of the authorised body to establish procedures to restrict and reduce emissions of greenhouse gases to the atmosphere. The authorised body is responsible for maintaining a register and inventory of greenhouse gas emissions in Kazakhstan. Under the Code, the authorised body should also establish quotas for the maximum allowable discharges of greenhouse gases in the country.

On the reporting of emissions, the Code states that, “legal entities having sources and absorbents of

greenhouse gases shall, annually not later than the second quarter of the year following a reporting year, submit basic information required for the inventory…[of greenhouse gases]…to the authorised body”.

Information from this national inventory is to be recognised as public and is subject to publication.

15.2.3 Republic of Kazakhstan Emissions Trading Scheme

The Kazakh Emissions Trading Scheme65 was enacted in law on 3 December 2011 through an amendment to the Ecological Code. A pilot scheme began on 1 January 2013 with allowance surrender obligations imposed on 178 businesses, and the scheme officially began in January 2014. Companies that fail to surrender sufficient allowances each year are liable to a fine and criminal prosecution. The primary objective of the Emissions Trading Scheme is to meet Kazakhstan’s national emissions reduction target

which, under the Kyoto Protocol, is 5% over the period 2013-2020 against a 1990 baseline.

Sectors affected by the scheme include those in the oil, gas, and chemical industries. The first phase of the scheme (until 2020) applies to company reporting, but the intention of the scheme is to introduce reporting

64 Ecological Code of the Republic of Kazakhstan. 2007.

http://invest.gov.kz/upload/docs/en/323a08584fc35cf34230a6139a54d974.pdf (Accessed 30/05/2014). 65 International Emissions Trading Association (IETA). 2013. Kazakhstan: A case study guide to emissions trading.

http://www.ieta.org/assets/Reports/EmissionsTradingAroundTheWorld/edf_ieta_kazakhstan_case_study_september_2013.pdf. Accessed 30/05/2014).



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at an installation level after this. As noted by the World Banks’s recent review66, there are still a number of

practical details to be clarified in the scheme. The emissions threshold for inclusion in the scheme is 20,000 tonnes of CO2 per year. The scheme only covers emissions of CO2 at present; however it may be expanded to cover other greenhouse gases after the first phase. Based on this, it is likely that emissions resulting from this project will be included in the scheme and this is most likely to be through registration of the operator initially, and later at the individual installation level. (i.e. at first KPI will register and then at a later date the Project will be registered separately).


15.3.1 Overview

Operational emissions associated with the combustion of fuel, electricity consumption and the manufacturing process have been quantified in this assessment. The methodology used for this assessment is consistent with the EBRD Methodology for the Assessment of Greenhouse Gas Emissions and satisfies the requirements of the other lenders.

15.3.2 Calculation methodology

15.3.2.1 Direct emissions

Combustion of natural gas

Annual emissions which result from the combustion of natural gas in the on-site boilers and gas turbine have been quantified using the total volume of natural gas used per year. The formula below outlines the calculation used to calculate CO2 emissions.

(

) (

) (

)

Section 15.3.4 outlines assumptions which were made regarding the natural gas composition. From the composition of the fuel, the mass of the gas and the carbon content of the fuel were calculated.

Combustion of process off-gas

Emissions from the combustion of process off-gas were calculated using the same methodology and formula as for natural gas. Section 15.3.3.3 outlines the composition of the off-gas from the process.

Activity data (Section 15.3.3.3) and the composition data were used to calculate the total quantity of carbon in the off-gas following the same approach as for natural gas as above. The off-gas is combusted as a

66 http://documents.worldbank.org/curated/en/2014/05/19572833/state-trends-carbon-pricing-2014



315

mixed fuel also containing some natural gas. The quantity of natural gas used was accounted for as part of the separate natural gas calculation above.

15.3.2.2 Indirect emissions

Annual emissions which arise from the consumption of purchased electricity were calculated using the following formula:

(

) (

)

As it is intended that all electricity used will originate from the gas-fired power plant located within the IPC, a bespoke electricity emissions intensity was calculated. To make this calculation, an assumption was made regarding the efficiency of the power plant which are outlined in section 15.3.4.3. The formula used to calculate the bespoke electricity emissions intensity was:

where A= efficiency (%), B= gross calorific value (kWh/kg), C = carbon content of fuel (tC/t fuel)

The emissions which result from using the emissions intensity of the IPC natural gas power station were then compared with results which used the emissions intensity of the Kazakhstan national grid. The grid emissions intensity is given in the baseline data in section 15.4.2.

