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Saudi Aramco Environmental Monitoring Services

Saudi Aramco PMT

MARITIME YARD PROJECT DEPARTMENT

SAPMT-MYPD-2018-Q4-REP-001 | 0

01 November 2018

Saudi A ramco

Maritime Yard Project Environmental Compliance Monitoring

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Saudi Aramco Environmental Monitoring Services

Project No: SA222501

Document Title: Maritime Yard Project Department

Document No.: SAPMT-MYPD-2018-Q4-REP-001

Revision: 0

Date: 01 November 2018

Client Name: Saudi Aramco

Project Manager: Eddie Bradbrook

Author: Mahmoud Hashish

Jacobs, Zamel and Turbag Consulting Engineers Company (Jacobs ZATE)

Al Fanar Tower, Custodian of the Two Holy Mosques Road

Prince Humud Street

P.O. Box 981

Al-Khobar 31952

Kingdom of Saudi Arabia

T +966 13 898 9900

F +966 13 898 9911

www.jacobs.com

© Copyright 2018 Jacobs, Zamel and Turbag Consulting Engineers Company (Jacobs ZATE), a Saudi Arabian professional services partnership, is an affiliate of Jacobs Engineering Group Inc.. The concepts and information contained in this document are the property of JacobsZate. Use or copying of this document in whole or in part without the written permission of JacobsZate constitutes an infringement of copyright.

Limitation: This document has been prepared on behalf of, and for the exclusive use of JacobsZate’ client, and is subject to, and issued in accordance with, the provisions of the contract between JacobsZate and the client. JacobsZate accepts no liability or responsibility whatsoever for, or in respect of, any use of, or reliance upon, this document by any third party.

Document history and status

Revision Date Description By Review Approved

0 01 November 2018 Issued for Review MH EB EB


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Contents

1. Summary ............................................................................................................................................ 1

1.1 Overview & Scope .............................................................................................................................. 1

1.2 Environmental Compliance Critical Observations ............................................................................. 1

1.3 Inspection Schedule............................................................................................................................ 2

1.4 Environmental Compliance Criteria ................................................................................................... 2

1.5 Environmental Compliance Monitoring Dashboard ............................................................................ 2

2. Environmental Compliance Monitoring ........................................................................................... 6

Appendix A. Environmental Compliance Monitoring Photos


1

1. Summary

1.1 Overview & Scope

Inspection Overview

Project Site: Maritime Yard

Project Dept.

(MYPD)

Client

Representatives:

Amjad Shadid – Health, Safety & Environment

Coordinator

Date of

Inspection:

23rd - 24th October

2018

Inspection Team: Mahmoud Hashish, Abdullah AlGhanim and Calum

Campbell

Scope of

Environmental

Compliance

Monitoring:

Saudi Aramco PMT offices and compound, Maritime Yard Project Dept. (MYPD) construction

areas (platform, island, tuxedo area, finger jetty), SARCO vehicle inspection area, SARCO

steel and store yards, contractors’ offices and camps (i.e. HUTA/ARCHIRODON consortium)

were visited during the inspection.

The inspection covers the onshore project activities and facilities only. No offshore

inspection has been undertaken.

The objective of the Environmental Compliance monitoring is to evaluate the compliance of

the Project during the execution phase against the following Environmental requirements:

Land Use Permit (LUP) Conditions, Environmental Impact Assessment (EIA) Conditions,

Environmental Design Requirements, Construction Environmental Management Plan (CEMP),

Saudi Aramco Policies, Standards and Procedures, as well as Saudi Government

Environmental Regulations, Environmental Management System - EMS ISO 14001:2015 (as

applicable).

The concrete batching plant does not strictly fall under the contractual jurisdiction of

SAPMT, but it is known that primary contractors are utilizing this batching plant for the

project. For the purposes of reporting, the batching plant has been considered

independently and is reported separately in Section 2.

1.2 Environmental Compliance Critical Observations

Table 1 below describes the Major Non-Conformities for the project and the required Corrective Actions.

Note that the recommended Corrective Actions should be systematically implemented across the entire

project to achieve compliance.

The outstanding major non-conformity for the September visit (i.e. item 157) has been closed. No new major

non-conformities where recorded during Visit-1 of Quarter 4 (Q4.1).

Table 1: Major Non-Conformities for Maritime Yard Project and Required Corrective Actions

Ref Compliance Risk Required Action Reference Target Date Status

157 Unpermitted

discharge of

untreated

wastewater to

land

Review procedure for

monitoring and emptying

holding tanks during next

visit

No overflowing holding

tanks were observed in

the areas inspected.

MYPD EMS Manual

(Section 6), Saudi

Archirodon/Huta

Hegerfeld MYPD

Environmental

Management Plan

(Section 8); GERRI 2001

General Environmental

Regulations (Article 2);

SA Environmental

Protection Policy INT-5

4th Nov 2018 Closed


2

1.3 Inspection Schedule

Opening Meeting: 23rd October 08:30

Site Inspections: 24th October 07:00 – 09:30 (MYPD construction areas), 09:30 – 10:00 (contractors’

offices and camps (i.e. HUTA/ARCHIRODON consortium)), 10:00 – 10:30 (SARCO

vehicle inspection area), 10:30 – 11:30 (SARCO steel and store yards) and 14:00 –

14:30 (SAMPT Camp)

Interviews: SAMPT HSE coordinator (23rd October) HUTA/ARCHIRODON consortium EC (23rd

October) and Tamimi EC (24th October)

Close-out Meeting: 24th October 14:30

1.4 Environmental Compliance Criteria

The environmental compliance of the Project is defined using the criteria outlined in Table 2 Environmental

compliance is determined through; visual inspection, discussion and interviews with site representatives’ and

review of documentation associated with the Project.

Table 2: Compliance metrics, descriptions and associated risks

Colour

Code Compliance Description Associated Risks

Major Non-

Conformity

Non-compliance with national

legislation with potential for

significant environmental impact.

Potential for fine, penalty and/or

reputational damage. Immediate

corrective action should be taken.

Significant risk to the environment,

project schedule and cost due to

major non-conformity. Action to be

taken within 30 days.

Minor Non-

Conformity

Non-conformance against

environmental obligations (i.e. EIA,

CEMP, EMP) and Saudi Aramco

procedures or standards. Legal

non-compliance with potential for

minor significant environmental

impact.

Risk to the environment, project

schedule and project cost due to

minor non-conformity. Action to be

taken within 60 days.

Compliant

Compliance with environmental

obligations, national legislation,

Company standards. Best practice

recommendations are fully achieved.

No current risk to the environment.

No action required.

Observation

Considered to be compliant although

improvement required to achieve best

practice recommendations.

Alternatively, currently insufficient

evidence to determine compliance.

No immediate risk to the environment

although improvement recommended

within 90 days.

Not Inspected

Not inspected during visits to date.

Items that are not inspected are

prioritized for the next compliance

monitoring visit.

No action required. To be reviewed

following further compliance

monitoring visits.

1.5 Environmental Compliance Monitoring Dashboard

Figure 1 below provides the monthly overview of environmental compliance for the Maritime Yard Project

Department. The ring on the left indicates the status of all environmental items which are monitored and the


3

percentage (%) which have been inspected during Visit-1 of Quarter 4 (Q4.1). The ring on the right indicates

the % of compliance across the environmental items that were inspected (i.e. 91%), excluding items with

observations (i.e. compliant items (green) / compliant + minor non-conformities + major non-conformities

(green, amber, red) *100). Observations are excluded from this calculation as these are considered compliant

with room for improvement in best practice terms only or there is currently insufficient evidence to determine

compliance.

