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Chapter 23
ENVIRONMENTAL CONTROL &
WASTE DISPOSAL
CONTENTS
1. Scope
2. Purpose
3. Definitions
4. Responsibilities
5. Instructions
6. Environmental friendly practices
1. SCOPE
Adherence to requirements in Environmental Control Procedure shall minimise impact of
construction activities to land, air, water, flora and fauna. These requirements apply to
all construction activities and applicable locations throughout camps, Preparation of
Access Ways and work areas associated with installations under control of EPC
SUBCONTRACTOR.

Environmental Control Procedure describes requirements during construction for:


• Spill Prevention and Response
• Waste Management
• Dust Control
• Traffic
• Noise and Vibration Control
Responsibilities, management, co-ordination and review of these environmental activities
are to be implemented by Site Manager in coordination with QA / QC department and
HSE department.

2. PURPOSE
Environmental Control Procedure (ECP) describes environmental compliance activities
for EPC BCONTRACTOR Construction personnel and their subcontracted entities.

Objectives of ECP are to define specific environmental activities required to:


• Comply with Contract, HSE specifications and other applicable environmental
documents,
• Mitigate environmental impact of construction activities.
• Comply with local Environmental Protection Practices

EPC CONTRACTOR Construction team shall comply with this Procedure during
construction, start-up and initial operation of system. Each subcontractor involved in
construction activities shall be provided with a copy of this Procedure and required to
comply with its contents. Periodic reviews of Procedure shall be performed to confirm
its adequacy and Procedure regularly updated as required.

3. DEFINITIONS
Definitions regarding certain terms
1. Safety means safety, health & environment disciplines to support project activities
2. Company means an organization carrying out or prosecuting project

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3. Contractor means organization that has won project from client


4. Subcontractor means an organization that has won part of a project work from Contractor
organization
5. Client means an organization entitle Company in contractual terms that has entrusted
project to organization of Contractor
6. Personnel means all personnel involved on project site activities
7. Responsibility means job & contract responsibility
8. Training means training imparted for specific safety topic on job on project site
9. Management means organization top, middle & lower management
10. Safety Manager means a person with job title Safety Manager deployed by certain
organization
11. Project Manager means a person as such with PM title deployed by Contractor
12. Engineer means a person appointed by client or client company for an overall project
responsibility

EMPLOYER Project owner


Employer Representative A person authorised by EMPLOYER to act on their
behalf
Contractor Representative A person authorised by EPC CONTRACTOR to act on
their behalf
Waste Material or effluent or other unwanted surplus
substance that requires disposal because, it cannot be
re-used or recycled or there is no economic demand for
it.

RESPONSIBILITIES IN GENERAL RESPECTING CERTAIN CONTRACT


POSITIONS
1. Project Manager responsible for overall obligations, to provide schedule, all resources,
direction, engineering resolutions.
2. Site Manager responsible for overall site prosecution management over works &
subcontrcators.
3. Site Safety Officer responsible for overall safety management on site & report to Project
Manager / Site Manager / Corporate Safety Manager
4. Construction Manager responsible to arrange all safety related resources & provide site
team all requirements
5. Project Site Engineer responsible to carry out safety issues within section
6. Site Safety Inspector/Engineer responsible to supervise safety measures on site & control
safety issues, should bring to site line management to adopt correct measures.
7. Site Foremen responsible for compliance of safety measures as standards or as directed
8. An individual working on site responsible to maintain safety measures. In case, missing,
should bring to site team attention

4. RESPONSIBILITIES
EPC CONTRACTOR Site Manager has an overall responsibility for ensuring that
environmental controls described in this ECP are effectively implemented on Site in
coordination with QA / QC Manager and site HSE Manager.

5. INSTRUCTIONS
5.1. Health, Safety & Environmental Impact Assessment
Health, Safety and Environmental Impact Assessment prepared includes an
assessment of impact of Construction activities and Construction Camp on
environment and suggests measures to mitigate the impact.
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Suggestions made are summarised in the table 1, along with control


measures that EPC CONTRACTOR shall be undertaking.

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ENVIORNMENTAL CONTROL PROCEDURE

Table 1: Environmental Issues and EPC CONTRACTOR Control Measures.

