Environmental Action Plan: Amran Cement Plant · The aim of the present environmental action plan is to assist ACP in implementing a comprehensive EMP including mitigation, monitoring,

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Environmental Action Plan: Amran Cement Plant March, 2005 Prepared by: Dr. Mutasem El-Fadel, PhD Professor of Environmental Engineering American University of Beirut Mr. Ibrahim Alameddine, MS Environmental Specialist Water & Environment Sustainable Solutions, sarl

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ACKNOWLEDGEMENTS

We wish to extend our appreciation for the support and hospitality of their Excellencies Dr.

Mohamad Al-Iryani, Minister of Water and Environment (MWE) and Mr. Taha Abdullah

Hagir Governor of Amran, Dr. Mahmood Shedewa, Director General of the Environmental

Protection Authority (EPA), Mr. Abdul Malik Al-Amashi, Director General of the Ministry of

Agriculture and Irrigation, Dr. Jamal Nasser and Dr. Nasser Badi Al-Dhayanni from the

Ministry of Public Health, and Mr. Bakea Ali Bakea, Head of the Environmental Committee

in Amran. The assistance of Mrs. Ellen von Zitzewitz at the MWE and Mr. Hillal Al-Riyachi

at EPA are highly appreciated.

We would like to acknowledge the cooperation, assistance and hospitality of Mr. Nooman

Dowaid, General Manager at the Amran Cement Plant (ACP), Mr. Hussein Al-Huseini, Mr.

Abdel Wahab Al-Zubairi, Mr. Hussein Al-Rumaim, and other staff at ACP by providing

information and data about ACP and granting access to the Plant.

We would like to express our sincere gratitude to Ms. Cheri Rassas, Ms. Rana El-Khalil, and

the staff at Abt Associates in Yemen and the US for their dedication and continuous support

throughout the study.

Last but not least, special thanks are extended to the United States Agency for International

Development (USAID) for funding the Environmental Assessment for ACP and for

continuously endorsing much needed developmental projects in Yemen. The feedback and

follow-up of Dr. Douglas Heisler, USAID Director in Yemen, and Dr. Ahmed Attieg, Project

Manager at USAID are highly appreciated.

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PREFACE

The Amran Cement Plant (ACP) has actively been engaged in promoting economic

development in Yemen since it started its operations in October 1982. Our commitment

and contribution towards the improvement of the local economy of the area has been

unparalleled by providing employment opportunities as well as healthcare, education,

accommodation and pension plans for our employees. ACP’s vision towards its social

responsibilities has always ranked high on our priority list whereby we have been and will

continue to be a major donor for various governmental organizations by contributing

funds as well as much needed building materials required for the construction of vital

infrastructure projects, local schools, hospitals, and mosques. ACP is equally committed

towards environmental protection and compliance with health standards. The preparation

of this Environmental Assessment study has been requested and endorsed by the

management at ACP that is committed towards recognizing potential environmental

impacts of our plant to better control and eliminate them. We are equally committed

towards working on the implementation of the proposed environmental management

plans including mitigation and monitoring in a timely fashion as well as contributing to

capacity building and strengthening. Our conviction that the prosperity of our plant is

highly associated with our ability to strengthen our environmental compliance has lead us

to equip our new production line with the state of the art environmental emission control

equipment and to commit to the purchase of the Best Available Technology for reducing

dust emissions from the existing production line. In this respect, we are coordinating with

the United States Agency for International Development (USAID) that has shown interest

and support in complementing our efforts to limit emissions and enhance the well-being

of the inhabitants of Amran by contributing through funding and technical expertise.

Mr. Nooman DowaidGeneral Manager

Amran Cement Plant

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CONTENTS Page

COVER PAGE..........................................................................................................................i

ACKNOWLEDGEMENTS ....................................................................................................ii

PREFACE ...............................................................................................................................iv

CONTENTS .............................................................................................................................v

1. INTRODUCTION............................................................................................................1

2. ENVIRONMENTAL MITIGATION PLAN ................................................................2

3. ENVIRONMENTAL MONITORING PLAN.............................................................10

4. CAPACITY BUILDING, INSTITUTIONAL STRENGTHENING,

AND PUBLIC RELATIONS CAMPAIGN.................................................................14

APPENDIX A.........................................................................................................................17

1

1. INTRODUCTION This Environmental Action Plan (EAP) is based on findings reported in the Environmental

Assessment (EA) for the Amran Cement Plant (ACP). The ACP was initially envisaged as

part of a Five-Year Plan (1976-1981) for Yemen that aimed at promoting development and

boosting the local economy. ACP began production in October 1982 at a capacity of 500,000

tons of Portland cement per annum through the use of a dry manufacturing process. Actual

annual production has exceeded the design capacity in recent years and as such, the

management of ACP adopted a plan to expand its production capacity to 1,600,000 tones per

year. The expansion works, consisting of the addition of a new production line, were recently

commissioned and are currently in an advanced state of execution.

The environmental impact analysis of the existing conditions and the proposed expansion

works showed that potential impacts at ACP are associated with several indicators.