Figure 1: Current project compliance

A further breakdown of environmental compliance is provided across the twelve main environmental categories

in Figure 2 below. This breakdown assists with indicating where non-conforming conditions were observed and

shows where improvements or, in some cases, recent failures in compliance were recorded. Consequently, this

highlights the areas where further improvements are required.


5

Figure 2: Further breakdown of environmental compliance by category for Q4.1 (October 2018)

0

5

10

15

20

25

30

35

ManagementStructure,

Systems andAwareness

Air Quality Noise TerrestrialEcology

WasteManagement

Wastewater Soil &Groundwater

Fuels andChemicals

SpillManagement

ResourceManagement

Off-ShoreOperations

Batching Plant

Ap

plic

able

Co

mp

lian

ce I

tem

s

Compliance Category

Maritime Yard - Environmental Compliance - Q4.1

Minor non-conformity Observation Compliant


6

2. Environmental Compliance Monitoring

Item Compliance

Category Compliance Item

Reference Document

Compliance (Q3.3)

Observation (Q4.1) Action (Q4.1) Compliance

(Q4.1)

Management Structure, Systems and Awareness

1

Management Structure,

Systems and Awareness

Has a suitably qualified full-time Environmental Coordinator and backup been appointed for the project. This includes a suitably qualified SA PMT EC.

MYPD EIA (Section 9.4); MYPD EIA Section (Section 9.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8.1.9); MYDP EMS Manual (Section 6), EMS Manual

Minor non-

conformity

To achieve compliance with

Saudi Aramco’s corporate

objectives, a dedicated SA PMT

Environmental Coordinator

would be beneficial for the

project. This individual would

have oversight of all packages

with a sole responsibility for

environmental aspects of the

project.

Consider appointing a

dedicated and

appropriately qualified

Environmental

Coordinator.

Minor non-

conformity

2



Have EMPs been prepared and held on site?

MYPD EIA (Section 9.4); MYPD EIA (Section 9.5); Saudi Archirodon / Huta Hegerfeld; MYPD Environmental Management Plan (Section 1.3)

Compliant EMPs are held on site. None required. Compliant

3



Do EMPs contain EIA commitments and LUP conditions?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 19.1), LUP Attachment Letter

Compliant

Maritime Yard Project EPM has

been prepared based on

mitigation measures,

recommendations and findings

of the project EIA.

None required. Compliant


7

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

4



Are contact details for Environmental Coordinator communicated to staff?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)

Compliant

Contact details for HSE and EC

representatives were noted in

multiple locations visited across

the Project, including

noticeboards and emergency

contact registers.


5



Is there a clear hierarchy for environmental management on site?

MYDP EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)

Compliant

Hierarchy for environmental

management has been recorded

for SA PMT and primary

contractors inspected to date.


6



Is there an environmental policy and is this clearly communicated to staff and contractors (e.g. notice boards)?

MYPD EIA (Section 9.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 1.2); MYPD Environmental Management Plan (Section 15)

Compliant

Environmental

policy/information is posted on

HSE safety bulletin boards in

offices and across the site.


7



Have all staff attended HSE Induction training and a register maintained?

MYPD EIA (Section 10); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 1.3); MYPD EMS Manual (Section 7, 15)

Compliant

Evidence of continued HSE

inductions and training at SA

PMT offices for Al Khonaini

representatives arriving on-site.



8

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

8



Are Environmental Tool Box Talks (TBT) being held regularly and documented?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8.1.4); MYPD EMS Manual (Section 7, 15)

Compliant

SAPMT and primary contractor

have TBT for environment on

weekly basis and records were

observed.


9



Is specialist training being undertaken (Dredge Operation)?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 19.1); MYPD EIA (Section 10); MYPD EMS Manual (Section 7, 15)

Compliant

Discussion of continued monthly

training, such as spillage

response drills. Specialist

training for emissions

monitoring equipment planned

before the end of October.


10



Has appropriate environmental signage been erected around the site?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13.2); MYPD Environmental Management Plan (Section 21.3)

Compliant

Environmental/directional

signage noted on site. However,

signage for waste segregation

and chemical storage areas was

noted to be missing, ignored or

misplaced in a number of areas.

HUTA/SARCO: Workers

were observed resting

in a chemical storage

shelter in the pre-cast

area. In multiple

locations, including

the finger jetty and

SARCO camp waste

segregation signage

was not being

observed.

Observation


9

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

11



Is there an Emergency Response Plan and does this refer to environment?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13); MYPD Environment Management Plan (Section 8.1.9); MYPD EMS Manual (Section 11)

Observation

Tamimi: An updated ERP was

provided and included

environmental procedures, such

as emergency spill response.


12



Is there a register to record environmental incidents (e.g. spills)

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EMS Manual (Section 6); MYPD EMS Manual (Section 15)

Compliant Environmental incident

registers are kept. None required. Compliant

13



Does the project have a complaints procedure / register?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 14.1)

Observation

HUTA/SARCO: Provided

previously. Tamimi: A hand-

written logbook has been

created.

It was suggested that

electronic records are

kept and an associated

file is created for

tracking any

complaints.

Compliant


10

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

14



Has the project implemented procedures to manage the displacement of graziers from the site?

MYPD EIA (Section 9.4); MYPD EIA (Section 9.5); MYPD EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)

Compliant

Procedures have not been

development as the site was

considered of low agricultural

importance prior to

commencement. However, on

departure from the site,

security was observed

attempting to move on a group

of camels from the peripheries

of the site boundary.

None required -

continue to monitor. Compliant

Air Quality


11

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

15 Air Quality Has an Air Quality Management Plan been prepared?

MYPD EMS Manual (Section 5,6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8) MYPD EIA (Section 9.4); MYPD EIA (Section 9.5) (Note: EIA Does not describe specifically about Air Quality Management Plan)

Compliant No change. None required. Compliant

16 Air Quality Has a Dust Control Plan prepared?

MYPD EMS Manual (Section 5,6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EIA (Section 9.4); MYPD EIA (Section 9.5); RC Volume I Section 2.3.7 and 2.3.8



12

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

17 Air Quality

Are fugitive emissions monitored (i.e. dust)?

MYPD EMS Manual (Section 12); MYPD EIA (Section 10.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.4.1); SAES-A-102


18 Air Quality

Are air quality monitoring reports submitted to Saudi Aramco PMT?

SAES-A-102 Compliant

Previously included. The

content of the monthly report

to SA PMT will be reviewed for

air quality discussion during

next visit.


19 Air Quality Are stockpiles suppressed where necessary?

MYPD EIA (Section 9.8.1); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3,23), SAES-A-102


20 Air Quality

Are vehicle wheels being cleaned when entering or exiting the construction site?

MYPD EIA (Section 9.8.1); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3) SAES-A-102



13

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

21 Air Quality

Are trucks carrying dry spoil and other waste covered during transportation?

MYPD EIA (Section 9.8.1); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); GERRI 2001 General Environmental Regulations (Article 2)

Compliant

Trucks were observed to be

covered whilst carrying spoil to

the site from external sources.

However, large quantities of

spoil, primarily sand, were

observed uncovered within the

site. Additional spilling from

the back of trucks, through

large gaps in the rear of the

truck bed, was noted.

HUTA/SARCO: The

difficulties in

transporting loose

sand/spoil even over

short distances are

acknowledged.

However, considerable

quantities of spoil

were observed

uncovered and spilling

onto site roads,

subsequently

increasing the volume

of dust/sand in the

air. Consider methods

to improve these

practices.

Observation

22 Air Quality Are unpaved roads watered on daily basis?

MYPD EIA (Section 9.2); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant

Dust suppression activities were

observed and records have

previously been reviewed.