15.3.3 Activity data

15.3.3.1 Fuel and electricity use

Fuel and electricity use is consistent with the project description set out in Section 2 and from other project documents, including the Front-End Engineering Design (FEED), Fuel Balance, and other process documents. Table 15.2 summarises the activity data used in this assessment.

Table 15.2: Activity data used in the greenhouse gas calculation

Emissions source Input Value Unit

PDH plant Natural gas usage

20,247(1) kg per hour

Auxiliaries

PDH plant Off-gas used for combustion 15,388(2) kg per hour

Electricity use Electricity requirement for normal operation

55(3) MW

Source: 1. Fuel balance document 24/04/2014, 2. Document 108184-1100-PR-006-0051-B00, 3. See Chapter 2, Project Description



316

15.3.3.2 Natural gas composition

Table 15.3 presents the composition of natural gas to be used in the Project. The gas is calculated to have a carbon content of 73.2%.

Table 15.3: Composition of natural gas for use as fuel

Constituent Formula % Mol

Methane CH4 94.609

Ethane C2H6 2.569

Propane C3H8 0.473

Butane N-C4H10 0.010

Butane I-C4H10 0.076

Pentane N-C5H12 0.022

Pentane I-C5H12 0.020

Hexane C6H14 0.073

Nitrogen N2 1.367

Carbon dioxide CO2 0.684

Source: Project note IPMT-IPCI-SSEC-PN-PRO-0162

15.3.3.3 Process off-gas composition

Table 15.4 and Table 15.5 present the composition of the off-gas which comes from parts of the process. The mixed fuel containing off-gas will be approximately 60% by weight recovered from the process with the remaining mass of this mixed fuel gas made up by natural gas. The combustion of this natural gas is accounted for in Section 15.3.3.2.

Table 15.4: Recovered off gas stream 1


Hydrogen H2 87.3

Nitrogen N2 3.5

Carbon monoxide CO 2.6


Methane CH4 5.0

Acetylene C2H2 0.0

Ethylene C2H4 0.6

Ethane C2H6 0.5

Propylene C3H6 0.2

Propane C3H8 0.2




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Table 15.5: Recovered off gas stream 2.


Hydrogen H2 9.2

Nitrogen N2 1.4

Carbon monoxide CO 1.6


Methane CH4 13.3

Acetylene C2H2 0.3

Ethylene C2H4 21.9

Ethane C2H6 49.8

Propylene C3H6 0.2

Propane C3H8 0.0


15.3.4 Assumptions

15.3.4.1 Operating hours

It was assumed that the plant would be in operation, at normal capacity, for 8,000 hours per year as stated in the project description (chapter 2).

15.3.4.2 Carbon fraction oxidised

It was assumed that 99.5% of the carbon in the natural gas supplied was oxidised in combustion67. This is in line with IPCC guidelines.

15.3.4.3 Electricity use

It was assumed that the electricity used by the Project is sourced from the natural gas power station built within the IPC. There is a connection to the Kazakhstan national grid, and it is assumed that this is a back-up alternative to electricity from the power station.

It was conservatively assumed that the power plant on the IPC site will generate electricity with an efficiency of 50%. This value was taken from IFC guidelines on thermal power plants68.

67 EBRD Methodology for Assessment of Greenhouse Gas Emissions. Version 7, 6 July 2010.

http://www.ebrd.com/downloads/about/sustainability/ghgguide.pdf (Accessed 30/05/2014). 68 International Finance Corporation (IFC). 2008. Environmental, Health, and Safety Guidelines: Thermal Power Plants.

http://www.ifc.org/wps/wcm/connect/dfb6a60048855a21852cd76a6515bb18/FINAL_Thermal%2BPower.pdf?MOD=AJPERES&id=1323162579734 (Accessed 30/05/2014).



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15.3.5 Assessment of impact significance

As described in Section 5 the criteria for determining significance are specific for each environmental and social aspect but generally for each impact the magnitude is defined (quantitatively where possible) and the sensitivity of the receptor is defined. Although effects of greenhouse gas emissions at the global scale are reasonably well understood, the complexity of the issue warrants a slightly different approach to the other environmental topics.