Undoubtedly, ACP provides a positive socio-economic impact related to the increase in job

opportunities for locals as well as providing a product that is much needed to meet the

demand for the construction and development activities that are occurring on the national

scale. In contrast, several potential adverse impacts can negatively affect the environment

particularly those associated with air emissions, effluent discharge, and waste generation. The

assessment clearly indicated that ACP is a major source of dust emissions resulting in

potential high exposure levels. Other indicators that can potentially be impacted include

traffic, noise, surface and ground water quality, soil quality, terrestrial biodiversity, resource

use, health and safety, landscape and visual intrusion. As such, the adoption of a proper

environmental management plan (EMP) will enhance the sustainability of cement production

and the expected benefits from ACP operations. In this context, Table 1 provides a qualitative

summary of the significance of potential environmental impacts that are associated with

operations at ACP with and without the implementation of a comprehensive EMP at the plant.

2

Table 1. Summary of potential impacts with and without adopting an EMP

Magnitude Potential Impact

Without an EMP With an EMP Air quality - - - -/0 Waste generation - - - -/0 Traffic - - - Noise - - - Surface and groundwater quality - - -/0 Soil quality - - -/0 Terrestrial biodiversity - -/+ -/+ + Resource use - - - Health and safety - - - -/+ Landscape and visual intrusions - - - -/+ + Socio-economics -/+ + + -/+ + + +++ High potential positive impact ++ Moderate potential positive impact + Low potential positive impact 0 Neutral impact

- - - High potential negative impact - - Moderate potential negative impact - Low potential negative impact

The aim of the present environmental action plan is to assist ACP in implementing a

comprehensive EMP including mitigation, monitoring, and capacity building by prioritizing

the defined measures, setting the time frame for implementation with corresponding

responsibilities, and defining the location of potential interventions. These elements are

outlined in the remaining of this document.

2. ENVIRONMENTAL MITIGATION PLAN The primary potential adverse environmental impacts that are associated with the operations

at ACP can be controlled or contained by careful planning and adopting proper management

practices, as well as relying on effective environmental monitoring and training to support

management decisions. In the context of the present environmental assessment, a mitigation

plan proposed several impact-mitigation or control measures that will earn ACP more

acceptability, by eliminating or reducing to the extent possible potential impacts. Table 2

presents a summary of the proposed elements of the mitigation plan with an order of priority

that can be adopted by ACP management. The expected time frame for implementation with

corresponding responsibility and locations of interventions are also outlined in Table 2.

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Table 2. Proposed mitigation measures

Implementation time frame (Months) Impact Mitigation measures Priority 1 Attributes/location of intervention Responsibility 0 12 24 36 48 60 >60

• Installing fabric filters (or electrostatic precipitators) to achieve a Particulate Matter (PM)

emission factor of 30 mg/Nm3 from all stacks 1 Exhaust gases from raw mills, kilns, and clinker coolers

• Using water sprays to suppress dust emissions from primary crushers 1 Feeding hood of primary crushers

• Using water sprays (with and without surfactants) on all open piles and storage yards 1 Open and temporary storage piles at ACP

• Installing wind screens around open piles and storage yards 1 Open and temporary storage piles at ACP

• Paving/asphalting the roads and yards that experience a high traffic rate and spraying

regularly with small nozzle water spraying systems 1 Roads within ACP, the road connecting the primary

crusher with the various parts of the quarry, the road connecting ACP to the quarry, and the main yard facing the primary crusher

• Spraying unpaved roads regularly with small nozzle water spraying systems when possible

1 Unpaved low traffic roads

• Enclosing the raw material storage yard, maintaining it under negative pressure and equipping it with fabric filters

1 Raw material storage yard

• Installing adjustable conveyors to reduce dropping height 1 Raw material storage yard

• Ensuring proper maintenance of equipment on-site 2 ACP workshops

• Enforcing speed limits 1 Speed limit of 10 Km/hr on unpaved roads and 20 Km/hr on paved roads within ACP

• Adopting good housekeeping measures at ACP to reduce dust build-up 1 Throughout ACP

• Planting a green-buffer around ACP and the quarry 2 Use endemic species such as Tamarix aphylla, Salvadora persica, Acacia spp, Ziziphus spina-christi, Commifora kataf and Cadaba rotundifolia

• Setting up of an automatic truck wheel-wash facility 3 On the exit from ACP towards the public road network

• Covering trucks carrying dusty cargo with tarps or screening material, when practical 2

• Adopting a pelletization program for the generated Cement Kiln Dust (CKD) 3 CKD storage silo/storage yard Optional

• Wetting, compacting, and covering with a layer of soil CKD at disposal site 1 CKD disposal site

• Adopting combustion control approaches to reduce Nitrogen Oxides (NOx) emissions 3 Preheater/precalcinator kiln Optional • Installing post-combustion control equipment to reduce NOx emissions 3 Preheater/precalcinator kiln stacks Optional • Using low-sulfur fuels and raw materials 2 Fuel tanks and purchasing department Optional

• Adopting a continuous monitoring program of the sulfide sulfur content of the raw materials entering the kiln

2 ACP laboratory

• Adding slaked lime to the exhaust gas of the kiln in order to absorb some of the SO2 in case of elevated sulfur levels in raw materials or fuel

2 Control room and ACP laboratory Optional

Air quality

• Increasing the use of natural pozzolanic materials 2 Control room and ACP laboratory

ACP Management

Optional

• Reducing gas turbulence in the kiln and avoiding excessive flow velocities 1 Preheater/precalcinator kiln

• Using chains near the cool end of the kiln in order to minimize dust generation rates 2 Preheater/precalcinator kiln Optional • Wetting and compacting the generated CKD at the disposal site 1 CKD disposal site