14

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

23 Air Quality

Is a Vehicle Emissions Control Plan provided (e.g. prevention of vehicle idling)?

GAMEP Mobile Source Emissions (Article III) / EIA


24 Air Quality

Do vehicle and equipment performance tests meet vendor specifications prior to commencement of construction activities?

As above; and GAMEP Mobile Source Emissions (Article III)

Observation

HUTA/SARCO: EC showed the

device for checking equipment

and vehicle emissions. Training

for the site team in how to use

the device is planned before

the end of October.

HUTA/SARCO:

Emissions monitoring

and records using the

new equipment will be

reviewed on the next

visit.

Observation


15

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

25 Air Quality

Is there emission rating/performance criteria for equipment utilized on-site?

GAMEP Mobile Source Emissions (Article III)

Observation

HUTA/SARCO: Device now

available for undertaking

emissions testing.

HUTA/SARCO:

Emissions monitoring

and records will be

reviewed on the next

visit. As previously

discussed adding this

process to vehicle and

equipment

maintenance checklist

may be a pragmatic

approach to

implementing

monitoring. Consider

rating/performance

criteria. For example,

this may be based on

GAMEP standards.

Observation

26 Air Quality Black smoke emitted for plant or machinery?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3)

Observation

Al Khonaini: Although site

works are in the very early

stages black smoke was being

emitted from the small set of

heavy plant on-site.

HUTA/SARCO: Across the site,

and many different types of

heavy plant, black smoke was

observed.

Al Khonaini and

HUTA/SARCO:

Consider prioritising

plant emitting black

smoke for

maintenance. It would

also be prudent to

further prioritise plant

emitting black smoke

for emissions testing.

Observation


16

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

27 Air Quality

Are all stationery combustion engine exhaust emissions monitored for NOx, PM10 and SOx?

MYPD EMS Manual (Section 12); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8), GAMEP Mobile Source Emissions (Article III)

Observation

HUTA/SARCO: Device now

available for undertaking

emissions testing.

HUTA/SARCO and

Tamimi: Emissions

monitoring and

records will be review

on the next visit.

Consider a process for

checking generators

periodically. Sharing

the monitoring

equipment to check

the SA PMT Camp

generators (Tamimi)

would be pragmatic.

Observation

28 Air Quality

Are all mobile equipment maintained at the highest possible standard, and tested annually for emissions?

MYPD Environmental Management Plan (Section 8); SAES-A-102; GAMEP Mobile Source Emissions (Article III)

Compliant

Monthly maintenance and

inspection records are

submitted monthly to SAPMT.

As discussed above,

emissions testing with

new equipment could

be included in this

process.

Compliant

29 Air Quality

Do Emissions from dredgers comply with standards for NOx and SOx prescribed in International Maritime Organization (IMO)?

MYPD EIA (Section 9.8.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3)

Compliant

Evidence of inspections

reviewed previously.

International Maritime

Organization (IMO) inspections

take place annually.



17

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

30 Air Quality

Are material storage and loading / unloading areas located away from sensitive receptors

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); EMS Manual (Section 6); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant Confirmed in the areas

inspected. None required. Compliant

Noise


18

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

31 Noise Has a Noise Management Plan been prepared?

MYPD EMS Manual (Section 5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EIA (Section 9.4, 9.5) (Note: EIA Does not describe specifically about Noise Management Plan);SAES-A-105

Compliant

Noise monitoring plan has been

prepared and forms part of the

MYPD EMP.


32 Noise Is ambient noise monitoring undertaken?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.5.1); MYPD EIA (Section 10.1);

Compliant Records previously inspected. None required. Compliant

33 Noise

Are all equipment, machinery and vehicles maintained in a good working condition?

MYPD EIA (Table 9.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13.2)

Compliant

Evidence of inspections

reviewed previously. However,

see notes on black smoke

emissions above.



19

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

34 Noise

Are vehicle noise emissions compliant with GAMEP noise standards?

GAMEP Environmental Noise (Article VII)

Observation

Tamimi: Records for noise

emission monitoring at the

generators observed.

Continue to monitor. Compliant

35 Noise

Are all covers and hatches on equipment properly secured?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EMS Manual (Section 6)


inspected. Continue to monitor. Compliant

36 Noise

Do all high noise plant and equipment have acoustic barriers fitted?




37 Noise Are acoustic barrier doors closed at all times?





20

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

38 Noise

Are noise barriers erected between noise sources and sensitive receptors?

MYPD EIA (Section 9.8.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3, 23)



39 Noise

Is noise producing equipment sited away from sensitive receptors?

MYPD EIA (Section 9.8.6); ); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3)



40 Noise

Are suitable staff resting areas available away from noise generating activities?


Compliant

Staff rest areas are provided

and were observed in the

locations inspected. However,

workers were observed resting

in a chemical storage shelter at

the pre-cast x-block area.

HUTA/SARCO: Resting

areas are provided

away from noise

generating areas,

however, the use of

the correct areas

could be promoted.

Observation

41 Noise

Is there a requirement to adhere to time restrictions for noisy activities?

SAES-A-105; Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); MYPD EMS Manual (Section 6)

Compliant Records previously inspected. None required. Compliant


21

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

42 Noise Is unnecessary revving of engines avoided?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 13.2);

Compliant Not observed in the areas


43 Noise

Are there appropriate signs indicating high noise areas?

MYPD EIA (Section 9.8.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3);



44 Noise Is plant turned off when not in use?




Terrestrial Ecology

45 Terrestrial

Ecology

Are there any ecological sensitive receptors in proximity to site?

SAEP-396 (Section 2)

Compliant

Previously inspected. No issues

noted during site visit.

SA PMT: Positive move on-site

to 'save' two trees from the

main construction area and

transfer these to the SA PMT

Camp.



22

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

46 Terrestrial

Ecology

Is there a requirement to prepare a Terrestrial Biodiversity Management Plan?

MYPD EIA (Section 9.8.4) (Note: EIA does not specifically state the requirement for a Terrestrial Biodiversity Management Plan\)

Compliant Previously inspected. No issues

noted during site visit. None required. Compliant

47 Terrestrial

Ecology

Is there a requirement to implement biodiversity protection measures?

MYPD EIA (Section 9.8.4)



48 Terrestrial

Ecology

Are ecological mitigation measures being implemented?

MYPD EIA (Section 9.8.4)



Archaeology and Cultural Heritage

49 Archaeology and Cultural

Heritage

Are there any archaeological / cultural heritage receptors in proximity to site

n/a Not

applicable No receptors. Not applicable. None required.

Not

applicable


23

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Heritage

Is there a requirement to prepare a Cultural Heritage Management Plan

n/a Not


Not

applicable


Heritage

Is there a requirement to implement archaeological protection measures?

n/a Not


Not

applicable


Heritage

Are archaeological mitigation measures being implemented?

n/a Not


Not

applicable

Waste Management

53 Waste

Management

Is there a Waste Management Plan (WMP) for the project?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); MYPD EMS Manual (Section 5)

Compliant WMP is in place and has been

provided. None required. Compliant

54 Waste

Management

Are waste management mitigation measures addressed in the EIA reflected in the WMP?

MYPD EIA (Section 7.4)

Compliant Confirmed. None required. Compliant


24

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

55 Waste

Management

Are copies of relevant Saudi Aramco Chemical Hazard Bulletins or Materials Safety Data Sheets provided?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.13); GI.150.100

Observation Confirmed in the areas



25

56 Waste

Management

As a waste generator are Waste Tracking Forms issued (Waste Manifest)?