1. Construction

Environmental Issue Suggestions EPC CONTRACTOR Control Measures


• Contaminated Land. 1. Soil from areas of contamination shall be removed and EPC CONTRACTOR shall contact local authorities for
Contamination of Land by some accidental oil disposed of to an approved landfill location. disposing contaminated soil in approved land fill
spills or some effluent during construction
activities.
• Protection of ground Waters and Wadis. 1. Wash water run-off requires a system of temporary 1. A silt retention trap shall be constructed at all
Ground waters and other water sources like impoundment and settling to remove silt before returning wash water facilities. This retention shall allow
Wadis are utilised for agriculture and cattle to ground. This shall be carried out during site settling of sand, silt and grease etc. and only clear
feeding by local population and for weeds and preparation. water shall run-off to ground.
plants growing in area. This water source has to 2. Sewage must be treated and only after that, allowed to 2. Sewage Treatment plant shall be installed at each
be protected from pollution from construction run out to ground. Sewage treatment plants shall be camp to control sewage water out-lets.
activities. installed and be operational along with construction camp
3. At isolated locations, local methods shall be followed.

• Site Preparation. 1. EPC CONTRACTOR to have a traffic management 1. Temporary haul roads shall be constructed and
system in place with temporary haul road and traffic kept as clear of sand as is practicable.
segregation, where practicable. 2. Dust suppression measures shall be used to
2. Dust control measures to be implemented. Roads shall be control dust such as water sprays.
maintained to reduce dust as practical.

• Dust. 1. Temporary roads shall be constructed for site traffic. 1. Top layer of fine dust shall be graded away from
Dust shall be exacerbated by site activities such 2. Water spray browsers shall be used. traffic route as practical
as stripping and vehicle movements. 2. Water shall be sprayed to suppress the flying dust.
Area experiences sand storms.
• Noise. 1. Regular inspection of all equipment working on project 1. All equipments shall be maintained to acceptable
Excessive Noise level created by constant shall be done in accordance with manufactures noise level as recommended by manufacturer
operation of plants and equipment. recommendations so as to maintain minimised noise 2. Noise protection equipments shall be used by
levels personal if required to work in high noise level
areas
• Construction Camp. 1. Sewage treatment plant to be installed in camps. 1. Sewage Treatment Plant shall be installed and
Camps shall provide accommodation, catering 2. Traffic segregation must be implemented. maintained to meet requirements arising from
and sanitation for approximately all workforce 3. Dust suppression methods must be implemented. sewage at camps.
ENVIORNMENTAL CONTROL PROCEDURE

Environmental Issue Suggestions EPC CONTRACTOR Control Measures


personnel. Waste arising from these camps shall 2. Heavy traffic shall be separated from light
be significant which shall affect traffic to and vehicles and separate access roads maintained.
from camps. 3. Grading road and water spraying regularly, shall
control dust.
• Oil Spillage. 1. Use of Bunded storage for oil or fuel products for 1. Oil and fuel products shall be stored in bunded
Possible chances of oil leaks and spills from fuel containing accidental leak area for containing accidental leak.
refilling tankers, storage tanks and from brake 2. Availability of recovery facilities for any leaked 2. Recovery materials like absorbents, sand and sand
down of equipment shall contaminate ground and pollutant bags shall be available in vicinity to immediate
pollute adjacent ground water. 3. Use of drip trays while refuelling or handling fuel or use
oil products. 3. Drip trays shall be used to contain leaks, while
handling oil or refuelling.
4. Recovered contaminated soil and associated
materials shall be collected and disposed of in
safe method.
5.2. Spill Prevention and Response
EPC CONTRACTOR believes in prevention first and foremost by keeping
commitment and resorting to best practices throughout construction. However, in
event of an unforeseen natural disaster or manmade incident that results in a threat
to environment, EPC CONTRACTOR shall be prepared to respond in a timely
and effective manner that would limit environmental damage to a minimum. In
many cases, major pollution incidents can be prevented, if appropriate pollution
prevention measures are taken at an early stage. Planning is a key to success.
Both preventive measures and incident response strategy are addressed below.