• Reusing the generated CKD in the cement manufacturing process 1 Control room and ACP laboratory

• Reusing the CKD as a soil amendment when possible 1 At agricultural plots with acidic soils Optional • Reusing the CKD as a stabilizing agent when possible 1 At the Amran Wastewater Treatment Plant (AWWTP) Optional • Adopting pelletization of the generated CKD 3 CKD storage silo/storage yard Optional

• Segregating, properly storing, as well as disposing of empty chemical and fuel tanks along with the hazardous wastes generated at the ACP laboratories

1 Temporary solid waste storage areas at ACP

• Labeling the chemical wastes in English and Arabic, as well as storing them in corrosion resistant containers


• Implementing a purchasing and inventory control as well as the “First In First Out” system

2 Purchasing department at ACP

• Selling recyclable faulty equipment to metal recycling industries 2 Temporary solid waste storage areas at ACP

Solid waste

• Transporting non-recyclable equipment especially old fabric filters to a government approved sanitary landfill


ACP Management

4

Implementation time frame (Months) Impact Mitigation measures Priority 1 Attributes/location of intervention Responsibility 0 12 24 36 48 60 >60 • Disseminating information regarding the transportation schedule at ACP 1 Coordinate with Governate of Amran ACP Management

& Governate of Amran

• Limiting truck movements to off-peak hours 1 Coordinate with Governate of Amran ACP Management

• Installing adequate warning and signing at least 500 m down and up-gradient from the entrance of the ACP as well as on the exit that links ACP to the Amran main road

1 Stop signs, heavy machinery signs, and speed bumps ACP Management & Governate of

Amran

Traffic

• Adopting on-site traffic control measures 2 One way traffic within ACP; speed limit of 10 Km/hr on unpaved roads and 20 Km/hr on paved roads within ACP; adequate off-street parking spaces for heavy equipment and trucks

ACP Management

• Introducing good acoustic design for the new production line at ACP 1 Coordination with implementing contractors ACP Management, contractors, consultants

• Adopting proper scheduling of construction activities 3

• Scheduling noisy activities during the daytime periods 1 ACP Management,

contractors, consultants

• Operating well-maintained mechanical equipment on-site 2

• Ensuring that equipment that may be intermittent in use should be shut down between work periods or should be throttled down to a minimum

2

• Installing rubber coating in dumpers and entry chutes 2

• Using personnel protection gear such as earplugs, muffs, etc. 2

• Developing a greenbelt around the quarry area 2 Avoid exotic species and opt for endemic dust resistant

fast growing species such as the Tamarix aphylla, Salvadora persica, Acacia spp, Ziziphus spina-christi, Commifora kataf and Cadaba rotundifolia

ACP Management

• Controlling air-flow generated noise by adopting adequate sizing of inlet/outlet ducts 2 ACP Management, contractors, consultants

• Installing noise barriers around air blowers, pumps, and generators to reduce noise impacts at nearby receptors

1 Near motors, generators, and fans (primary crusher, raw mill, clinker cooler, cement mill, homogenization silos)

• Devising and implementing a rigorous inspection and maintenance program applicable to equipment on-site

1 ACP workshops

• Limiting blasting to trained personnel 1

• Initiating periodic recording of blast vibrations 3 Purchasing vibration meters

• Limiting blasting activities to fixed days and hours that are acceptable with nearby receptors

1 Blasting activities should be limited to weekdays and should avoid early morning hours and evening hours

ACP Management

• Disseminating the blasting schedule to nearby communities 1 ACP Management & Governate of

Amran

• Using of milli-second delay detonator, deck charging, or other techniques to reduce vibrations and noise

1 ACP quarry

Noise

• Increasing the use of surface miners that do not require blasting (currently only one surface miner is present at ACP)

1 Purchase additional surface miners to reduce need for blasting

ACP Management

5

Implementation time frame (Months) Impact Mitigation measures Priority 1 Attributes/location of intervention Responsibility 0 12 24 36 48 60 >60 • Covering open stockpiles of raw material and CKD with tarpaulin or similar fabric during

rainstorm events to prevent the washing away 2 CKD storage piles/yards

• Compacting earthworks at the quarry to prevent erosion especially during the wet season 2 ACP quarry site

• Adopting an adequate disposal/reuse plan for the generated CKD in order to minimize to the extent possible the leaching of alkali dust

1 Adopt wetting, compacting, and soil covering of CKD at the disposal site

• Installing an appropriate drainage system coupled with a sedimentation tank and grease/oil traps in order to reduce exposure time to potential discharge sources

2 Near fuel tanks, workshops, CKD storage piles/yards

ACP Management

• Developing a new mode of payment that compensates the drivers based on the amount of fuel that is actually delivered to ACP and not on the amount of fuel that is loaded at the refinery

1 Maarib refinery in conjunction with purchasing department Optional

• Establishing a buyback station near the oil refinery 1 Operated by Maarib refinery

Safir Refinery

Optional • Establishing a heating system (heating blanket) at the ACP for the fuel tankers in order to

help decrease the viscosity of the fuel 1 Near fuel tanks ACP Management

& Safir Refinery

• Imposing heavy fines that can reach up to dismissing any truck driver that practices uncontrolled discharge of fuels along the road

1 Maarib refinery in conjunction with purchasing department and highway patrol EPA, Police

• Cleaning the existing spillages in the wadis whereby dried fuel spills should be collected and transported to a landfill while fresh fuel pools should be pumped in containers and reused in small industrial kilns or ovens