MYPD EIA (Section 7.4, 7.3.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.7) Attachment VI; GAMEP Waste Regulatory Control and Compliance (Article III). GCC Unified Healthcare Waste Management Law.

Minor non-

conformity

HUTA/SARCO: Remaining issues

with RC Landfill not

signing/stamping for receipt of

waste. Also continued use of

ABCO for disposal of hazardous

wastes, outside of the RC

jurisdiction. Bee'ah certificate

to be emailed by EC to confirm

approval to dispose of medical

waste.

Tamimi: Waste manifests for

medical waste (SEPCO) had

been altered by hand and dates

of transportation/disposal raise

issues in accurate waste

manifesting. GAMEP certificate

for Hajar Consulting is required

for transportation/disposal of

hazardous waste outside the RC

boundary.

HUTA/SARCO:

Consider the use of

vendors within the RC

jurisdiction for

hazardous waste

disposal. Procurement

of Bee'ah or ADCO was

discussed with the EC.

Provision of Bee'ah

approvals for medical

waste to be followed

up.

Tamimi: Waste

manifests for medical

waste (SEPCO) should

not be altered and this

will be reviewed on

the next visit.

Similarly to

HUTA/SARCO,

alternatives to Hajar

Contracting were

discussed for

hazardous waste (used

oil) within the RC

jurisdiction (i.e.

Unilube).

Minor non-

conformity


26

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

57 Waste

Management

Are Waste Tracking Forms held on record for 5 years?

MYPD EMS Manual (Section 15); GAMEP Waste Regulatory Control and Compliance (Article III)

Compliant

No change, project requirement

to archive all project

documentation.


58 Waste

Management

Is an approved Waste Transporter used?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.7); RCER-2015-Volume-I (Section 5.8) GAMEP Waste Handling and Storage (Article IV)

Observation

Risal GAMEP certificate not

available. However, discussion

of waste transporting routes

confirmed that waste does not

leave the RC boundary and

therefore RC approval is

sufficient.

Tamimi: GAMEP certificate for

Hajar Consulting is required for

transportation/disposal of


boundary.



27

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

59 Waste

Management

Is an approved waste receiving facility used?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.7); RCER-2015-Volume-I (Section 5.1.6); If RC approval for disposal outside of RC Industrial City: GAMEP Landfill Design and Operation

Compliant No change.

It has previously been

recommended that a

Waste Receiver

register is developed

which lists the waste

receivers used by the

project, the wastes

they are approved to

take (i.e. Class I – III),

and confirmation that

they have an

operator’s licence

from either GAMEP or

RC as applicable, and

issue and expiry dates.

Compliant

60 Waste

Management

Are waste materials transported outside the boundary of Industrial City for storage, treatment or disposal?

RCER-2015-Volume-I (Section 5.3.1)

Observation

HUTA/SARCO: No change to

previous visits. ABCO facility in

Abqaiq continues to be used,

primarily due to

financial/procurement reasons.

Tamimi: GAMEP certificate for

Hajar Consulting is required for

transportation/disposal of


boundary.

HUTA/SARCO: EC to

investigate RC waiver

process for

transporting wastes

outside the boundary

of the Industrial City.

Consider RC approved

vendors within the RC

boundary.

Observation


28

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

61 Waste

Management

Does waste generator record types, quantities and classification of wastes?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.12); RCER-2015-Volume-I (Section 5.2.5, 8); If RC approval for disposal outside of RC Industrial City: GAMEP Waste Regulatory Control and Compliance (Article II); GAMEP Waste Acceptance Criteria (Article II and Article III)

Minor non-

conformity

Tamimi: A clear waste

inventory was provided.

Maintain waste

inventories going

forward.

Compliant

62 Waste

Management

Are non-hazardous waste streams segregated?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); RCER-2015-Volume-I (Section 5.1.11)

Minor non-

conformity

HUTA/SARCO: Food wastes and

general waste observed to be

mixed in multiple locations

across the site. For example; x

block pre-cast yard, SARCO

camp, steel yard and finger

jetty.

Tamimi: Food waste and office

waste observed to be mixed in

an additional skip situated

away from the main waste

storage area, near to the new

chemical storage area.

HUTA/SARCO:

Consider reviewing the

provision and signage

of waste skips across

the site and TBTs with

staff to promote the

correct use of waste

areas.

Tamimi: Consider

having only one waste

storage area with

clear signage to avoid

mixing wastes.

Minor non-

conformity


29

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

63 Waste

Management

Are hazardous and non-hazardous wastes segregated?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); RCER-2015-Volume-I (Section 5.1.11); GAMEP Waste Handling and Storage (Article III)

Compliant

Hazardous and non-hazardous

wastes were segregated in the

areas inspected.


64 Waste

Management

Is there a designated hazardous waste storage area?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10); RCER-2015-Volume-I (Section 5.1.11); RCER-2015-Volume-I (Section 4.3.3, 5.1.10); GAMEP Waste Handling and Storage




30

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

65 Waste

Management

Is the hazardous waste storage area constructed on impervious surface such as concrete or asphalt?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6)



66 Waste

Management

Does the contractor demonstrate clear understanding of SAP EH&S Module requirements for manifesting of hazardous waste and recordkeeping?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management System (Section 10.11.1); MYPD EMS Manual (Section 15); GI 430.001

Compliant Previously discussed, no

change. None required. Compliant

67 Waste

Management

Are storage areas clearly marked and signed with regard to the quantity and hazardous characteristics of the wastes stored therein

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.11); RCER-2015-Volume-I (Section 4.3.16)

Minor non-

conformity

HUTA/SARCO: Multiple used oil

drums (i.e. waste) were

observed outside hazardous

waste storage areas at the

vehicle servicing area. In

addition these were without

drip trays.

HUTA/SARCO:

Promote the use of

appropriate and

clearly marked storage

areas.

Minor non-

conformity


31

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

68 Waste

Management

Are storage areas well maintained and subject to good housekeeping?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment V)

Compliant

Housekeeping was poor across

the project site and the

majority of skips were noted to

be full or overflowing.

HUTA/SARCO: key

areas include the

SARCO camp waste

storage area, vehicle

servicing area and the

main works areas, e.g.

finger jetty. Providing

waste storage in areas

where workers rest

(i.e. surrounding

welfare facilities) and

increasing the

frequency of waste

collection will assist in

achieving compliance.

Observation

69 Waste

Management

Are all skips water tight / in good condition?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (10.10, Attachment V; RCER-2015-Volume-I (Section 4.3.26, 4.4.4, 4.4.5, 5.3.5, 5.3.9)


inspected.

None required.

Continue to discourage

the use of

temporary/unfixed bin

bags etc.

Compliant


32

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

70 Waste

Management

Is there a procedure for reporting spills and leaks?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12.6); MYPD EMS Manual (Section 6); RCER-2015-Volume-I (Section 4.4.7, 8.2.7)


71 Waste

Management

Is there a procedure for cleaning up spills?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12.6); MYPD EMS Manual (Section 6); RCER-2015-Volume-I (Section 4.3.20); GAMEP Waste Handling and Storage (Article XIV)

Compliant

Confirmed, additional spill

response procedures were

noted in Tamimi's ERP.

None required.