5.2.1. Spill Prevention


Following procedures shall be carried out to reduce possibility of a spill
that may be harmful to environment or to health and safety of staff:
• Appropriate precautions shall be taken so far as is reasonable, to
protect storage areas and equipment from vandalism.
• Stores of potentially polluting material shall be situated on an
impervious base surrounded by an impervious bund capable of
containing a volume 50% greater than store. Valves shall be checked
periodically on routine HSE inspections to ascertain that they are
closed.
• Special consideration shall be given to certain leakages arising from
surface runoff around temporary stockpiles of materials
• All stationary diesel and petrol operated construction equipment shall
have impervious drip trays placed beneath during operation. Spillages
into drip trays shall be collected for safe disposal
• Vehicles and mobile equipment shall be regularly inspected to be
maintained to confirm for not leaking or dripping. Operators shall be
instructed in their HSE training to notify their supervisors if they
noticed some problems with their vehicles, whereby appropriate
maintenance shall be done. Maintenance of construction plant
maintenance shall be closely supervised and required measures
implemented to prevent hydrocarbon contamination. These measures
shall include use of drip trays, absorbent materials close at hand and
careful disposal of used materials.
• Major equipment and vehicles shall be refuelled on an impervious
base. Care shall be taken not to spill any fuel. Absorbent materials
shall be available closely. Stationary equipment with impervious drip
trays shall be refuelled in-situ, fuel containers be sealed after use and
stored on an impervious base away from water bodies.
• Higher levels of dust containment prevention method shall be used
for contaminated excavated material than used for other material.
Appropriate measures may include use of fine water sprays to
thoroughly moisten all surfaces and maintain surface moist, use of
protective fences or screens to provide prevention from winds,
minimising unnecessary handling of material and enclosure of
excavated material in wind proof containers prior to removal from
site.
5.2.2. Spill Response
Magnitude of discharge/spill shall determine extent of actions that have to
be taken.
Key actions in responding to a spill to minimise its environmental impact
are:
a. Early detection.
Regular inspections and training shall be carried out to enable early
detection. It is everyone’s responsibility to be aware of potential
pollution risks.
b. Notify your supervisor/emergency team
Notify supervisor, who shall notify Site Manager or HSE Manager.
Emergency services shall be notified as necessary.
c. Assess safety risk to humans
• Attempt containment and cleanup operations of spilt substances,
only when it can be performed safely.
• If spilled material is flammable, eliminate sources of ignition near
spill area.
• Personnel and neighbours are to be evacuated, if they are prone to
risk
• Secure area and establish perimeter control at a safe distance from
spill.
d. Stop source of spill.
When it can be performed safely, stop source of spill. Pollution
control equipment shall be available from EPC CONTRACTOR site
administration offices, storage and refuelling areas.
e. Contain spill (if liquid).
Liquid spills - If spill is liquid, its path shall be blocked or diverted
and then soaked up using an absorbent material.
[Gaseous spills/leaks – A gaseous leak must be stopped at source as
soon as possible and then disperse in air. It is not practicably possible
to contain a gaseous leak, but weather conditions should be checked to
assess most likely flow direction into which, leaked/spilled pollutant
shall flow out to. If it is expected to pose a risk to human health, area
shall be emergently evacuated]
f. Clean up.
• No spills shall be rinsed away.
• Contaminated soils and cleanup materials from spills must be
handled properly using personal protective equipment, stored in a
suitable container that is then labelled and stored in appropriate
location for subsequent disposal.
• Screen/cover stockpiles of polluted matter to prevent dispersion.
g. Dispose with care.
Contaminated soils and used cleanup materials shall be treated as
hazardous waste which would be disposed of accordingly to a
designated disposal site.
h. Document incident.
Site HSE Manager shall be responsible for ensuring that a report is
filed containing information on date, time, location, type and quantity
of spilled material, description and cause of incident, action taken,
name of person reporting incident and recommended actions for
ensuring incident doesn’t reoccur.
5.2.3. Spill Response Materials
Spill response/pollution control materials shall be stored in a safe location
on site in close proximity to storage and waste areas. This material is to be
used to contain and clean up pollution, while care shall be taken to dispose
of absorbent materials properly. They shall not be washed away. Site
HSE Manager shall keep stocks well maintained and replenished.
Spill Response materials shall include following:
• Sand
• Sand bags
• Buckets and Shovels
• Storage Containers
Sand is one of most versatile containment materials, which can be used to
soak up spillages of oil and chemicals and used in sand bags either to
block off substances from sensitive areas or channel them off to a
predetermined collection point. Sand stocks must be dry. Buckets and
shovels should be readily available. Mechanical loading shovels,
excavators and dump trucks may also, be available for sand distribution
and clean up. Storage containers for contaminated materials and earth
shall be bund located in waste storage area, labelled and treated as
hazardous waste.
5.3. Waste Management
It is EPC CONTRACTOR’s policy to minimise and reuse/recycle waste materials,
whenever possible and to dispose of remaining wastes in accordance with this
Procedure.