Greenhouse gas emissions are closely related to economic growth and this is taken account of in international political agreements such as the Kyoto Protocol. Developing nations with low emissions are afforded more scope to increase their greenhouse gas emissions, whereas the majority of developed nations are expected to reduce their emissions.

The relationship between emissions from an individual project and national or international greenhouse gas reduction targets is difficult to reconcile. This is due to the provisions for growth and development. For this reason, there are currently no published guidelines for determining the significance of project greenhouse gas emissions (beyond EBRD screening criteria for ESIAs discussed in Section 1.1.4.4).

Guidance notes for IFC Performance Standard 3 suggest methods of evaluating project greenhouse gas emissions. These are presented in Table 15.6. This guidance only suggests the presentation of the impacts; not how to assign significance.

In this assessment, criteria provided in the IFC guidance have been used to present the greenhouse gas emissions totals. However, no level of significance is attached to the emissions.

Table 15.6: Suggested IFC criteria for assessing GHG emissions impacts

IFC Criteria Comments

The project’s GHG emissions relative to the host country total national emissions to understand the magnitude of its own emissions.

Discussed in the relevant parts of this assessment.

The project’s GHG emissions performance relative to the good international practice performance / host country national average performance.

Where possible, comparison to metrics has been undertaken. However, the project has a complex set of inputs and output products and therefore establishing a suitable comparator for performance is not possible. In addition there is little information on national or regional performance or total emissions for this type of process. The impacts of the project have been quantitatively compared against EBRD screening categories but discussed further qualitatively.

The annual trend of the project’s GHG emissions performance over time to monitor deterioration from the originally designed performance.

This has been considered as part of the monitoring plan for the project and included within the ESMP.

Opportunities to further improve the project’s GHG emissions performance.

This has been considered in the mitigation section of this assessment. .

Note: The European Bank for Reconstruction and Development guidance suggests a similar set of evaluation criteria.



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15.4.1 UNFCCC National Reporting

Kazakhstan submitted National Communications 3-6 to the UNFCCC in 201369. Table 15.7 presents a summary of national emissions from 1990 to 2011. The largest source of greenhouse gas emissions in Kazakhstan is from energy supply (84.5% of gross emissions in 2011). Industrial processes accounted for 6.25% of gross emissions in 2011. Net emissions of Kazakhstan fell by 23.8% between 1990 and 2011.

Table 15.7: GHG emissions in Kazakhstan by sector (MtCO2e)

Sources 1990 1995 2000 2005 2008 2009 2010 2011

% Difference

between 1990 and

2011

Energy supply 300 181 144 190 198 222 245 232 -22.6

Industrial processes 18 8 10 13 14 14 15 17 -4.2

Agriculture 38 23 15 19 21 22 22 21 -43.8

LULUCF -2 -7 -10 -3 -2 -2 -3 -3 42.8

Waste 3 3 3 3 4 4 4 4 48.4

Total emissions minus removals by LULUCF (net emissions)

356 208 162 223 235 259 283 271 -23.8

Total emissions excluding removals by LULUCF (gross emissions)

358 215 172 226 237 262 286 274 -23.4

Source: National Communication III-VI of the Republic of Kazakhstan to the United Nations Framework Convention on Climate Change. LULUCF refers to Land Use, Land Use Change, and Forestry. This refers to emissions, or emissions removals, which result from land use practices. These include, for example, deforestation, afforestation, and reforestation. Changes through LULUCF are accounted for in Kyoto Protocol emissions targets70.

The national communication included a breakdown of emissions occurring in industrial processes. Values given for industrial process emissions were in units of CO2 and not directly comparable to CO2e. In 2011, emissions from industrial processes were 15.0 MtCO2. Of this, 0.3 MtCO2 (1.8%) was due to the chemical industry.