Continue to discourage

the use of

Compliant


33

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

72 Waste

Management

Are spill kits available in waste storage areas?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6); MYPD EIA (Table 9.6); RCER-2015-Volume-I (Section 4.3.3, 4.3.19); GAMEP Waste Handling and Storage (Article XIV)



73 Waste

Management

Are hazardous wastes removed off-site within 180 days? The 180 days shall include the storage period of wastes at the premises of generating facility and the disposal facility

MYPD EIA (Section 7.4)(EIA States 90 days) GAMEP Waste Handling and Storage (Article VI);

Compliant Confirmed. None required Compliant

74 Waste

Management

Do waste storage areas minimise the risk of vermin?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23); SAEHC-S-03 (Section 5.1)

Observation

HUTA/SARCO: Evidence of stray

dogs observed at the waste

storage at the SARCO camp.

Uncovered skips were being

used for food waste.

HUTA/SARCO:

Progress on waste

storage across the

site, including the

SARCO camp will

assist in achieving

compliance.

Observation


34

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

75 Waste

Management

Is recycling and reuse addressed and implemented for specific waste streams that can be recycled?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.4); RCER-2015-Volume-I (Section 5.3.2)

Observation

Recycling discussed with

HUTA/SARCO and Tamimi.

Previously discussed with SA

PMT that quantities of recycled

materials could be added to the

weekly project dashboard

report although this was not

reviewed.

Ongoing development

of recycling on-site.

Continue to monitor.

Observation

76 Waste

Management

Are waste generators (within the construction site) trained on implementing the WMP?

MYPD EIA (Section 10.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 14.1, Table 14.1); MYPD EMS Manual (Section 7)



35

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

77 Waste

Management

Does the hazardous waste storage area have a secondary containment system to control any leaks or spills?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6); RCER Volume I (Section 4.3.7); GAMEP Waste Handling and Storage (Article IX)



78 Waste

Management

Are non-compatible hazardous wastes stored in the same area or separately?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Table 14.1); RCER-2015-Volume-I (Section 4.3.6); GAMEP Waste Handling and Storage (Article III)

Compliant Confirmed is the areas



36

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

79 Waste

Management

Is there open burning of waste on site?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment V); MYPD EMS Manual (Section 6); RCER-2015-Volume-I (Section 5.6.2) SAES-S-007 (5.3.3)

Compliant No burning of waste observed. None required. Compliant

80 Waste

Management

Do above-ground hazardous waste storage tanks have secondary containment systems?

MYPD EIA (Section 7.4); MYPD EMS Manual 6.5.6; RCER-2015-Volume-I (Section 4.3.7); GAMEP Waste Handling and Storage (Article IX)



81 Waste

Management

Do underground hazardous storage tanks have secondary containment systems?

MYPD EIA (Section 7.4); MYPD EMS Manual 6.5.6; RCER-2015-Volume-I (Section 4.5.1); GAMEP Waste Handling and Storage (Article IX)

Observation

HUTA/SARCO: Progress noted

with visual inspection checklists

provided. These will be

provided in other languages

appropriate to the individuals

carrying out the inspections.

HUTA/SARCO:

Drawings of the

underground

secondary

containment yet to be

provided.

Observation


37

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

Wastewater

82 Wastewater

Has a Wastewater Management Plan (WWMP) been prepared for the project?

MYPD EIA (Section 7.3.2,7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8), MYPD EMS Manual (Section 6)

Compliant Included in WMP. None required. Compliant

83 Wastewater

Are the types, sources and quantities of generated wastewater provided?

MYPD EIA (Table 7.1); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Plan (Section 20.1, 10.10); RCER-2015-Volume-I (Section 3.4.15, 3.8.6); GAMEP Waste Regulatory Control and Compliance (Article III); GAMEP Waste Acceptance Criteria (Article II)

Minor non-

conformity

Tamimi: Included in the waste

inventories provided for SA PMT

Camp

Maintain wastewater

inventories going

forward.

Compliant

84 Wastewater

If raw sewage is disposed off-site is an EPD waiver in place?

SAES-A-104 (Section 5.1.1.2 f); SAEHC-02 (Section 3.1.2)

Minor non-

conformity EPD waiver required.

SA PMT: Contact EPD

to acquire waiver.

Minor non-

conformity


38

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

85 Wastewater

Is there a procedure to report overflowing holding tanks to Saudi Aramco EPD?

MYPD EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); SAEHC-02 (Section 3.3.4.3)

Observation

HUTA/SARCO: Progress noted

with visual inspection checklists

provided. These will be

provided in other languages

appropriate to the individuals

carrying out the inspections.

Tamimi: Wastewater collected

twice a day, with additional

visits on request if sensors

indicate full tanks. If overflows

occur consider implementing

regular visual checks as

discussed above.


86 Wastewater

Are Waste Manifest Forms held for disposal of sanitary wastewater?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment VI); RCER-2015-Volume-I (Section 5.2.1, 5.2.5); GAMEP Waste Regulatory Control and Compliance (Article III); SAEHC-02 (Section 3.3.4.4);

Minor non-

conformity

All: Continued issues with RC

STP signing/stamping for the

receipt of wastewater.

HUTA/SARCO: RC approval for

FACE as a wastewater

transporter has expired and

new approvals were not

available.

All: Continued effort

to find a solution at

the RC STP to provide

signatures/stamps for

receival of waste.

HUTA/SARCO:

Provision of RC

approval for FACE as a

wastewater

transporter.

Minor non-

conformity


39

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

87 Wastewater

Is a Water Disposal Plan and Water Disposal Request Form required (Water Disposal Approval Form been submitted to EPD 60 days prior to disposal of hydro-test wastewater)?


Not

applicable

Not applicable at this stage of

the project. None required

Not

applicable

88 Wastewater

Is wastewater used for hydro-testing and correctly disposed?


Not

applicable



Not

applicable

89 Wastewater

Is wastewater discharged to an evaporation pond and does the pond(s) meet Saudi Aramco design requirements?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Attachment VII); SAES-A-104 (Section 15)

Compliant

Discussion with SA PMT about

the use of the bentonite

material for backfill in non-

construction areas.

It would be prudent

for SA PMT to seek

advice directly from

EPD.

Compliant


40

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

90 Wastewater

Is wastewater reused on site and is this approved by Saudi Aramco EPD?

MYPD EIA Section (9.8.3); SAES-A-104 (Section 14); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 20.1); SAEHC-02 (Table 1 and Table 16); GERRI 2001 General Environmental Regulations (Article 2)

Not

applicable Not applicable. None required.

Not

applicable

91 Wastewater

Is there any discharge of wastewater to marine waters? Discharges approved by EPD?

MYPD EMS Manual (Section 13); SAES-A-104 (Section 15)

Compliant No change, previously



41

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

92 Wastewater

Is there any discharge to land and if so, permitted by Saudi Aramco EPD?

MYPD EMS Manual (Section 13); SAEHC-02; SAES-A-104; GAMEP Industrial and Municipal Wastewater Discharges (Article II + IV)

Compliant

HUTA/SARCO: Unapproved

discharges to land have been

stopped as per previous

reports. EC indicated that new

holding tanks for pre-cast

concrete wastewater are on

order. These larger tanks will

be used to store and treat

(coagulants) larger quantities of

water until it can be reuse for

general site activities, e.g. dust

suppression. This will vastly cut

down on the wastewater

currently taken away by ABCO.

HUTA/SARCO:

Progress on concrete

wastewater storage

and treatment will be

review on future

visits.

Compliant

93 Wastewater

Are there procedures for monitoring effluent wastewater?

MYPD EIA (Table 10.2); MYPD EIA (Section 9.8.3); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9, Table 14.1); RCER-2015-Volume-I (Section 8.2.2); SAES-A-104 (Section 5.4); SAEHC-02 (Section 2)

Compliant

Water analysis is undertaken

prior to the discharge of

effluent to the marine

environment from marine

vessels

None required Compliant

94 Wastewater

Are there procedures for monitoring hydro-test wastewater?