1 Hiring a qualified contractor with previous experience in cleaning oil leakes EPA, Safir Refinery

• All fuel tanks at ACP should be bunded 1 Bunds should be impermeable and resistant to the stored materials, avoid drains or taps that lead to a blind collection point, incorporate the distribution pipes within the bunded areas while avoiding the penetration of contained surfaces, have a design capacity in excess of 110 percent of the largest tank or greater than 25 percent of the total volume of the tanks, and be subject to regular visual inspection

• Constructing oil-water separators and sand precipitators near workshops and fuel tanks 3 Collected grease and oil should be skimmed before discharge

Surface and groundwater

• Neutralizing the water released from the chemical laboratory 3 Build a stabilization pond with pH meter to collect effluent from ACP laboratory

ACP Management

• Providing for adequate storage, appropriate disposal practices, or complying with soil application rates in case CKD reuse as a soil amendment

1 Disseminate reuse safe practices and monitor application rates and soil pH in affected lands

• Properly storing chemicals and fuels on site 1

• Installing natural or synthetic liners beneath chemical and fuel storage tanks 2

• Developing procedures for emergency clean-up of spilled fuel 2 Implement yearly drills for emergency clean-up crew

Soil quality

• Avoiding the application of agrochemicals during on-site landscaping activities 3

ACP Management

• Preserving existing vegetation when feasible, avoiding fires, prohibiting the disposal of wastes, hazardous and chemical material in non- allocated areas

3

• Initiating a landscaping program on-site, as well as endorsing a well planned restoration and reforestation plan for the quarry and the buffer area

2

• Removing all buildings, equipment, wreckage and wastes following closure of quarry 3 Following Closure

• Reshaping quarry walls to prevent unloading cracks and potentially dangerous collapse 3

• Reshaping of walls and loosening of compacted floors to facilitate revegetation and to ensure the aesthetic quality of the restored landscape

2

• Retaining natural drainage on-site 2 Construct water drains at the quarry site to allow the descent of the water along natural drainage contours

Terrestrial biodiversity

• Adopting a revegetation program that uses indigenous stocks of local vegetation 2 Avoid exotic species and opt for endemic dust resistant fast growing species such as the Tamarix aphylla, Salvadora persica, Acacia spp, Ziziphus spina-christi, Commifora kataf and Cadaba rotundifolia

ACP Management

6

Implementation time frame (Months) Impact Mitigation measures Priority 1 Attributes/location of intervention Responsibility 0 12 24 36 48 60 >60 • Reusing the treated wastewater effluent at the AWWTP for landscaping purposes 3 Coordinate with AWWTP on available quantities and

expected effluent quality ACP Management

& AWWTP Optional

• Using closed loop water recovery systems as well as providing provisions for the collection and use of rainwater

1 Installing closed-circuit cooling water systems with softening and separation for the mills and clinker cooling sections

• Implement a power consumption audit 1 Measure consumption at each production section

• Optimizing the clinker burning process by providing appropriate instruction/training of

the kiln operators as well as through the installation of new equipment such as dosing systems, homogenization silos, pre-blending beds, new clinker coolers, etc.

3

• Using energy-efficient equipment that should be properly operated, maintained, and turned off whenever not in use

2

• Adopting computer aided deposit evaluation and preparation techniques that can be used

to plan for optimal quarrying schemes 3 Purchase/develop a software system that

geographically outlines the characteristics of underlying bed-rock

Resource use

• Exploring the potential use of phospho-gypsum, an industrial byproduct available from fertilizer plant as replacement to natural gypsum

3 Check with nearby fertilizer plants on the availability of phospho-gypsum

ACP Management

Optional

• Defining procedures on explosive handling and other precautions during blasting 1 Define explosive charge, column depth, and appropriate mill-second detonator

• Enforcing site security 3 Restricting access to the facility by proper fencing

Maintaining a buffer area around the facility and the quarry with a radius of 500 m Installing warning signs in Arabic and English at the entrance of the facility to warn people about the risks associated with the cement industry Displaying emergency telephone numbers for Police, Ambulance, and Fire services in Arabic and English Locking gates outside working hours Erecting a fence along the perimeter of the site, consisting of non-combustible wire screens, 3 m high, and with a mesh of 50 mm or less to prevent unauthorized access Erecting site identification board of durable material and finish at the entrance of the site giving the name of the site, and the name, address and telephone number of the site operator Providing at least one 24 hour guard for the facility Keeping a daily record of persons and vehicles entering/leaving the site

ACP Management

Health and safety

• Ensuring site safety 2 Visitors report to the site office where they should sign-in and be issued a pass. Visitors should also sign out on departure and surrender their pass. No visitors should be permitted to access the operational areas unless they have received the express permission and have attended a site safety briefing or are accompanied by an employee familiar and knowledgeable in site safety procedures Staff and employees working on-site attend a safety and operational course before commencing work Personnel and visitors to the operational areas of the site wear personal protective clothing inclusive of high visibility clothing, protective footwear, and safety helmets