69 National Communication III-VI of the Republic of Kazakhstan to the United Nations Framework Convention on Climate Change.

http://unfccc.int/files/national_reports/annex_i_natcom_/application/pdf/kaz_nc3,4,5,6_eng.pdf (Accessed 30/05/2014). 70 United Nations Framework Convention on Climate Change. Land Use, Land Use Change, and Forestry (LULUCF).

https://unfccc.int/methods/lulucf/items/3060.php (Accessed 04/06/2014).

https://unfccc.int/methods/lulucf/items/3060.php



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15.4.2 Emissions Intensity of Electricity Generation

Table 15.8 presents the emissions intensity of electricity produced in Kazakhstan over a five year period. In the latest available year, 2011, the emissions intensity was 431gCO2/kWh71. This is lower than the worldwide average emissions intensity (536gCO2/kWh)71.

Table 15.8: Emissions intensity of electricity produced in Kazakhstan

Year 2007 2008 2009 2010 2011

Emissions intensity (gCO2/kWh) 683 566 441 409 431

Source: IEA Statistics. CO2 emissions from fuel combustion 2013: highlights.

In 2011, 81.1% of Kazakhstan’s domestic electricity production came from coal. A further 9.2% came from

hydropower, and 9.1% came from natural gas. The remaining 0.6% came from oil72. The emissions factor in Table 15.8 is relatively low for the high proportion of coal. This is due to the use of coal in combined heat and power (CHP) plants in Kazakhstan, which have a relatively high efficiency.


Table 15.9 presents the calculated direct emissions of CO2 which will occur annually during the operation of the Project. This result is based on activity presented in section 15.3.3 and on the methodology given in section 15.3.2.1.

Table 15.9: Annual Direct Emissions of CO2

Source GHG emissions (tCO2/yr)

Combustion of natural gas (boilers and turbine) 432,331

Combustion of process off-gas 115,031

Total 547,362

Table 15.10 presents the calculated annual indirect emissions of CO2 which will occur during the Project’s

operation. This result is derived from inputs presented in section 15.3.3 and on the methodology given in section 15.3.2.2. It is based on a calculated emissions intensity of the IPC power plant of 363gCO2/kWh.

Table 15.10: Annual Indirect Emissions of CO2

Source GHG emissions (tCO2/yr)

Electricity use 159,673

Total 159,673

71 IEA Statistics. CO2 emissions from fuel combustion 2013: highlights.

http://www.iea.org/publications/freepublications/publication/CO2EmissionsFromFuelCombustionHighlights2013.pdf. (Accessed 30/05/2014).

72 IEA Statistics. Kazakhstan: Electricity and Heat for 2010. http://www.iea.org/statistics/statisticssearch/report/?country=KAZAKHSTAN&product=electricityandheat&year=2010 (Accessed 30/05/2014).



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If the result was repeated using the average emissions intensity of electricity in Kazakhstan (431 gCO2/kWh in 2011), total indirect emissions would be 189,640 tCO2/yr, an increase of 29,967tCO2/yr.

Table 15.11 presents the total emissions of CO2 which will occur during the Project’s operation.

Table 15.11: Emissions of CO2 which will occur during the Project’s operation

Type Source GHG emissions (tCO2/yr)

Direct Combustion of natural gas 432,331

Direct Combustion of process off-gas 115,031

Indirect Electricity use 159,673

Total emissions 707,036

Total emissions from the Project are expected to be 707,036 tCO2 per year. This is equivalent to 0.26% of total annual emissions in Kazakhstan. Emissions are equivalent to 0.30% of annual energy supply emissions in Kazakhstan.


The site is located within the IPC where additional areas are designated for the development of the ethylene, polyethylene, butadiene and polymer production plants. Each of these will contribute to emissions of greenhouse gases. At the present time the emissions from these developments cannot be quantified since the size and nature of these facilities is not known; at a later stage such a quantification may be possible.

However, unlike other environmental impacts, the cumulative GHG emissions from a specific collection of plant is not meaningful, since the majority of these emissions would occur regardless of whether they are sited within the IPC or elsewhere, especially as the developments are not inter-dependent. It is more appropriate to consider the cumulative impact of development in the context of a given project’s national

emissions. This cumulative impact has been presented in the above assessment.

Notwithstanding this an element of cumulative impact has been implicitly accounted for in the assessment by virtue of the potential for electricity supply to be provided by the power generated at plant within the IPC and the resulting emissions associated with this power have been included in the total impact for this project. There are also possible efficiencies associated with co-locating industrial processes of this kind, though, for example, the potential to share infrastructure and/or the possibility of using outputs from one process as the inputs to another (although all development will be designed to operate in a stand-alone capacity).