SAES-A-104 (Section 5.4)

Not

applicable



Not

applicable


42

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

95 Wastewater Has a water conservation plan been prepared?

MYPD EIA (Section 9.8.3); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.11); Saudi Aramco Water Conservation Policy INT-11

Observation

HUTA/SARCO: WCP has been

prepared.

Tamimi: No WCP has been

prepared.

Tamimi: Consider

implementing a water

conservation plan at

the SA PMT camp. This

could be matched to

the new inventory of

wastewater and

involve a programme

to reduce overall

monthly water usage

per number of people

using the camp.

Observation

96 Wastewater

Is storm water drainage system disconnected from sewer lines?

GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant No change, not required at this

stage of the project. None required. Compliant


43

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

Soil & Groundwater

97 Soil &

Groundwater

Has a Groundwater Protection Plan (GWPP) been prepared for the project?

MYPD EIA (Section 10, Table 10.2); MYPD EMS Manual (Section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); GERRI 2001 General Environmental Regulations (Article 2)

Compliant

Groundwater wells installed to

monitor for water level and

contamination only.


98 Soil &

Groundwater

Is groundwater used during construction, and if so, has a permit from Saudi Aramco EPD been approved

MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); RCER 2015; Saudi Aramco Water Conservation Policy INT-11

Compliant

No groundwater abstraction in

place.. There are two

groundwater wells but these

are for monitoring only.


99 Soil &

Groundwater

Is a Drainage and Dewatering Plan required and in place?

SAES-A-114 Observation

Not applicable no dewatering

currently taking place as part

land reclamation works.



44

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

100 Soil &

Groundwater

Are quantities and quality of the water consumption monitored (e.g. site preparation, potable water)?

MYPD EIA (Table 10.2), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9); MYPD EMS Manual (Section 12); RCER-2015-Volume-I (Section 3.13.1)

Compliant Reported monthly to SA PMT. None required. Compliant

101 Soil &

Groundwater

Is ground water quality monitored for suitability of use?

MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); RCER-2015-Volume-I (Section 3.13.1,3.11.4); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Not

applicable

Groundwater is monitored for

quality only; weekly monitoring

and monthly reporting.

Groundwater is not utilized for

construction

Not applicable Not

applicable


45

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

102 Soil &

Groundwater

Is quantity / quality of wastewater reinjection to groundwater aquifer monitored?


Not

applicable Not applicable None required

Not

applicable

Fuels and Chemicals

103 Fuels and Chemicals

Are all fuel and oil stored within a bund / secondary containment?

MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6); RCER-2015-Volume-I (Section 4.3)

Minor non-

conformity

HUTA/SARCO: Multiple oil

drums were observed without

drip trays or bunding at the

vehicle servicing area and at

the finger jetty. Tamimi: Initial

works observed to install

secondary containment for

diesel tank.

HUTA/SARCO:

Promote the use of

appropriate drip drays

where required.

Tamimi: Progress on

the secondary

containment of the

diesel tanks will be

reviewed during the

next visit.

Minor non-

conformity


Are all chemicals stored within a bund / secondary containment?

MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 14.1, Table 14.1, 21.3); RCER-2015-Volume-I (Section 4.3)




46

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Are there procedures for inspecting and testing the integrity of above-ground storage tanks?

MYPD EIA (Section 9.4, 9.5); MYPD EMS Manual (section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)

Compliant Previously inspected,

confirmed. None required. Compliant


Are there procedures for inspecting and testing the integrity of below ground storage tanks?

MYPD EIA (Section 9.4, 9.5)(Note: EIA does not specifically describe about procedure); MYPD EMS Manual (section 6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); RCER-2015-Volume-I (Section 4.5.4)

Observation

HUTA/SARCO: EC indicated

that procurement was in

progress for a 3rd party

contractor to check the

integrity of below ground

storage tanks. Tamimi:

Discussion held on the topic

although no change from

previous visits.

HUTA/SARCO:

Continue to progress.

Tamimi may benefit

from contacting

HUTA/SARCO EC and

combining integrity

checks in the future.

Observation


Does refuelling take place in a sealed area with impermeable surface?





47

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Are refuelling vehicles and equipment inspected and maintained to reduce the risk of leaks and spills?

MYPD EIA (Section 8); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section14); EMS Manual (Section 12)

Compliant

Weekly work permits in place

for each vehicle which include

regular inspections.



Is fuel transfer equipment and methodology acceptable?

MYR EMS Manual (Section 6.0); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8)




Are spill kits available at all fuel storage and refuelling points?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8, 21.3); MYPD EIA (Section 9.8.2); MYR EMS Manual (Section 2); RCER-2015-Volume-I (Section 4.3.19)

Observation

Tamimi: Spill kit was not

available at the fuel storage

area next to one of the main

generators (Generator 2).

Corrective action was

immediately taken

although Tamimi may

benefit from the

purchase of more spill

kits.

Observation


48

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Are spill kits available in waste storage areas?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); MYPD EMS Manual (Section 13)




Are spill kits provided in chemical storage areas?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); MYPD EMS Manual (Section 13)

Compliant

HUTA/SARCO: Spill kits not

observed at all necessary points

at the SARCO steel yard/store

area.

HUTA/SARCO:

Consider providing

spill kits to achieve

compliance.

Observation


Are spill kits carried on refuelling vehicles?

MYPD EMS Manual (Section 2,10, 13); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23);

Compliant

Confirmed in the areas

inspected for refuelling

vehicles.

HUTA/SARCO: It

would be prudent to

provide a spill kit for

the greasing truck,

which may also be

used for other

maintenance works

while out on site.

Compliant


49

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Is there a plan for inspecting completeness and availability of spill kits?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 14.5); MYPD EMS Manual Section 6.0); RCER-2015-Volume-I (Section 4.3.20)

Compliant

Spill kit checklists observed

with spill kits for the most

part. Tamimi held the checklist

in the office although this was

moved to be with the relevant

spill kit during the inspection.



Are hazardous materials stored a min of 50m from drains / wells / water bodies?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6)




Are Saudi Aramco Chemical Hazard Bulletins / Material Safety Data Sheets available in chemical storage areas?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 10.14)

Observation

MSDS sheets observed in various

locations across the site.

However, MSDS sheets and

relevant chemical inventories

were not available at a key

SARCO chemical storage area.

HUTA/SARCO:

Provision of MSDS

sheets and clear

inventories in primary

chemical storage areas

is required to achieve

compliance.

Observation


50

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Are chemical and fuel storage facilities suitably labelled?

Saudi Archirodon / Huta Hegerfeld MYPD Environment Management Plan (Section 6.5.6), MYPD EMS Manual Section 6.0); RCER-2015-Volume-I (Section 4.3.15, 4.3.16)

Compliant

HUTA/SARCO: Food items

found alongside chemicals in

SARCO store yard. These areas

should be clearly labelled and

segregated.

HUTA/SARCO: Clear

segregation between

food and chemical

storage is required to

achieve compliance.

Minor non-

conformity


Is an inventory of chemical materials maintained on site?

Saudi Archirodon / Huta Hegerfeld MYPD Environment Management Plan (Section 6.5.6), MYPD EMS Manual Section 2)

Compliant

HUTA/SARCO: Chemical

inventory unavailable in the

SARCO chemical storage area.

HUTA/SARCO:

Provision of MSDS

sheets and clear

inventories in primary

chemical storage areas

is required to achieve

compliance.

Observation


Are incompatible chemicals stored in separate locations?





Is information displayed regarding compatibility requirements?


Not

inspected

Not observed in the areas

inspected.