ACP Management

7


• Enhancing safety at site facilities 2 Explosives are stored in a remote site within the boundaries of ACP that is far from residential buildings, fuel tanks, and office spaces The explosive storage facility is fenced with barbwire, locked, guarded, and has access to a well-compacted road and fire fighting equipment A drinking water supply is provided at the site Tanks are clearly labeled with details of contents, potential hazards (e.g. explosive, flammable, toxic etc.), and emergency services telephone numbers Closed working spaces are properly ventilated (at least 5 Air Changes per Hour) Electrical grounding is ensured while handrails and guard railing should be regularly inspected and maintained Compacted service roads are provided and maintained from the site entrances to the active quarry areas

ACP Management

• Establishing environmental controls 1 Maintaining a record of the types and quantities of

wastes generated Maintaining a record on the disposal/reuse practices being adopted Ensuring that raw material and CKD transportation vehicles traveling to or from the site are fully sheeted (i.e. flat bed) or well-contained from point of departure to arrival Cleaning vehicles leaving the site of debris from chassis and under-parts Ensuring that no waste materials are burned within site boundaries. A fire should be regarded as an emergency and immediate action should be taken to extinguish it Preventing stagnation of water volumes to hamper insect and vector breeding

ACP Management

Health and safety

• Regulating transportation on-site 3 Vehicles should be cleaned at the end of daily operations Vehicles should be fitted with automatic backing lights and warning sound device Vehicles should be licensed and have appropriate third party insurance Drivers must be in the possession of a current relevant truck driving license

ACP Management

8


• Developing emergency/contingency plans 2 A safety specialist should be responsible for the preparation, implementation and maintenance of a safety program, which should be periodically evaluated. The responsibility of the safety specialist includes performing safety training and conducting safety inspections, sessions and practice. He should also be responsible for the investigation of accidents. A safety committee should be formed and regular safety meetings should be organized. Contingency plans should be established to maintain occupational health and safety procedures for various aspects of operations, identify likely accidents, outline emergency scenarios, establish command hierarchy, organize communication lines, determine response actions, delegate responsibilities, designate evacuation signal, identify rendez-vous points mark on appropriate maps for each work area, and coordinate with local fire service, police and ambulance services. All safety equipment and tools should be regularly maintained. In addition, environmental friendly fire-fighting equipment such as dry powder extinguishers should be provided within the premises of the facility. Annual fire fighting training drills for the operating staff should be conducted. The safety specialist should prepare, implement and maintain a comprehensive fire protection and prevention program. The safety specialist should also be responsible for the inspection and maintenance of the fixed and portable fire protection equipment and for the investigation of fire incidents All emergency exits at ACP should be clearly marked (emergency lights and/or fluorescence), and free from debris to ensure quick and free passage in case of emergency

ACP Management

Health and safety

• Ensuring personnel protection 2 Individuals working on the cement manufacturing line should be provided with overalls, PVC type overalls for wet weather working, respiratory masks, eye protection plugs and defenders, ear protection plugs and defenders; and high visibility waistcoats Uniforms and Personal Protection Equipment (PPE) should be kept hygienic and in good condition. Workers should also be trained on the appropriate use of PPE and be convinced with the importance of using PPE for their own safety and welfare. Personal ID cards should be provided for all employees A trained first aider should be present on-site at all times during operational hours. First aid kits should be kept at several locations and be regularly inspected to replenish any deficiencies The periodic health monitoring program for on-site workers should be enhanced to allow record keeping of all illnesses and accidents occurring on-site. Regular medical checkups should be provided for staff on a semi-annual basis

ACP Management

9

Implementation time frame (Months) Impact Mitigation measures Priority 1 Attributes/location of intervention Responsibility 0 12 24 36 48 60 >60 • Preserving existing floral cover when feasible 3

• Avoiding on-site storage of wastes and equipment 2 ACP Management

• Prohibiting heavy equipment and transport vehicles from parking outside the fenced

boundary of the facility 2 Provide of-street parking spaces for heavy equipment

and transport trucks ACP Management

& Governate of Amran

• Selecting appropriate paint colors for the exterior of the buildings to help them blend with

the surrounding 2

• Complying with the building codes of the area and reducing the construction of elevated structures

2

• Maintaining buildings within the facility to preserve their architectural and visual appeal 2

• Planning and implementing an appropriate landscaping program for the site that takes

into account restoration or creation of native floral cover with local fauna and flora 1

• Planning and optimization quarry operations in order to minimize actively working areas 2

• Shielding the quarrying face of the hill from public view by erecting visual barriers 1

• Quarrying from hill faces away from public view 1

• Adopting a rolling restoration programs (to the extent technically feasible) rather than waiting until quarrying is finished

2

• Provisioning a greenbelt to bar any unsightly intrusion the project may have on the milieu 2 Planting one row of tree seedlings with at least 1 m of

height, one per 3m, along the fence line of the site Dedicate an area corresponding to at least 10 percent of the total site area for landscaping and greenbelt

Landscape and visual intrusions

• Establishing stable landforms and adequate drainage systems prior to the initiation of revegetation work

2 Construct water drains at the quarry site to allow the descent of the water along natural drainage contours

ACP Management

• Reducing potential exposure to emissions, especially dust 1

• Restricting the movement and transportation of heavy machinery outside the sites to off-

peak traffic hours and night time (if noise levels do not exceed the standards) 2

• Providing the local community residing in the vicinity of ACP priority in terms of providing job opportunities, especially to individuals or families that may be negatively affected

1

• Adopting policies to recruit locally and to hire local contractors when possible 2

• Adopting a monitoring plan to assess potential adverse impacts on nearby receptors 1 Regular monitoring reports should be made available