There are a number of mitigation measures which will avoid or reduce greenhouse gas emissions. These are listed in Table 15.12.



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Table 15.12: Possible mitigation measures

Type of emission Description

Direct - combustion The plant will likely be required to participate in the national Emissions Trading Scheme. This will encourage the plant to maintain high levels of efficiency. A monitoring and management system will be required to ensure compliance with the requirements of the scheme. The operator should consult with the Ministry of Environment and Water Resources to understand the process of being included in the Scheme and should also make sure they have the required staff capacity to comply with the scheme.

Direct – fugitive The management of fugitive emissions of propane and fuel gas using best-practice maintenance techniques has been included in the Project design. This includes directing fugitive emissions to the on-site flare, which reduces emissions compared to an uncontrolled release of gas. These practices should be regularly reviewed to ensure adherence and systems regularly maintained.

Indirect Electricity usage is the largest source of operational emissions in the Project. Energy efficiency measures should be implemented where possible to reduce usage of electricity.

The emissions intensity of electricity from the IPC power plant is significantly lower than Kazakhstan grid-average electricity. During normal operation, the IPC power plant is expected to supply the Project’s electricity needs. However, a link to the Kazakhstan electricity grid is available. The use of electricity from the grid should be minimised as much as practicable.

Monitoring Monitoring of greenhouse gas emissions during the Project’s operation should be conducted by an appropriately trained person and carried out using a best-practice technique. This technique should follow an internationally-recognised methodology and meet the requirements of the relevant lenders’ standards in section 15.2.1. A methodology statement should be created and a proper record-keeping procedure adopted throughout.

A process should be in place to capture data related to accidental releases of propane and fuel gas. On review, if these releases are found to be significant, the scope of the greenhouse gas reporting should be extended to include these.

Monitoring data should be collected, analysed, and reviewed periodically outside of the formal reporting process. This is intended to allow for corrective actions to be taken, and for data quality to be checked.

15.8 Summary

This assessment has quantified the greenhouse gas emissions which will result from the Project’s

operation. The significant sources of emissions identified were natural gas combustion, combustion of process off-gases, and indirect emissions from the consumption of purchased electricity.

Total emissions from the project are expected to be 707,036 tCO2 per year. This is equivalent to 0.26% of total annual emissions in Kazakhstan. These emissions are equivalent to 0.30% of annual energy supply emissions in Kazakhstan.



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16.1 Introduction

This section describes the potential impacts of the construction and operation of the Project upon known and potential Cultural Heritage aspects of the area and sets out the proposed mitigation in order to minimise the impact of the Project upon the cultural heritage resource.

An assessment of the impact of the Project on identified cultural heritage resources, addressing direct impacts on cultural heritage assets (disturbance or destruction through construction/excavation) and indirect impacts (setting and pollution at tangible cultural heritage sites or loss/damage to intangible forms of culture) has been undertaken.



Provision for the protection of Cultural Heritage is accounted for within the Constitution of the Republic of Kazakhstan. In particular, Article 37 states: ‘Citizens of the Republic of Kazakhstan shall be obliged to care for the preservation of historical and cultural heritage, to protect historical and cultural monuments.’

Main legal documents that regulate cultural heritage protection and preservation are following: Law № 1488-XII “On protection and use of historical and cultural heritage” of the Republic of

Kazakhstan dated July 2, 1992 (as amended of 13.01.2014). “Rules for determining the security zones, construction control zones and zones of protected natural

landscape for the historical and cultural heritage and their patterns of use” approved by the

Government Decree No. 1218 dated October 28, 2011. “Concept for the protection and development of the intangible cultural heritage in the Republic of

Kazakhstan” approved by the Government Decree No. 408 dated April 29, 2013. “State list of historical and cultural monuments of local importance of Atyrau Region” approved by

Atyrau City Akimat Decree No. 299 Dated November 23, 2010.