HUTA/SARCO:

Consider providing

information on the

compatibility

requirements of the

chemicals stored.

Observation


51

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Do storage areas have adequate space for vehicle manoeuvring to prevent accidental damage to storage vessels / containers?

MYPD EMS Manual (Section 5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12)




Do chemical stores have adequate ventilation?


Not

inspected

HUTA/SARCO: AC warehouse

and separate AC container

inspected. The doors of the AC

container were open and at

least one of the AC units in the

container was not working.

HUTA/SARCO:

Consider methods to

maintain adequate

ventilation, i.e.

closing doors and

fixing faulty AC units.

Observation


Do all chemical containers (at point of use) have drip trays?

MYPD EMS Manual (Section 2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.15); GERRI 2001 General Environmental Regulations (Article 2)

Not

inspected

Confirmed in the areas



52

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)


Do all chemical containers (at point of use) have spill kits?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8, 21.3); MYPD EIA (Section 9.8.2); MYR EMS Manual (Section 2)




Are all chemical / fuel materials stored in original containers?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6)



Spill Management

126 Spill

Management

Stationary diesel and petrol operated equipment have impervious drips trays?




127 Spill

Management

Is emergency communication information displayed at spill sensitive locations?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8), MYPD EMS Manual (Section 8)




53

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

128 Spill

Management

Are fuel / chemical spills and contaminated ground remediated?


Compliant

Tamimi: Spill observed within

generator area. It is understood

the spill was as a result of

maintenance works earlier in

the day although no

remediation had been

undertaken.

Tamimi: Consider

implementing spill

response procedures

when spills occur.

Provision of more spill

kits as previously

highlighted may assist

with this.

Minor non-

conformity

129 Spill

Management

Is there a procedure for managing and reporting marine spills (e.g. chemical, oil etc)?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23), RCER Volume I 3.10

Not

inspected

HUTA/SARCO: ERP contains

spill response procedures both

on and offshore.


130 Spill

Management

Are portable toilets free of leaks?

MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant

HUTA/SARCO: Toilet block in x

block pre-cast area was

observed to be leaking. It was

unclear if this was excess water

from cleaning/leakage or

sewage.

HUTA/SARCO: HSE site

representative

initiated a team to

respond to the leak

and check other

similar toilet blocks.

To be review on next

site visit.

Observation


54

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

131 Spill

Management

Is septic / holding tank overflow prevented?

MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); SAEHC-02 (Section 3.3.4.2)



132 Spill

Management

Are wash basins connected to septic tanks / holding tanks?

MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SAES-A-104

Compliant

HUTA/SARCO: Toilet block in x

block pre-cast area was

observed to be leaking. It was

unclear if this was excess water

from cleaning/leakage or

sewage.

HUTA/SARCO: HSE site

representative

initiated a team to

respond to the leak

and check other

similar toilet blocks.

To be review on next

site visit.

Observation


55

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

133 Spill

Management

If plant washing is taking place is it on a hard standing with collection tank?


Not

applicable

No washing of plant observed

on site. None required.

Not

applicable

134 Spill

Management

Is servicing of plant/vehicles occurring impermeable surface with drainage?

MYPD EIA (Section 9.8.2); Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant Confirmed at the SARCO

vehicle servicing area. None required. Compliant

135 Spill

Management

Are construction materials stored to minimize releases to ground?

MYPD EIA (Section 9.8.2); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5




56

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

136 Spill

Management

Are components containing refrigerants stored correctly to prevent damage and release?

MYPD EMS Manual (Section 6), MYPD Environmental Management Plan (Section 8)

Not

applicable Not applicable None required.

Not

applicable

Resource Management

137 Resource

Management

Are construction materials stored to avoid damage and losses?

MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.3, 23) GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5




57

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

138 Resource

Management

Does the project implement ‘Just on Time’ procurement and delivery?


Not

inspected

Discussed with HUTA/SARCO

EC, all materials/deliveries

come in from KSA and

surrounding GCC countries and

therefore is delivered in short

timeframes on demand.


139 Resource

Management

Is fuel / energy consumption monitored tracked for the project?

MYPD EMS Manual (Section 12), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.13,10.16,12.1, 13.2); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant Confirmed and monthly reports

are sent to SA PMT None required Compliant


58

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

140 Resource

Management

Is water consumption monitored / tracked for the project?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.10); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SA Water Conservation Policy INT-11

Compliant Confirmed and monthly reports

are sent to SA PMT None required Compliant

141 Resource

Management

Is there a programme to promote water and energy conservation?

MYPD EIA (Section 9.8.3); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9.11); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SA Water Conservation Policy INT-11

Observation

Insufficient evidence at this

stage to determine whether

continual improvement

practices are being

implemented across the site.

HUTA/SARCO: WCP in place

although further evidence of

implementation is sought.

All: To achieve

compliance evidence

of water and energy

conservation plans and

implementation is

required.

Observation


59

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

142 Resource

Management

Is there a programme to promote material recycling and reuse?

MYPD EMS Manual (Section 5); MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.4)

Observation

Recycling discussed with

HUTA/SARCO and Tamimi.

Previously discussed with SA

PMT that quantities of recycled

materials could be added to the

weekly project dashboard

report although this was not

reviewed.

Ongoing development

of recycling on-site.

Continue to monitor.

Observation

143 Resource

Management

Is there a programme to inspect water storage tanks and pipes to minimize leakage?

MYPD EMS Manual (Section 5) MYPD EIA (Section 9.8.5, Table 9.6); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5; SA Water Conservation Policy INT-11

Compliant

There is an inspection

procedure for tanks. No

leakages observed during site

visit


Batching Plant

144 Batching

Plant

Are material / aggregate stockpiles suppressed to minimise dust emissions?

SAES-A-102 (5.17); MYPD EIA (Section Table 9.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3),



60

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

145 Batching

Plant

Black smoke emitted from plant or machinery?

MYPD EIA (Section 10.1, Table 10.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9); MYPD EMS Manual (Section 12)

Compliant No black smoke emissions

observed at the batching plant. None required. Compliant

146 Batching

Plant

Are hazardous and non-hazardous wastes segregated?

MYPD EIA (Section 7.4); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan



147 Batching

Plant

As a waste generator are Waste Tracking Forms issued (Waste Manifest)?

MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6); RCER-2015-Volume-I (Section 4.3)

Compliant

Al Kifah: Waste manifests were

not available for inspection and

are kept externally. There is

ambiguity surrounding the

contractors used and the waste

tracking systems in place.

Al Kifah: It was

discussed to maintain

waste inventories and

manifest copies on-

site. This will be

reviewed again on the

next visit.

Minor non-

conformity


61

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

148 Batching

Plant

Are all fuel and oil stored within a bund / secondary containment?

MYPD EIA (Section 9.8.3, 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 14.1, Table 14.1, 21.3); RCER-2015-Volume-I (Section 4.3)



149 Batching

Plant

Are all chemicals stored within a bund / secondary containment?

MYPD EIA (Section 9.8.7); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.10); GAMEP Waste Handling and Storage (Article IV)

Compliant

Al Kifah: Chemicals were

observed to be stored away

from designated storage areas

beneath the batching plant

itself. This area was not bunded

and the drip trays provided

were overflowing.

Al Kifah: The use of

designated and

appropriately

bunded/maintained

areas is required for

chemical storage.

Minor non-

conformity

150 Batching

Plant

Are storage areas well maintained and subject to good housekeeping?

SAEHC-S-03 (Section 5.1)

Observation

Al Kifah: Housekeeping was

poor at the batching plant. As

an example, boxes of fibrous

material required for the

batching process were stored

on a stairwell, in direct

sunlight, against clear

instructions on the boxes to

keep covered and within

certain temperature ranges.