• Instigating a formal system which responds in a timely fashion to complaints about

nuisances (air pollution, noise, etc.) 1 Provide a hotline number with an operator that can

dispatch an investigating team within 24 hr

ACP Management

• Permitting local schools and teams to use the sport courts at ACP’s residential complex 3 Coordinate with local schools and teams

• Making emergency response teams available to local municipalities 3 Coordinate with local fire fighting squadron

• Making company clinics available to the surrounding community 3

ACP Management, NGOs

• Committing to the publishing of data and reports on environmental performance 1 ACP Management,

YCCIM, EPA

Socio-economic

• Providing in-kind contributions to the local community either through cement or other building products

2 ACP Management, NGOs

Priority level: 1= High priority measure; 2= Medium priority measure; 3= Low priority measure : Proposed time period to execute the mitigation measure : Implementation should be immediate and continuous : Continuous implementation of mitigation measures in place

10

3. ENVIRONMENTAL MONITORING PLAN Monitoring of air quality, noise levels, surface and ground water quality, soil quality, waste

generation, terrestrial biodiversity, resource use, traffic, health and safety, landscape and

visual intrusion, and socio-economic indicators as well as operations is essential at ACP.

While ACP can directly assist in the implementation of monitoring activities, it is

recommended that an independent third party consultant be responsible for the overall

implementation of the monitoring in close coordination with ACP, the Environmental

Protection Authority (EPA) representing the Ministry of Water and Environment (MoWE)

and the Yemen Corporation for Cement Industry and Marketing (YCCIM) representing the

Ministry of Industry and Trade (MoIT). Figure 1 depicts a potential framework for

implementing environmental management plans at ACP.

Figure 1. Framework for implementing the environmental management plan

A summary of the monitoring indicators with corresponding location, monitoring frequency,

as well as the proposed time frame for the staged implementation of the proposed monitoring

plan taking into consideration ACP’s logistical constraints is presented in Table 3, while

Appendix A presents draft monitoring forms that can be further refined during the

implementation phase. Note that quarterly monitoring progress reports shall be prepared with

yearly comprehensive reports to present the results of monitoring activities and assess the

adequacy and the needs for improvement of environmental control measures.

Ministry of Industry & Trade

Yemen Corporation for Cement Industry

& Marketing

Amran Cement Plant Environmental

Operations Committee

Oversight of environmental monitoring activities

Contractors Environmental consultant

NGOs and local community

Ministry of Water & Environment

Environmental Protection Authority

11

Table 3. Summary of the proposed monitoring plan

Implementation time frame (Months to implement) Impact Monitoring means Parameters Location Frequency

0 12 24 36 48 60 >60

PM/PM10, NOx, Temperature, oxygen level and SOx Pyro-processing stacks at ACP Biannually until continuous

monitoring program is operational

PM/PM10, Temperature Pyro-processing stacks at ACP Continuous

NOx, and SOx Pyro-processing stacks at ACP Continuous/Monthly

PM/PM10, Temperature Cement grinding stack, clinker

cooler stack, By-pass stack Continuous

PM/PM10, SOx, Temperature, oxygen level, combustion efficiency Combustion sources Biannually

PM/PM10, NOx, and SOx Quarterly

Measurements/Sampling (using the following analysis techniques: extractive, paramagnetic, electrochemical, non dispersive infrared, non dispersive ultraviolet, chemiluminescence, cross-duct opacity)

PM/PM10, NOx, and SOx

Selected receptors (Al-Dhabr village, Amran town, Al-Shadhna village, ACP employee residence, Town of Thila, Town of Hababah, Town of Shibam) Upon complaint/week

Existing fabric filters Monthly or in case of a PM

emission surge

Air quality

Audit Fabric filter components All fabric filters including those present in bag house Directly after the installation of the new fabric filter

Quarry, primary crushers, raw mill, cement mill Biannually

Noise Measurements Leq (dBA) 4 sites selected around the perimeter of the facility (ACP residence complex, Al Darb village, Al Shadhna village, Qa’at Bait Urji village)

Bi-annually and upon complaints

Tapped wells located in the areas surrounding the CKD disposal site (at least 3 wells)

Quarterly

Groundwater wells, installed grease traps, oil/water separators, as well as sedimentation tanks

Quarterly

Surface and groundwater Sampling Temperature, pH, oil content,

suspended solids, COD

Spillage site(s) (responsibility of Safir Refinery and EPA) Every two weeks after spillage

12


0 12 24 36 48 60 >60

Moisture content, pH, salinity, and nutrients (nitrogen, phosphate, potassium, chloride, sodium)

Annual

Soil Sampling

Heavy metal content (mercury, lead, chromium, copper, nickel, zinc and cadmium)

CKD disposal site as well as in the agricultural plots that are treated with CKD

Every three years

Generation, storage, recycling, transport, and disposal ACP and CKD disposal site Quarterly

Audits, photographic documentation, and interviews

CKD generation rate ACP Daily

Solid waste

Sampling pH CKD disposal site Weekly

Visual inspection and photographic documentation General condition of the floral cover ACP, quarry sites, and landscaped

areas Annual

Terrestrial biodiversity

Monitor floral and faunal species composition Diversity, distribution, species ACP, quarry sites, and landscaped

areas Every five years

Metering Water and energy consumption ACP and associated quarries Continuously

Resource use

Audit Raw material consumption ACP and associated quarries Continuously

Proper use of PPE, presence of safety signs, first aid kit, and fire fighting devices