16.2.2 International Finance Corporation Standards

The development of the Project should comply with IFC Performance Standard 8: Cultural Heritage 2012. Performance Standard 8 aims to ‘preserve and protect cultural heritage by avoiding, reducing, restoring, where possible, and in some cases compensating for the adverse impacts that projects might cause to cultural heritage’ (IFC 2012) and recognizes the importance of cultural heritage for current and future generations. Consistent with the Convention Concerning the Protection of the World Cultural and Natural Heritage, this Performance Standard aims to ensure that clients protect cultural heritage in the course of their project activities.

16 Cultural Heritage



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16.2.3 European Bank for Reconstruction and Development Standards

The development should also comply with the EBRD Performance Requirement 8: Cultural Heritage 2014. Performance Requirement 8 aims to ‘protect irreplaceable cultural heritage and to guide clients to avoid or mitigate adverse impacts on cultural heritage in the course of their business operations.’ (EBRD 2014).

The Bank also supports a precautionary approach to the management and sustainable use of cultural heritage in line with the Rio Declaration on Environment and Development.


This chapter is written in line with the International Finance Corporation (IFC) Performance Standard 8 Cultural Heritage 2012. The baseline data is based on information from an ethnographic and archaeological survey of the land plot allocated for construction of the Integrated Gas-Chemical Complex by specialists of Atyrau Museum of the Regional Studies and History. In addition data has been collated from the following sources: UNESCO online database of World Heritage Sites; and Published and unpublished (grey literature) articles.

16.3.1 Spatial and Temporal Scope of Assessment

The area of influence will encompass the (i) primary project site and related facilities that the client (including its contractors) develops or controls, such as power transmission corridors, access roads and construction camps (ii) areas potentially impacted by cumulative impacts from further planned development of the project and (iii) areas potentially affected by impacts from unplanned but predictable developments caused by the project that may occur later or at a different location. The area of influence does not include potential impacts that would occur independently of the project.

Risks will be analysed for key stages of the project cycle including pre-construction, construction, operations and decommissioning or closure.

16.3.2 Impact assessment criteria

An assessment of the significance of impacts with regards to cultural heritage and archaeology has been made for the construction and operational phases of the Project. The significance of potential impacts is a function of the presence and sensitivity of archaeological receptors, and the magnitude (duration, spatial extent, reversibility, likelihood and threshold) of the impact.

16.3.2.1 Sensitivity criteria

The sensitivity of the archaeological potential for a site is presented in Table 16.1



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Table 16.1: Criteria of Value

Sensitivity

High Sites of the highest importance, e.g. World Heritage Sites (including nominated sites), assets of acknowledged international and/or national importance and assets that can contribute significantly to acknowledged international research objectives

Medium Undesignated archaeological sites; well preserved structures or buildings of historical significance, historic landscapes or assets of a reasonably defined extent and significance, or reasonable evidence of occupation / settlement, ritual, industrial activity.

Low Comprises undesignated sites with some evidence of human activity but which are in a fragmentary or poor state or assets of limited historic value but which have the potential to contribute to local research objectives, structures or buildings of potential historical merit

Negligible Historic assets with very little or no surviving archaeological interest or historic buildings and landscapes of no historical significance.

16.3.2.2 Magnitude criteria

The degree or magnitude of effect is determined through consideration of the nature, scale and extent of effect. The criteria for determining magnitude are presented in Table 16.2

Table 16.2: Magnitude Criteria

Magnitude

Major Severe damage or loss of the cultural heritage resource

Moderate A high proportion of the cultural heritage resource damaged or destroyed

Minor A small proportion of the cultural heritage resource damaged or destroyed

Negligible The cultural heritage resource will not be affected, because of distance from the development, or method of construction

16.3.2.3 Significance

The significance of the effect is dependent upon the importance of particular site and the amount of potential damage. Table 16.3 presents the manner in which the significance of impacts is determined by the interaction between the magnitude of impacts and the sensitivity of receptors affected. Moderate or major effects are considered to be significant.

Table 16.3: Level of Significance

Magnitude of Impact

Sensitivity of Receptors

Negligible Low Medium High

Negligible Insignificant Insignificant Insignificant Insignificant

Minor Insignificant Slight / Minor Minor Minor

Moderate Insignificant Minor Moderate Moderate

Major Insignificant Minor Moderate Major



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16.4.1 Site location

The site is located within the Caspian Depression, a large flatland area that encompasses the northern part of the Caspian Sea.