Before wastes can be disposed off appropriately, these first need be categorised
and segregated. This in practice is often made difficult due to wide range of solid,
chemical and effluent waste that need be segregated, stored and disposed off. Site
Manager is responsible for allocation of a trained official to guide and control
classification, storage, handling, transport and disposal of wastes.

Waste can generally be classified as either:


• Domestic and municipal waste
• Nonhazardous industrial waste
• Hazardous waste.

In table 2 over, storage and disposal methods for reusable / recyclable materials,
domestic waste, nonhazardous construction waste, hazardous waste, waste water
and sanitary waste are described.
ENVIORNMENTAL CONTROL PROCEDURE

Table 2: Waste Storage and Disposal Controls

Category Storage Disposal


• ALL WASTES • A specific area shall be designated for storage of • Waste shall be transported to designated area
waste, before it is disposed off site. agreed with Local Authorities, which is
• Selected sites should stand away from water bodies, concerned Municipality.
drainage ditches and shall be located on hardcore to • Disposal of waste shall be delivered to designated
minimise risk of soil contamination. area as necessary, supervised by Local
• Containers shall be bunded, where necessary. Authorities.
• Fire prevention systems and pollution control • Vehicles delivering waste to disposal area shall
equipment shall be provided for storage facilities, be covered where necessary to prevent dropping
where necessary to prevent fires or releases of en route, leaking, sifting or blowing of solid
hazardous materials to environment. waste from vehicle.
• Storage areas should be made inaccessible to animals • Spillages or waste lost from disposal vehicle en
and visitors. route to disposal site shall be promptly cleaned
• Storage containers shall be of sufficient size and up.
quantity to contain all solid wastes generated between • Before starting work, HSE Manager shall
collections. confirm that drivers have specialised training
related to handling and disposal of cargo.
• HSE Manager shall maintain a working file to
record waste being disposed. This shall include
date, time, type of waste, approximate volume of
waste and disposal method.
• Landfill and incineration site shall be periodically
inspected.

• Reusable / Recyclable • Reusable material shall be stored in an orderly • Reusable materials shall be sent to Yard for
• Timber manner and in an accessible location. appropriate recycling
• Metals
• Paper

• Domestic Waste • An adequate number of containers shall be Domestic waste shall be disposed off through
• Food Waste strategically placed over construction areas and Municipality facilities.
• Domestic Trash temporary facilities. These containers shall be
regularly collected and taken to main waste storage
ENVIORNMENTAL CONTROL PROCEDURE