ACP, roads linking ACP with the main road network

Health and safety Health and safety surveys

Injury/illness records ACP

Continuously

Visual inspection and photographic documentation of the existing landscape and assessing the current visual intrusions

Biannually prior to the development and implementation of the landscaping program

Assess the state of the adopted re-vegetation scheme and reassess visual intrusion following 5 years of landscaping

Quarterly

Landscape and visual intrusions

Visual inspection and photographic documentation

Quarry exploitation pattern and resulting visual intrusion

ACP, quarry sites, landscaped area, surrounding receptors

Quarterly

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0 12 24 36 48 60 >60

Field questionnaires Population perception ACP and region of influence Annually

Interviews Employment records ACP Continuously

Socio-economic

Field questionnaires and collecting data from Ministry of Agriculture and Irrigation

Monitor yields in nearby agricultural plots and compare with current yields

Region of influence Annually

Operations monitoring Visual inspection and

documentation

Production rate, gas flow rates, counter readings, pressure values, temperatures, abnormal readings, overloads, stoppage, outages

All facilities and major equipment at the plant and quarry site Daily

: Proposed time period to execute the monitoring program : Implementation should be immediate and continuous : Continuous implementation of monitoring activity in place

14

4. CAPACITY BUILDING, INSTITUTIONAL STRENGTHENING,

AND PUBLIC RELATIONS CAMPAIGNS

In the context of the ACP, capacity building in environmental management falls within several

sectors ranging from the management of air quality, water quality, traffic, solid waste to resource

conservation, health and safety, as well as operations. Proper environmental management dictates

that construction and operation procedures be implemented in accordance to the current state of

the art and knowledge regarding environmental protection. This can be accomplished by hiring

competent personnel with the appropriate educational and professional background and

instituting periodic training programs and site-specific plans. For this purpose, ACP employees

as well as the employees of contractors and consultants involved in the various activities of the

plant should be required to attend environmental training-awareness seminars-workshops. In an

effort to strengthen institutional capacity and enhance environmental awareness, such seminars-

workshops should be opened for individuals from concerned ministries and agencies such as the

MoWE, EPA, NWRA, MoAI, YCCIM, MoIT, MoPH, NGOs, etc. The objective of the seminars-

workshops is to ensure environmental awareness, knowledge and skills for the implementation of

environmental management plans. Seminars-workshops shall be conducted at least twice per year

for a period of one to two days. A maximum of 30 participants should participate in a particular

seminar-workshop, which should address various topics including:

• Environmental laws, regulations, and standards

• Pollution health impacts

• Prevention and control measures

• Sampling techniques and environmental monitoring guidelines (air, noise, water, solid waste,

soil)

• Air quality management

• Solid waste management

• Water and wastewater management

• Traffic and pedestrians safety measures

• Risks associated with the cement industry

• The fundamentals of occupational health and safety procedures

• Procedures for dealing with spillage, fires and other accidents

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• Instructions on the use of protective clothing

• Operating procedures at the plant

• BAT in the cement industry

Furthermore, it is recommended that the permanent staff at ACP that is in charge of coordinating

the implementation of the environmental management plans be given the opportunity to attend

relevant international workshops coupled with study tours at well controlled cement factories to

gain the needed know-how on implementing and advancing adopted environmental management

measures at ACP. The formation of a high level Environmental Committee at ACP (Comprising

the General Manager, the supervising head engineer(s), and the heads of the different

departments) is also conducive at showing commitment to environmental management. The

committee’s role should focus on assessing current environmental practices, developing an

internal audit system, reviewing environmental monitoring reports, identifying required control

measures, initiating public relations campaigns to report and advertise ACP’s environmental

commitment, maintaining a clear environmental policy, and establishing a transparent

communication with governmental and non-governmental agencies concerned in environmental

management. Note that launching a well planned public relations campaign (i.e. television,

billboards, newspapers, seminars at local schools and universities, facility visits) highlighting

ACP’s commitment to environmental protection can significantly improve its image and gain the

trust of the public particularly in the Amran area. Table 4 presents a summary of the proposed

plan for capacity building, institutional strengthening, and improving public relations at ACP

with the corresponding activities, responsibility of implementation, and the proposed time frame.

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Table 4. Summary of the proposed plan for capacity building and institutional strengthening Activity Targeted audience Content/task Responsibility Time frame

Training and awareness

ACP employees as well as the employees of contractors and consultants involved in the various activities of the plant

Environmental awareness, knowledge and skills for the implementation of environmental management plans

ACP management and environmental consultant(s) trainers

Monthly for a period of one to two days during the first year and at least twice per year for a period of one to two days thereafter

Training the trainers

Permanent staff at ACP who are in charge of coordinating the implementation of the environmental management plans

Relevant international workshops coupled with study tours at well controlled cement factories

ACP management 1 to two weeks every year for at least 4 years

Training ACP employees Environmental management, international experience, and relevance to ACP

Permanent staff at ACP that is in charge of coordinating the implementation of the environmental management plans

At least a 2 day workshop twice per year

Formation of a high level Environmental Committee at ACP

Comprising the General Manager, the supervising head engineer(s), and the heads of the different departments

Assessing current environmental practices, developing an internal audit system, reviewing environmental monitoring reports, identifying required control measures, initiating public relations campaigns to report and advertise ACP’s environmental commitment

ACP management

Formation within 6 months Extensive meeting for the first 6 months followed by regular monthly meetings

Compliance with international standards, international accreditation such as ISO 14001

Obtaining environmental and quality accreditation such as ISO 14001

Environmental Committee at ACP

Within 5 years Environmental Committee should monitor progress biannually

Public relations campaigns

General public, Governate of Amran, Ministries and authorities, NGOs

Field questionnaires and interviews Environmental Committee at ACP Continuous engagement

Advertisement General public Television, billboards, newspapers, seminars at local schools and universities, plant visits

Environmental Committee at ACP and ACP management

Following major landmark accomplishments such as (EA report, installation of new Fabric Filter system, operating new production line, initiation of monitoring program, etc.)