16.4.2 Archaeological and Historical Background

16.4.2.1 Ethnographic and archaeological assessment and survey

An ethnographic and archaeological assessment and survey73 has been undertaken for the wider IPC site in which the proposed Project will be located. This report provides a regional, national and local archaeological and historical baseline.

The proposed development is located within an area formerly part of the Caspian Sea which regressed approximately eight to sixteen thousand years ago, forming a flat area of land, covered by salt pans.

There is evidence for early Stone Age communities which were hunting and breeding livestock from the third to first millennium BC in the wider region. The archaeological evidence of this period includes stone tools and burial sites. The evidence from historical sources would suggest that there were numerous tribes during the Stone Age period which is reflected by different material culture.

The Atyrau region is famous for its late Stone Age settlements dating to the fourth to second centuries BC. These were peripatetic communities largely based on fishing. On this basis there is a reasonable assumption that the settlements and hunting activity of the late Stone Age was located around water sources (away from the IPC).

In the area of the proposed development there is poor preservation of archaeological evidence relating to these ancient cultures. This is partly due to the lack of good construction material such as wood and stone. There is recent archaeological research that proves that the Stone Age tools made of silicon are preserved in areas to the north and east of the Caspian Sea (Z.S.Samashev, BKAE L.L.Galkin, The Institute of Archaeology of the Academy of Sciences of Kazakhstan).

During the Bronze Age Kazakhsatan was populated by nomadic communities. The region in which the proposed development is located has had a lack of research into these communities but this is unlikely to mean a lack in archaeological resource. The period is characterised by barrows (burial mounds) which are attributed to the Savromatians, Sarmatians and Massageteans cultures who lived in the second half of the first millennium BC. The mounds are often constructed in local stone and are found across the country.

73 Kassenov M.S, Ethnographic and archaeological survey at the land plot allocated for construction of Integrated Gas-Chemical

Complex of Atyrau Oblast on the territory of Karabatan settlement (Kazakhstan Petrochemical Industries Inc. LLP, 2013)



327

In the early Middle Ages this territory was interchangeably occupied by the Alans, Huns, Khazars and Kipchaks tribes. Little previous study has been undertaken for this period for Kazakhstan and the archaeological potential for this period is unknown.

In mid-13th century the lands of Western Kazakhstan were part of the Golden Horde (western sector of the Mongol Empire), under the reign of the empire of Genghis Khan, and his son Juchi Ulus and their descendants. During this period settlements, cities and caravanserais (road side inns) were constructed. Trade and economic relations between the East and the West were also strengthened with the creation of intercontinental caravan roads.

The most sizeable city erected in the time of the Golden Horde was Saraychik (45km east of the integrated petrochemical complex). The city considerably influenced the wider region and was a political, cultural and trade centre. Caravanserais and fortresses, as well as water wells were built along the roads to and from the city of Saraychik, in particular, the road that led from Saraychik to Khorezm (in modern day Uzbekistan). This road passed through the Ustyurt plateau (through the saline lands). In order to maintain these communications routes troops and workmen were station along it which attracted herders and fishermen into the area. Seasonal settlements composed of yurts, associated with herders and Caravan stop overs often by wells were located within the plateau, while sedentary settlements and homestead towns were scattered along the banks of the river Sokol (45km to the west of the IPC).

During the early 15th century the collapse of the Golden Horde led to the creation of new states. During this period the Nogay Horde took over control of the modern territory of Western Kazakhstan. The economy of the Nogay Horde was based around nomadic livestock breeding. The Nogay people migrated across the lands in between the Middle Povolzhye and the Aral Sea.

From mid-16th century, the territories of the Nogay Horde were pressed from the North by Russia and the Ural Cossacks and from the east by the Kalmyk tribes. During this period the nomadic Alshyn tribe occupied the former Nogay territories in Western Kazakhstan.

The above baseline information indicate that there was significant nomadic and sedentary settlement and associated farming actives within the region (in which the integrated petrochemical complex is located). None however has specifically been identified within or near the IPC.

As part of the survey and assessment74 a site walkover was undertaken of the area of the scheme and a test pit was excavated within the south west corner of the IPC. The walkover survey identified no historical or cultural remains. The test pit did not record any cultural heritage material.