Al Kifah: Consider

improving

housekeeping at the

batching plant.

Observation


62

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

151 Batching

Plant

Do waste storage areas minimise the risk of vermin?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5



152 Batching

Plant

Are spill kits available at all fuel storage and refuelling points?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5




63

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

153 Batching

Plant

Are spill kits provided in chemical storage areas?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 6.5.6, 10.14);GI.150.100 (Section 4.1); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant

Al Kifah: Spill kits were not

provided next to the additional

chemical storage area being

used beneath the batching

plant.

Al Kifah: Chemical

storage issues,

including spill kit

provision requires

addressing to achieve

compliance.

Minor non-

conformity

154 Batching

Plant

Are Saudi Aramco Chemical Hazard Bulletins / Material Safety Data Sheets available in chemical storage areas?

MYPD EIA (Section 9.8.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.13); GI.150.100

Compliant

Al Kifah: Confirmed at the main

batching plant building

although the MSDS sheets were

not available for the chemicals

stored beneath the batching

plant.

Al Kifah: Consider

providing MSDS sheets

next to the relevant

chemicals.

Observation


64

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

155 Batching

Plant

Are all chemical / fuel materials stored in original containers?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 23); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant Confirmed None required Compliant

156 Batching

Plant

Are fuel / chemical spills and contaminated ground remediated?

MYPD EMS Manual (Section 6), Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 8); SAEHC-02 (Section 3.3.4.2); GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5

Compliant No fuel/chemical spills

observed at the batching plant. None required. Compliant


65

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

157 Batching

Plant

Is septic tank / holding overflow prevented?


Major non-

conformity

No overflowing holding tanks

were observed in the areas

inspected.

None required

although continue to

monitor to maintain

compliance.

Compliant

158 Batching

Plant

Is vehicle washout water adequately contained / treated?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 10.2);GERRI 2001 General Environmental Regulations (Article 2); SA Environmental Protection Policy INT-5




66

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

159 Batching

Plant

Are construction materials stored and handled to minimize releases to ground?

SAES-A-102 (5.17); MYPD EIA (Section Table 9.2); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.3),



Off-Shore Operations

160 Off-Shore

Operations

Is there a requirement to prepare a Dredging and Reclamation Environmental Management Plan?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Annex I)

Compliant Yes, this has been inspected. None required. Compliant

161 Off-Shore

Operations

Has a silt screen been installed to prevent sediment dispersion?

MYPD EIA (Table 9.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 20); RCER-2015-Volume-I (Section 6.1.3)

Compliant

Silt screen curtains are used to

mitigate the dispersion of

suspended solids during

dredging and reclamation

activities.



67

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

162 Off-Shore

Operations

Have controls and contingency measures been prepared for the following: Sediment characteristics; marine flora and fauna; water quality; waste management; spill response and emergency procedures; and air and noise?

Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan Annex I (Section 20); MYPD EMS Manual (Section 6)

Compliant

These controls are contained in

the dredging plan and the EMS

documentation


163 Off-Shore

Operations

Is monitoring of turbidity in the areas outside the area of dredging recorded / retained?

MYPD EIA (Table 9.6); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 9); MYPD EMS Manual (Section 12)

Compliant

Confirmed. Daily recording and

‘stop’ controls are in place if

levels exceed 4.5 NTU


164 Off-Shore

Operations

Is a marine wildlife monitoring program adopted during dredging to monitor for their presence each day?

MYPD EIA (Section 9.8.5); Saudi Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Table 14.1); RCER-2015-Volume-I (Section 6.1.2)

Compliant

The primary contractor

conducts daily onshore and

offshore wildlife monitoring

(fauna, birds, avifauna and

mammals) then reports the

records monthly in the

environmental report to SAPMT.



68

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

165 Off-Shore

Operations

Is marine equipment, including dredgers, inspected and maintained (e.g. prevent spills, leaks; emissions comply with standards)? NOTE: Emissions from dredgers shall comply with the standards for NOX and SOX prescribed by the International Maritime Organization (IMO)


Compliant

The primary contractor

conducts a weekly visual

inspection for vessels using a

checklist. Records were

observed at the time of the

visit. No inspection for vehicles

or engines. The primary

contractor is working on having

a device for stack emissions

monitoring (for vehicles,

equipment and vessels). For

vessels, they are inspected

annually by International

Maritime Organization (IMO) as

per the IMO requirements


166 Off-Shore

Operations

Has containment bund been deployed in areas of reclamation?

MYPD EIA (Section 9.8.3); Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 21.9);

Compliant Confirmed from on-shore

None required but to

be reviewed off-shore

during future visits

Compliant

167 Off-Shore

Operations

Has a bunkering procedure been implemented?

Archirodon / Huta Hegerfeld MYPD Environmental Management Plan (Section 12.5)

Not

inspected

Bunkering checklist was

discussed and provided by

HUTA/SARCO EC.


168 Off-Shore

Operations

Are spill kits available during bunkering?

MYPD Environmental Management Plan (Section 12.5);

Compliant

HUTA/SARCO: EC confirmed

spill kits are available on

marine vessels.



69

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

169 Off-Shore

Operations

Do incoming vessels have third party analysis of ballast water indicating the absence of the species as listed by International Maritime Organization (IMO)?

International Maritime Organization Ballast Water Management Convention 2004

Not

inspected

HUTA/SARCO: EC confirmed

this has occurs and archive

records are available from the

marine team.

None required, to be

further reviewed on

next visit.

Compliant

170 Off-Shore

Operations

Do vessels comply with MARPOL Annex I (Regulations for the Prevention of Pollution by Oil)?

The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex I)

Minor non-

conformity

HUTA/SARCO: No longer used

their own trucks for oil

transfers for disposal. ABCO is

used instead.

None required.

However, see notes on

ABCO within waste

management section.

Compliant

171 Off-Shore

Operations

Do vessels comply with MARPOL IV (Prevention of Pollution by Sewage from Ships)?

The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex IV)

Compliant

Each vessel has an onboard STP

which discharges to sea after

treatment. ALS Arabia collect

samples for analysis before it is

discharged to sea.


172 Off-Shore

Operations

Do vessels comply with MARPOL V (Prevention of Pollution by Garbage from Ships)?

The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex V)

Compliant

Waste is collected by

Almandariya and taken to RC

approved landfill. Waste

manifests are available.



70

Item Compliance


Reference Document

Compliance (Q3.3)


(Q4.1)

173 Off-Shore

Operations

Do vessels comply with MARPOL VI (Prevention of Air Pollution from Ships)?

The International Convention for the Prevention of Pollution from Ships (MARPOL, Annex VI)

Not

inspected

HUTA/SARCO: Discussed with

EC. Possibility of using new

emissions testing equipment to

review compliance.

HUTA/SARCO: EC

agreed to look into

this further over and

above visual

inspections.

Observation


71

Appendix A. Environmental Compliance Monitoring Photos

Ref Photographic Evidence: Notes:

62

Mixing of non-hazardous wastes streams on site


72


64

Good Example: Designated hazardous waste storage

area in SARCO vehicle servicing area

67

Used oil drums (i.e. waste) were observed outside

hazardous waste storage areas at SARCO vehicle

servicing area.

117

Food items found alongside chemicals in SARCO store

yard.


73


128

Spill observed within generator area (Generator 2) in

SAPMT Camp.

130

Leaking from toilet block in x block pre-cast areas

149

Drip tray filled with water in the batching plant


74


N/A

Good Example: Moving a tree from the construction

site and replant it in front of SAPMT Camp