Category Storage Disposal


area.
• All food waste shall be properly stored in containers
with sealed tops to minimise possibility of vermin
infestation.
• Non Hazardous Construction Waste • Construction debris and demolition material shall not Combustible waste shall be taken to Municipality
• Combustible e.g. non reusable timber, card be allowed to accumulate such that it presents an Incineration area
packaging wastes environmental, health and/or safety hazard. Non combustible waste shall be taken to Landfill
• Non combustible e.g. concrete etc. • Inert construction waste shall be segregated into area.
combustible and non combustible.
• Flammable substances must be stored away from
sources of ignition.
• Hazardous Waste: • Site Manager shall confirm that a trained official is Hazardous waste shall be disposed off into area so
According to UN classification hazardous wastes can allocated to guide and control classification, storage, designated by municipality. It shall remain
be categorised as follows: handling, transport and disposal of wastes. segregated and in labelled storage containers.
• Explosives • Hazardous waste shall be retained in a secure area HSE Manager shall register all hazardous waste and
• Gases (including toxic and flammable gases) with an impervious bunded base. disposal methods. Safety Data sheets shall be
• Area shall be located away from sources of ignition. consulted HSE Manager.
• Flammable liquids, including solvents
General points above in ‘ALL WASTES’ section
• Flammable solids • This area shall be at least 17m (50 ft) away from
apply
• Oxidising agents and organic peroxides water bodies and drainage ditches.
Incompatible hazardous wastes shall not be
• Toxic and harmful substances, including • Different types of hazardous waste shall be stored transported together.
toxic metals separately to avoid adverse chemical reactions and
• Radioactive facilitate eventual treatment.
• Corrosives, including acids and alkalis • Hazardous waste shall be stored separately from
nonhazardous waste.
• Other dangerous substances.
• Hazardous waste shall be stored in tightly closed, leak
Hazardous wastes generated on site may include:
proof containers made of or lined with materials that
• Contaminated Land
are compatible with hazardous waste to be stored.
• Chemical Wastes including cleaning fluids, Containers shall be clearly marked with appropriate
lubricants, paints, dye, coating substances, warning labels to accurately describe their contents
solvents, corrosion inhibitors, biocides, and detailed safety precautions. Labels shall be
emulsions etc. waterproof, securely attached and written in local
• Batteries/ Capacitors language and English. Wherever possible, chemicals
• Hydrocarbon Waste should be kept in original container.
• Fire extinguishants • Hazardous chemicals shall be stored and handled in
ENVIORNMENTAL CONTROL PROCEDURE

Category Storage Disposal


accordance with manufacturers Material Safety Data
Sheet (MSDS).
• Spill prevention measures shall be adhered to.
• Site HSE Manager shall register all hazardous waste
and disposal methods. Safety Data sheets shall be
consulted by Site HSE Manager.
• Equipment, materials and skills shall be readily
available to deal with spillages.
• Washing facilities shall be available.

• Sanitary Waste and Waste Water Storage / Treatment • Treated effluent water shall be used for irrigation
• Waste water and sewage arising from camp. • Fresh water supplies shall be segregated from and dust control, after it has been analysed to
wastewater in accordance with Health Requirements confirm that it is safe for such intended purposes.
of Contract Documents. • Sewage treatment plant shall be erected and made
• No wastewater shall be injected into groundwater. operational during first phase of camp
• All wastewater shall be allowed for settling silt before occupancy.
allowing to drain to ground
• All camp units shall be connected to a sewage main,
which run through a PVC pressure line to a treatment
system located adjacent to camp.
• Treatment system shall be based upon use of an
extended aeration activated sludge process with an
aeration system and solids separation using settlement
and would consist of twin streams each with adequate
capacity. All treated effluent shall gravitate to a
chlorine contact tank, where chlorination done to
achieve a chlorine residual of 0.5 – 1.0 ppm prior to
passing to a designated collection basin located
adjacent to camp.
• Facilities shall be maintained by EPC
CONTRACTOR to minimise interruption.
ENVIORNMENTAL CONTROL PROCEDURE
5.4. Dust and Emissions
Most prevalent construction emission is fugitive dust however emissions of
Carbon mono oxide “CO” and related exhaust gases are likely to be released from
diesel generators and other activities, such as onsite painting, refuelling of
equipment, application of adhesives, waterproofing chemicals and incomplete
combustion of fuel in construction equipment. Note that none of planned activities
shall cause release of hydrogen sulphide gas.

Dust and Emissions must be controlled during construction down to an acceptable


level and to achieve this:
• Should be no unnecessary idling of vehicles and machinery.
• Fuel, paint and chemical containers shall be kept sealed, when not directly in
use.
• All vehicles and Construction Plant shall be properly maintained to minimise
excessive exhaust emission. Where possible, engines shall be located away
from work areas.
• Should problems arise for example with defective equipment, which results in
generation of fumes, gases or odours onsite for which, operators shall be
instructed through their HSE Awareness Training to shut down and notify
respective supervisor to facilitate appropriate mitigation response.