16.4.2.2 Additional baseline data

An assessment of cultural heritage monuments of local value within the Autyran region identified the site of ‘Barrow Ran’ 58km to the south-west of the village of Dossor75, located potentially near the IPC. The site

74 Kassenov M.S, Ethnographic and archaeological survey at the land plot allocated for construction of Integrated Gas-Chemical

Complex of Atyrau Oblast on the territory of Karabatan settlement (Kazakhstan Petrochemical Industries Inc. LLP, 2013)



328

visit undertaken in April 2014 identified two cemetery sites and a burial site (potentially the barrow) located near the A27 road, 5km to the south of the Project site (Photo 16.1 and Figure 16.1).

Photo 16.1: Burial site located near the A27 road


75 Kazakhstan Petrochemical Industries Inc., Integrated petrochemical complex in Atyrau region, EIA Report, Project 108184-0001-

TTC/RK-OBOC (2013)



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Figure 16.1: Sensitive locations identified in preliminary scoping assessment.




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16.4.3 Conclusions and Key Gaps in Information and Uncertainties Regarding

Baseline Conditions

This archaeological baseline has been compiled using available information. The proposed Project and associated road and rail infrastructure is located within a wider landscape which is known to contain sites of cultural heritage importance. No evidence has been found that remains of international, national or local importance are present within the development area. However, there is little cultural heritage and archaeological data available specific to the area of the Project.


16.5.1 Construction

There will be no direct impact to known cultural heritage assets as none of the project infrastructure or construction activities will occur within 200m of any of the known cultural heritage features. There will also be no impact on the setting of the burial mound (monument of local value) and the two cemeteries.

There is potential for previously undiscovered archaeological remains (buried archaeology) of low value to be impacted by the preparatory site works. Ground clearance and ground levelling have been undertaken prior to the construction of the Project. These ground works have the potential to have a moderate impact on these remains and have a minor effect, which is not considered to be significant.

There is also potential for the construction of the foundations of the Project to have a moderate impact on the potential low value archaeological remains and have a minor effect which is not considered to be significant. Table 16.4 summaries the construction activities that have been identified as having a potential impact on cultural heritage.

16.5.2 Operation

It is envisaged that the operation of the Project will not impact the known or unknown archaeological remains and artefacts; should any be present, they will have been disturbed and removed during the construction phase. There will also be no operational impact on the setting of the burial mound (monument of local value) and the two cemeteries.

16.5.3 Decommissioning

Decommissioning of the Project will have no impact upon the cultural heritage resource because the activities associated with decommissioning will be confined to areas previously impacted during the construction phase of the Project.



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The ethylene, polyethylene plant, butadiene production plant and polymer production plant also form part of the wider IPC site. As with the Project there will be no direct impact to known cultural heritage assets as none of the project infrastructure or construction activities will occur within 200m of any of the known cultural heritage features. However, there is the potential for previously undiscovered low value archaeological remains (buried archaeology) to be impacted by the site works.


16.7.1 Abnormal/Emergency Conditions

As set out in the IFC Performance Standard 8: Cultural Heritage 2012, KPI and the EPC contractor or EPCM contractor are responsible for developing provisions for managing chance finds, which will be applied in the event that unexpected archaeological remains are encountered during the construction of the scheme. In the event that archaeological finds or features are identified during the course of works associated with construction groundworks, an emergency procedure will be required in order to stop work and allow for the assessment of the archaeological potential of the remains. Assessment must be carried out by a designated archaeological professional. If buried archaeological remains are of significance then a system will be put in place to mitigate harm. This may involve protecting the remains or a system to excavate and record the remains. Therefore, a chance finds procedure will be included within the Construction Environment Management Plan.


Following the implementation of the proposed mitigation measures, there are expected to be no residual impacts.





Construction Preparation of work site (Clearance and levelling of areas for the construction of the Propane Dehydrogenation and Polypropylene Plant)

Low

Moderate

Minor

Contractor to develop a chance finds procedure prior to works commencing that outline approach in accordance with this ESIA

Insignificant

Construction Foundation excavation for Propane Dehydrogenation and Polypropylene Plant

Low Moderate

Minor

Contractor to develop a chance finds procedure prior to works commencing that outline approach in accordance with this ESIA

Insignificant



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