17

APPENDIX A Draft monitoring program for ACP

AMRAN CEMENT PLANT

MONITORING REPORT AND ASSESSMENT MANUAL

Name and position Contributed in section(s) Date

Prepared by:

Reviewed by:

Quality control by:

Approved by:

RAW MATERIALS

Raw material consumption

Type of raw material consumed Quantity consumed (tons/month)

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WATER CONSUMPTION

Quantity of surface water being consumed in m3/month:

Quantity of groundwater being consumed in m3/month:

WATER QUALITY

1. Analysis of the water quality being used in production and groundwater quality from the wells surrounding the Cement Kiln Dust (CKD) disposal site:

Water source Analysis parameters Location Description pH Nitrates Calcium Other

Specify the time period between each sampling round:

2. Analysis of drinking water quality at ACP:

Source/sample location pH Calcium E. Coli Nitrates Total

Coliform Fecal

Coliform Free chlorine


Describe sampling procedures:

Specify water analysis lab:

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ENERGY CONSUMPTION

1. Electricity:

Specify the annual average electricity consumption (kWhr/year):

Specify the percentage of the electricity being produced at ACP (%):

2. Fossil Fuels:

Annual fossil fuel consumption rates

Type of fossil fuel Average annual consumption Cost (USD/year)

Fuel type Sulfur content Source

Diesel

Gasoline

Heavy Fuel Oil

Other

Fuel storage tanks

Tank number and location Capacity Fuel type

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SOLID WASTE STREAM Solid waste generation, and management

Type Source Quantity Storage site Treatment option used (if available) Hauling/transport technique Final disposal site

21

HAZARDOUS WASTES

Do hazardous wastes undergo segregation according to type: Yes No In case the hazardous wastes undergo segregation describe the process by filling the following table:

Hazardous waste management

Type Source Quantity Storage

method on-site

Treatment option (if adopted)

Final disposal site

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EMISSIONS AND AMBIENT AIR QUALITY

1. Describe the main point emission sources:

Stack number Site Elevation Diameter Collects emission gases from

Adopted emission reduction technology (if present)

Flue gas exit temperature

Flue gas emission velocity or flow rate

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2. Constituents of air emissions

Constituent Concentration Site/stack Emission

monitoring technique adopted

Treatment technology adopted

(if available)

Flue gas flow rate(m3/hr)

Cement/clinker production during

sampling

Prevalent meteorological conditions during

sampling

Time of sampling

Min: Max: Average: Averaging time:







24

Monitoring constituent release into the atmosphere


Describe sampling equipment used:

Specify party responsible for carrying out the sampling:

Last date equipment undergo calibration:

Party responsible for carrying out calibration:

3. Ambient air quality

Site Parameter Concentration Average time of sampling

Sampling method/

equipment

Cement/clinker production during

sampling Date

Al-Dhabr village

Amran town

Al-Shadhna village

ACP employee residence

Town of Thila

Town of Hababah

Town of Shibam



Last date equipment undergo calibration:

Party responsible for carrying out calibration:

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EFFLUENT QUANTITY AND QUALITY

1. Estimate the quantity of the generated effluent

Source Type Quantity Treatment option adopted Final disposal site

2. Effluent quality assessment:

Source Parameter Concentration Sampling method/ equipment Date



26

NOISE MONITORING

1. Noise level at ACP

Equipment/production section

Cement/clinker production during measurement Noise level dB(A) Date

2. Noise levels at nearby receptors

Location Noise level dB(A) Cement/clinker production during measurement Date

ACP residence complex Al Darb village Al Shadhna village Qa’at Bait Urji village

Specify the time period between each measurement round:

Specify party responsible for carrying out the measurement:

27

SOIL QUALITY

Site Parameters analyzed for Concentrations Date

28

OCCUPATION HEALTH

Personal Protection Equipment

Type Use Employees using it (number and job description)

Maintenance frequency

Party responsible for maintenance

Maintenance frequency for the ventilation system Adopted air changes for the ventilation system Is the indoor lighting sufficient?

Yes No List sections with insufficient lighting:

Are the walkways clean, dry, and easily accessible Yes No List the walkways that are not safe:

Are the emergency exits clearly marked and easily accessible? Yes No

List the emergency exits that do not comply:

Are there certain jobs that are associated with a high rate of absence and/or sickness? Yes No List these jobs:

Describe the type of accidents that happened during the last operational year

Describe the causes that lead to these accidents Describe what has been done to avoid the occurrence of such accidents in the future

Documents

Environmental Action Plan: Amran Cement Plant · The aim of the present environmental action plan is to assist ACP in implementing a comprehensive EMP including mitigation, monitoring,