Dust shall be controlled as far as, is practicable. Control measures can


significantly help minimise dust in most cases with exception of sand storms. If a
severe sand storm occurs, Site Manager shall decide whether or not, to close site
works. After dust storm has settled, roads shall be cleaned.

Fugitive dust emissions shall be minimised by implementing following controls:


• Water spraying. Shall be conducted at a frequency to keep surfaces moist.
Treated wastewater or ground water shall be used for this purpose.
• All concerned persons shall be required to fully cover with sheeting or spray
water on open bodied trucks hauling sand, gravel or soil between onsite and
offsite areas. All transgressions shall be immediately brought to attention of
hauler concerned by Site HSE Manager. Failure to comply with this
requirement shall result in offender prevented from accessing site.
• If sandblasting operations are required, shall be located and scheduled, so as
to minimise noise and dusting effects on adjacent work areas.
• Excavation faces not being worked shall if required, be moistened. Formation
level shall not be moistened excessively or better avoided.
• Deliveries of finely ground materials shall be using bag form or stockpiled in
specified locations, where material can be suitably covered.
• Minimum drop heights shall be used during material transfer.
• Roads around site, particularly at site entrance, shall be monitored on a
regular basis. Shall be kept as clear from dust and dirt, as is practicable.
Should it required necessary, road in vicinity of site entrance shall also, be
swept.
• Construction personnel shall be required to enter site over prepared surfaces
and park in designated lots.

Should problems arise, which result in excessive dust generation onsite, workers
shall be instructed through their HSE Awareness Training to notify their
supervisor to facilitate appropriate response.
5.5. Traffic
Following traffic controls shall apply:
• Construction area access shall be limited to construction vehicles only.
• Nonessential vehicles parking on site shall be restricted to designate areas.
• Site access shall be limited through established roadways. Traffic shall be
routed to site avoiding residential areas as far as, is practicable.
• The majority of construction vehicles shall be restricted to designate parking
areas. Parking regulations shall be established and enforced.
• All road surfaces shall be maintained in safe and passable conditions.
• Vehicle washing facilities shall be provided onsite.

6. ENVIRONMENTAL FRIENDLY PRACTICES


6.1. Environmental Friendly Construction Practices
6.1.1 Follow all permit and environmental mitigation requirements.
6.1.2 Stay within project boundary. Watch for and avoid flagged exclusion
zones onsite.
6.1.3 Leave wildlife and vegetation alone. Conduct with care project activities
that can affect wildlife and vegetation (e.g. clearing) to avoid unnecessary
disturbance.
6.1.4 Do not dump waste in streams, ponds, lakes, rivers, wetlands, natural
drainages or other sensitive areas.
6.1.5 Implement and maintain erosion control and storm water measures as
appropriate, such as drainage ditches and trenches to divert flows away
from active work areas, structures to prevent situation from reaching
surface waters and sedimentation ponds to settle out storm water
particulates/particles.
6.1.6 Place drip pans under all standing mobile equipment.
6.1.7 Respond to spills by stopping source of spill and immediately notifying
your supervisor. Contain spill and clean it up using absorbent materials.
Do not rinse spill away. Document and report type, quantity of spilled
material, date, time and cause of spill and cleanup as required.
6.1.8 Maintain equipment in proper operating condition. Stockpile overburden,
spoil and fill at least 50 feet/15to 20m from surface water and wetlands,
whenever possible.
6.1.9 Recycle treated wastewater to be reused as dust control, if allowed and
where practicable. Avoid using oil as a dust suppressant.
6.1.10 Store wastes in properly designated areas. Label all containers accurately.
Store hazardous waste securely in closed containers. Ship hazardous
wastes to appropriate treatment and disposal facilities complying with
local requirements.
6.1.11 Do not burn anything except untreated wood.
6.1.12 Recycle / reuse welding rods, used batteries, used oil, solvents, paints,
paper, glass and scrap wood or metal, where required and as much as
possible.
6.1.13 Immediately stop work and notify your supervisor, if human remains or
archaeological artefacts are found.
6.1.14 Immediately stop work and notify your supervisor, if contaminated soil
(unusual colouration or odour) or underground storage tanks are
discovered.
6.1.15 Ask your Supervisor or Environment, Safety and Health
representative, if you have other questions.

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